This Disclosure document is being offered to you by Capital A Wealth Management, LLC (“Firm” or “Capital A”)
about the investment advisory services we provide. It discloses information about our services and the way those
services are made available to you, the client.
We are an investment management firm located in New Castle, PA. Capital A was registered with the SEC in
November 2023. David Domenick, Sr., David Domenick, Jr., Brandon Domenick, Joseph Palimino and Michael D.
Richards Jr are the owners of the Firm. Michael D. Richards Jr is Chief Compliance Officer of the firm.
We are committed to helping clients build, manage, and preserve their wealth, and to provide guidance that helps
clients to achieve their stated financial goals. We specialize in retirement investing and income generation. We
will offer an initial complimentary meeting upon our discretion; however, investment advisory services are
initiated only after you and Capital A execute an Investment Management Agreement.
INVESTMENT MANAGEMENT SERVICES
We manage advisory accounts on a discretionary basis. Once we determine a client’s profile, income need, and
investment plan, we execute the day-to- day transactions with or without prior consent, depending on the client’s
agreement with our firm. Account supervision is guided by the client’s written profile and investment plan. We
may accept accounts with certain restrictions if circumstances warrant. We primarily allocate client assets among
various mutual funds, exchange-traded funds (“ETFs”), cash, and individual debt (bonds) and equity securities in
accordance with their stated investment objectives. In some cases, our Firm does utilize pre-built portfolios for
clients based on their risk tolerance and time horizon.
In personal discussions with clients, we determine their objectives, time horizons, risk tolerance and liquidity and
income needs. As appropriate, we also review their prior investment history, as well as family composition and
background. Based on client needs, we develop the client’s personal profile and investment plan. We then create
and manage the client’s investments based on that policy and plan. It is the client’s obligation to notify us
immediately if circumstances have changed with respect to their goals and income needs.
As determined through our Firm’s initial due diligence with the client, we will determine if clients are seeking an
actively managed investment strategy for their account(s). Our Firm will provide ongoing investment review and
management services. This approach requires us to periodically review client portfolios.
With our discretionary relationship, we will make changes to the portfolio, as we deem appropriate, to meet your
financial objectives. We trade these portfolios based on the combination of our market views and your objectives,
using our investment philosophy and strategies as described in Item 8 of this Brochure. We tailor our advisory
services to meet the needs of our clients and seek to ensure that your portfolio is managed in a manner consistent
with those needs and objectives. You will have the ability to leave standing instructions with us to refrain from
investing in particular industries or invest in limited amounts of securities.
You are advised and are expected to understand that our past performance is not a guarantee of future results.
Certain market and economic risks exist that adversely affect an account’s performance. This could result in
capital losses in your account.
USE OF MODEL MANAGERS AND PLATFORM PROVIDER
The determination to use a particular model or models is based on each client’s individual investment goals,
objectives and mandates. Our Firm has entered into an agreement with AE Wealth Management, LLC (“AEWM”),
an SEC registered investment adviser, to provide asset management services that include:
• model money managers
• portfolio managers
• strategists.
As part of the AEWM program, Clients provide our Firm and AEWM discretion to select third party, non-affiliated
investment managers (“Model Managers”) to design and manage model portfolios.
Capital A has access to AEWM’s reporting systems, client relationship management systems and workflow
systems to assist clients to establish an advisory account. Due to this arrangement, AEWM will have access to
client information, but AEWM will not serve as an investment advisor to our clients. Capital A and AEWM are
non-affiliated companies. AEWM charges our Firm an annual fee for each account administered by AEWM. The
annual fee is paid from the portion of the management fee retained by us. Clients receive continuous investment
advice based on investment objective, risk profile and time-horizon. While investment strategies and
recommendations are tailored to the individual needs of each client, they consist of an asset allocation consistent
as outlined in Item 8 of this Brochure.
