A. Description of the Advisory Firm
Able Wealth Management LLC (hereinafter “AWML”) is a Limited Liability Company
organized in the State of New Jersey. The firm was formed in July 2018, and the principal
owners are Seth Philip Hodes and Yoel Kaplowitz.
B. Types of Advisory Services
Portfolio Management Services
AWML offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. AWML creates an Investment
Policy Statement for each client, which outlines the client’s current situation (income, tax
levels, and risk tolerance levels). Portfolio management services include, but are not
limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring
AWML evaluates the current investments of each client with respect to their risk tolerance
levels and time horizon. AWML will request discretionary authority from clients in order to
select securities and execute transactions without permission from the client prior to each
transaction. Risk tolerance levels are documented in the Investment Policy Statement,
which is given to each client.
AWML seeks to provide that investment decisions are made in accordance with the
fiduciary duties owed to its accounts and without consideration of AWML’s economic,
investment or other financial interests. To meet its fiduciary obligations, AWML attempts
to avoid, among other things, investment or trading practices that systematically
advantage or disadvantage certain client portfolios, and accordingly, AWML’s policy is to
seek fair and equitable allocation of investment opportunities/transactions among its
clients to avoid favoring one client over another over time. It is AWML’s policy to allocate
investment opportunities and transactions it identifies as being appropriate and prudent
among its clients on a fair and equitable basis over time.
“Held Away Asset” Portfolio Management Services – Pontera Platform
We offer an additional investment management service for “Held Away accounts,” such
as 401(k), 403(b), HSA, and 529 plan accounts. These accounts are not opened at
Charles Schwab or Fidelity. We use a third-party platform, Pontera, to leverage an Order
Management System to implement asset allocation and opportunistic rebalancing
strategies on behalf of clients. We regularly review the available investment options in
these accounts, monitor them, and rebalance and implement our strategies in the same
way we do other accounts, though using different tools as necessary.
A link will be provided to Clients allowing them to connect account(s) to the platform. Once
a client’s account is connected to the platform, we will review the current account
allocations. When deemed necessary, we will rebalance the account considering the
Client’s investment goals and risk tolerance, and any change in allocations will consider
current economic and market trends. The goal is to improve account performance over
time, minimize loss during difficult markets, and manage internal fees that harm account
performance. Client account(s) will be reviewed at least quarterly and allocation changes
will be made as deemed necessary. The Pontera’s platform allows us to avoid having
custody of Clients’ funds since we do not have direct access to Client log-in credentials.
We are not affiliated with Pontera and receive no compensation from Pontera for using
their platform. Pontera charges AWML an annual fee of 0.25% of the assets on their
platform.
Where requested by the client, our Portfolio Management Services may include ongoing
discretionary investment management and monitoring with respect to certain held-away
accounts (e.g., employer sponsored retirement accounts) identified by the client. In order
to manage certain types of held away accounts, we will utilize a third-party platform
provided to us by Pontera Solutions (respectively, the “Pontera Platform” and “Pontera”).
The Pontera Platform allows us to avoid having custody of client funds and securities since
we do not have direct access to client log-in credentials to affect trades. Where these
services are requested, a link will be provided to the client allowing them to connect to the
held away account(s) they desire AWML to manage via the Pontera Platform. Once a
client’s account(s) is connected
to the Pontera Platform, AWML will review the current
account allocations. We will monitor the account on an ongoing basis and when deemed
necessary and appropriate, rebalance the linked account(s) in consideration of the client’s
unique investment goals, needs, and limitations.
Sub-Advisory Platform Sponsors
AWML has entered into agreements with Betterment LLC and Altruist LLC (collectively
“Sponsors”) to utilize their advisory platform technology. These Sponsors have developed
a Platform (as defined below) for use by independent investment advisors such as AWML.
The Platform is a proprietary automated investment management platform for use by
independent investment advisors to offer their clients a customized portfolio of exchange
traded funds, publicly traded equities, fixed income securities, closed end funds and
mutual funds (collectively “Investments”). In connection with the Platform, the Sponsors
provide AWML with technology and related trading and account management services.
Pension Consulting Services
AWML offers consulting services to pension or other employee benefit plans (including
but not limited to 401(k) plans). Pension consulting may include, but is not limited to:
o identifying investment objectives and restrictions
o providing guidance on various assets classes and investment options
o recommending money managers to manage plan assets in ways designed to
achieve objectives.
o monitoring performance of money managers and investment options and making
recommendations for changes
o recommending other service providers, such as custodians, administrators, and
broker-dealers
o creating a written pension consulting plan
These services are based on the goals, objectives, demographics, time horizon, and/or
risk tolerance of the plan and its participants.
Financial Planning
Financial plans and financial planning may include but are not limited to investment
planning; life insurance; tax concerns; retirement planning; college planning; and
debt/credit planning.
Services Limited to Specific Types of Investments
AWML generally limits its investment advice to mutual funds, closed-end mutual funds,
interval funds, fixed income securities, real estate funds (including REITs), insurance
products including annuities, equities, private equity funds, ETFs, treasury inflation
protected/inflation linked bonds, venture capital funds and private placements, although
AWML primarily recommends long term. AWML may use other securities as well to help
diversify a portfolio when applicable.
Federally Insured Cash Account (“FICA”) Program
AWML and entered into a Placement Agent agreement with StoneCastle Network
(“StoneCastle”) to offer a bank deposit bank account program to its clients through which
they (each, a “FICA Depositor”) can make a single deposit with a custodian and such
amount will have 100% Federal Deposit Insurance Corporation (“FDIC”) or National Credit
Union Administration (“NCUA”) insurance coverage up to prescribed amounts. This FICA
program is only offered to eligible clients.
C. Client Tailored Services and Client Imposed Restrictions
AWML offers the same suite of services to all of its clients. However, specific client
investment strategies and their implementation are dependent upon the client Investment
Policy Statement which outlines each client’s current situation (income, tax levels, and risk
tolerance levels). Clients may impose restrictions in investing in certain securities or types
of securities in accordance with their values or beliefs. However, if the restrictions prevent
AWML from properly servicing the client account, or if the restrictions would require AWML
to deviate from its standard suite of services, AWML reserves the right to end the
relationship.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, and certain other administrative fees.
AWML does not participate in wrap fee programs.
E. Assets Under Management
AWML has the following assets under management:
Discretionary Amounts:
Non-discretionary
Amounts:
Date Calculated:
$ 244,423,665 $0 December 2023
In addition, AWML provides consulting to approximately $102,320,801 in 401(k) plan
assets. These services are provided on an Assets Under Advisement (“AUA”) basis