A. Firm Information SPWM Advisors LLC d/b/a Stonepath Wealth Management (“Stonepath Wealth Management” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission. The Advisor is organized as a Limited Liability Company (LLC) under the laws of the State of Delaware. Stonepath Wealth Management was founded in November 2023 and is owned by Prestige Worldwide Enterprises Inc, and LRG Financial, Inc. The Advisor is operated by Matthew Golba (Chief Executive Officer and Financial Advisor), and Lauren Golba (President, Chief Compliance Officer and Financial Advisor). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Stonepath Wealth Management.
B. Advisory Services Offered Stonepath Wealth Management offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, and retirement plans (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Stonepath Wealth Management's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.
Investment Management Services Stonepath Wealth Management provides customized investment management services for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. Stonepath Wealth Management works closely with each Client to identify their investment goals, objectives, risk tolerance and financial situation in order to create an overall portfolio strategy. Stonepath Wealth Management will then construct an investment portfolio primarily consisting of low-cost, diversified mutual funds, exchange-traded funds (“ETFs”), individual stocks, bonds, option contracts, alternatives, or Independent Managers to meet the needs of its Clients. The Advisor may also recommend the Advisor’s Model Management Services as described below. The Advisor may retain other types of investments from a Client’s legacy portfolio based on portfolio fit and/or tax considerations.
Stonepath Wealth Management’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Stonepath Wealth Management will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
Stonepath Wealth Management evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Stonepath Wealth Management may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Stonepath Wealth Management may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement.
Stonepath Wealth Management may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
At no time will Stonepath Wealth Management accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated Page 4 account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor.
Model Management Services Stonepath Wealth Management provides customized investment strategies through model portfolios (“Model Portfolios”) that are recommended by Advisory Persons or third-party investment advisors. Advisory Persons may recommend that Clients utilize

the Model Portfolios for all or a portion of the Client’s investment portfolio based on the Client’s investment objectives and risk tolerance. The Advisor’s Model Portfolios include several different strategies including Strategic Portfolios (Conservative, Moderate Conservative, Moderate, Growth, and Focused Growth), Core Portfolios, and Stock Models (Growth, Value, and Dividend).
Use of Independent Managers Stonepath Wealth Management will recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Clients investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures).
Financial Planning Services Stonepath Wealth Management will provide a variety of financial planning and consulting services to Clients as part of its investment management services. The Advisor will also provide standalone financial planning services pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs.
Stonepath Wealth Management may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for Page 5 investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor.
Financial Institution Consulting Services The Advisor provides investment consulting services to brokerage customers (herein “Brokerage Customers”) of Mutual Securities, Inc. (herein “MSI”) who provide written consent requesting to receive the Advisor’s consulting services pursuant to a written agreement with the Advisor. Consulting services are strictly on products Clients have purchased through Mutual Securities, Inc. Please see Item 10 – Other Financial Industry Activities and Affiliations for additional details.
C. Client Account Management Prior to engaging Stonepath Wealth Management to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: ●Establishing an Investment Strategy – Stonepath Wealth Management, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
●Asset Allocation – Stonepath Wealth Management will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
●Portfolio Construction – Stonepath Wealth Management will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
●Investment Management and Supervision – Stonepath Wealth Management will provide investment management and ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs Stonepath Wealth Management does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Stonepath Wealth Management.
E. Assets Under Management As of April 15, 2024, Stonepath Wealth Management manages $177,974,559 in Client assets on a discretionary basis. Clients may request more current information at any time by contacting the Advisor.