We will not enter into an investment adviser relationship with a prospective client whose investment objectives
are considered incompatible with our investment philosophy or strategies or where the prospective client seeks
to impose unduly restrictive investment guidelines. However, Clients have the ability to impose reasonable
restrictions on the management of their accounts, including the ability to instruct the firm not to purchase certain
securities.
We do have limited authority to direct the Custodians to deduct our investment advisory fees from accounts, but
only with the appropriate written authorization from clients.
Clients may engage us to advise on certain investment products that are not maintained at our Firm’s
recommended custodian, such as variable life insurance, annuity contracts, and assets held in employer sponsored
retirement plans. Where appropriate, we provide advice about any type of held away account that is part of a client
portfolio.
You are advised and are expected to understand that our past performance is not a guarantee of future results.
Certain market and economic risks exist that adversely affect an account’s performance. This could result in capital
losses in your account.
FINANCIAL PLANNING SERVICES
We include financial planning services as part of our investment management engagement. However, if requested,
we offer standalone financial planning services. Through the financial planning process, our team strives to engage
our clients in conversations around the family’s goals, objectives, priorities, vision, and legacy – both for the near
term as well as for future generations. With the unique goals and circumstances of each family in mind, our team
will offer financial planning ideas and strategies to address the client’s holistic financial picture, including estate,
income tax (Capital A is not a tax services Firm and you should always consult a tax professional), charitable, cash
flow, wealth transfer, and family legacy objectives. Our team partners with our client’s other advisors (CPAs,
Enrolled Agents, Estate Attorneys, Insurance Brokers, etc.) to ensure a coordinated effort of all parties toward the
client’s stated goals. Such services include various reports on specific goals and objectives or general investment
and/or planning recommendations, guidance to outside assets, and periodic updates.
Our specific services in preparing your plan may include:
PERSONAL: We can review family records, budgeting, personal liability, estate information and
financial goals.
TAX & CASH FLOW: We can analyze the client's income tax and spending and planning for past,
current and future years; then illustrate the impact of various investments on the client's current
income tax and future tax liability. Keep in mind, Capital A is not a tax services Firm and clients should
consult a tax professional for specific tax questions and advice.
INVESTMENTS: We can analyze investment alternatives and their effect on the client's portfolio.
INSURANCE: We can review existing policies to ensure proper coverage for life, health, disability,
long-term care, liability, home and automobile.
RETIREMENT: We can analyze current strategies and investment plans to help the client achieve his
or her retirement goals.
DEATH & DISABILITY: We can review the client's cash needs at death, income needs of surviving
dependents, estate planning and disability income.
ESTATE: Some personnel that are appropriately licensed can assist the client in assessing and
developing long-term strategies, including as appropriate, living trusts, wills, review estate tax,
powers of attorney, asset protection plans, nursing homes, Medicaid and elder law.
A written evaluation of each client's initial situation or Financial Plan is provided to the client. Our financial
planning and consulting services do not involve implementing any transaction on your behalf or the active and
ongoing monitoring or management of your investments or accounts. Clients have the sole responsibility for
determining whether to implement our financial planning and consulting recommendations. To the extent that
the client would like to implement any of our investment recommendations through Capital A or retain us to
actively monitor and manage your investments, the client must execute a separate written investment advisory
services agreement with Capital A.
If requested by client, a written financial plan is presented to the client within three (3) months of the contract
date, provided that all information needed to prepare the written financial plan has been accurately and promptly
provided by the client.
TYPES OF RETIREMENT PLAN SERVICES
Our Firm offers (1) Discretionary Investment Management Services, (2) Non-Discretionary Investment Advisory
Services and/or (3) Retirement Plan Consulting Services to employer-sponsored retirement plans and their
participants. Depending on the type of Plan and the specific arrangement with the Sponsor, we may provide one
or more of these services. Prior to being engaged by the Sponsor, we will provide a copy of this Form ADV Part 2A
along with a copy of
our Privacy Policy and Plan Sponsor Investment Management Agreement ("Agreement") that
contains the information required under Sec. 408(b)(2) of the Employee Retirement Income Security Act
("ERISA") as applicable.
The Agreement authorizes our Investment Advisor Representatives ("IARs") to deliver one or more of the
following services:
Discretionary Investment Management Services
These services are designed to allow the Plan fiduciary to delegate responsibility for managing, acquiring and
disposing of Plan assets that meet the requirements of the Employee Retirement Income Security Act of 1974
("ERISA"). We will perform these investment management services through our IARs and charge fees as described
in this Form ADV and the Agreement. If the Plan is subject to ERISA, we will perform these services as an
“investment manager” as defined under ERISA Section 3(38) and as a “fiduciary” to the Plan as defined under
ERISA Section 3(21). Our Firm will review with Sponsor the investment objectives, risk tolerance and goals of the
Plan and provide to Sponsor an Investment Policy Statement (“IPS”) that contains criteria from which we will
select, monitor and replace the Plan's designated investments. Once approved by Sponsor, our Firm will review
the investment options available to the Plan and will select the Plan's investment options in accordance with the
criteria set forth in the IPS. On a periodic basis, we will monitor and evaluate the plan investments and replace any
that no longer meet the IPS criteria.
Non-Discretionary Investment Management Services
These services are designed to allow the Sponsor to retain full discretionary authority or control over assets of the
Plan. We will solely be making recommendations to the Sponsor. We will perform these Non-Discretionary
investment advisory services through our IARs and charge fees as described in this Form ADV and the Agreement.
If the Plan is covered by ERISA, we will perform these investment advisory services to the Plan as a "fiduciary"
defined under ERISA Section 3(21). Our Firm will review with Sponsor the investment objectives, risk tolerance
and goals of the Plan. If the Plan does not have an IPS, we will provide recommendations to Sponsor to assist with
establishing an IPS. If the Plan has an existing IPS, our Firm will review it for consistency with the Plan's objectives.
If the IPS does not represent the objectives of the Plan, we will recommend to Sponsor revisions to align the IPS
with the Plan's objectives. Based on the Plan's IPS or other guidelines established by the Plan, our Firm will review
the investment options available to the Plan and will make recommendations to assist Sponsor with selecting
investments to be offered to Plan participants. Once Sponsor selects the investment options, we will, on a periodic
basis and/or upon reasonable request, provide reports and information to assist Sponsor with monitoring the
Plan’s investments. If a investment option is required to be removed, our Firm will provide recommendations to
assist Sponsor with replacing the investment.
PARTICIPANT INVESTMENT ADVICE
Our Firm will meet with Plan participants, upon reasonable request, to collect information necessary to identify
the Plan participant's investment objectives, risk tolerance, time horizon, etc. We will provide written
recommendations to assist the Plan participant with creating a portfolio using the Plan's investment options or
Models, if available. The Plan participant retains sole discretion over the investment of his/her account.
Retirement Plan Consulting Services
Retirement Plan Consulting Services are designed to allow our IARs to assist the Sponsor in meeting his/her
fiduciary duties to administer the Plan in the best interests of Plan participants and their beneficiaries. Retirement
Plan Consulting Services are performed so that they would not be considered “investment advice” under ERISA.
The Sponsor may elect for our IARs to assist with any of the following services:
• Administrative Support
o Assist Sponsor in reviewing objectives and options available through the Plan
o Review Plan committee structure and administrative policies/procedures
o Recommend Plan participant education and communication policies under ERISA 404(c)
o Assist with development/maintenance of fiduciary audit file and document retention policies
o Deliver fiduciary training and/or education periodically or upon reasonable request
o Recommend procedures for responding to Plan participant requests
• Service Provider Support
o Assist fiduciaries with a process to select, monitor and replace service providers
o Assist fiduciaries with review of Covered Service Providers ("CSP") and fee benchmarking
o Provide reports and/or information designed to assist fiduciaries with monitoring CSPs
o Coordinate and assist with CSP replacement and conversion
• Investment Monitoring Support
o Periodic review of investment policy in the context of Plan objectives
o Assist the Plan committee with monitoring investment performance
o Educate Plan committee members, as needed, regarding replacement of DIA(s) and/or QDIA(s)
• Participant Services
o Facilitate group enrollment meetings and coordinate investment education
o Assist Plan participants with financial wellness education, retirement planning and/or gap analysis
Potential Additional Retirement Services Provided Outside of the Agreement
We and our IARs, in the course of providing Retirement Plan Services or otherwise, may establish a client
relationship with one or more plan participants or beneficiaries. Such client relationships develop in various ways,
including, without limitation:
• as a result of a decision by the plan participant or beneficiary to purchase services from us not involving
the use of plan assets;
• as part of an individual or family financial plan for which any specific recommendations concerning the
allocation of assets or investment recommendations relating to assets held outside of a plan; or
• through a rollover of an Individual Retirement Account ("IRA Rollover").
In providing these optional services, we may offer employers and employees information on other financial and
retirement products or services offered by us and our IARs. If we are providing Retirement Plan Services to a plan,
IARs may, when requested by a participant or beneficiary, arrange to provide services to that participant or
beneficiary through a separate agreement.
When a participant requests assistance with an IRA Rollover from his/her plan to an account advised or managed
by us, we will have a conflict of interest if our fees are reasonably expected to be higher than those we would
otherwise receive in connection with the Retirement Plan Services. For participants invested in plans which we
do not advise, we also have a conflict of interest given that we may not earn any compensation if they remain
invested in their current plan. We will disclose relevant information about the applicable fees charged by us prior
to opening an IRA account. Any decision to affect the rollover or about what to do with the rollover assets remain
that of the plan participant or beneficiary alone.
DISCLOSURE REGARDING ROLLOVER RECOMMENDATIONS
When a client or prospect leaves an employer, they typically have five options regarding their existing retirement
plan: (i) leave the money in the former employer’s plan, if permitted; (ii) roll over the assets to the new employer’s
plan, if one is available and rollovers are permitted; (iii) rollover to a brokerage (self-directed) Individual Retirement
Account (“IRA”); (iv) roll over the assets to an advisory IRA; or (v) cash out the account value (which could,
depending upon the client’s age, result in adverse tax consequences). Clients contemplating rolling over
retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney.
There is an inherent financial incentive for your IAR to recommend that you roll over your assets into one or more
accounts, because the enrollment will generate compensation based on the increase in your IAR’s total assets
under management. We address these financial compensation conflicts by including the disclosure of the conflicts
in this brochure and by requiring your IAR to recommend investment advisory programs, investment securities,
and services that are in the best interest of each client based upon the client’s investment objectives, risk
tolerance, financial situation, and cost. As fiduciaries of the Investment Advisers Act of 1940, we have to act in
your best interest and not put our interest ahead of yours. At the same time, the way Capital A makes money
creates some conflicts with your interests. Clients are under no obligation, contractually or otherwise, to complete
the rollover. Furthermore, if the client does complete the rollover, the client is under no obligation to have the
assets in an account managed by us.
WRAP FEE PROGRAM
Capital A is the sponsor and manager of Wrap Program (the “Program”), a wrap fee program (i.e., an arrangement
where brokerage commissions and transaction costs are absorbed by the Firm). The fee covers transaction costs
or commissions resulting from the management of your accounts, however, most investments trade without
transaction fees today, so our payment of these and other incidental custodial related expenses should not be
considered a significant factor in determining the relative value of our wrap program. Participants in the Program
may pay a higher aggregate fee than if brokerage services are purchased separately. Additional information about
the Program is available in Capital A’s Wrap Brochure, which appears as Part 2A Appendix 1 of the Firm’s Form
ADV.
ASSETS
Because this is our initial SEC application, Capital A has $0 of discretionary assets under management and $0 of
non-discretionary assets under management as of this filing date.