A. Description of the Advisory Firm
B. Types of Advisory Services
adviser for account management. All fees attributable to this service are payable by the client,
and AWM is not compensated by any of its recommended third-party advisers for referrals
made. AWM will review the ongoing performance of the third-party adviser as a portion
of the client's portfolio.
Services Limited to Specific Types of Investments
AWM generally limits its investment advice to mutual funds, fixed income securities, real
estate funds (including REITs), equities, ETFs, treasury inflation protected/inflation
linked bonds and non-U.S. securities. AWM may use other securities as well to help
diversify a portfolio when applicable.
Miscellaneous Disclosures
Periods of Portfolio Inactivity. AWM has a fiduciary duty to provide services consistent
with the client’s best interest. As part of its Portfolio Management services, AWM will review
client portfolios on a regular basis to determine if any changes are necessary based upon
various factors, including but not limited to investment performance, fund manager tenure,
style drift, account additions/withdrawals, the client’s financial circumstances, and changes
in the client’s investment objectives. Based upon these and other factors, there may be
extended periods of time when AWM determines that changes to a client’s portfolio are
neither necessary nor prudent. Clients remain subject to the fees described in Item 5 below
during periods of account inactivity. There can be no assurance that investment decisions
made by AWM will be profitable or equal any specific performance level(s).
Cash Positions. AWM considers cash and cash equivalents (e.g., money market funds, etc.) to
be a material component of a client’s investment allocation. As a result, at any specific point
in time, depending upon perceived or anticipated market conditions/events (there being no
guarantee that such anticipated market conditions/events will occur), AWM may maintain
cash and/or cash equivalent positions for defensive, liquidity, or other purposes. Unless
otherwise agreed, all such cash and cash equivalent positions shall be included as part of
assets under management for purposes of calculating AWM’s advisory fee. Clients are advised
that, at any particular time, AWM’s asset-based advisory fee may exceed the yield earned on
cash and cash equivalent positions.
Client Obligations. In performing its services, AWM shall not be required to verify any
information received from the client or from the client’s other professionals, and is expressly
authorized to rely thereon. Moreover, each client is advised that it remains their
responsibility to promptly notify AWM, in writing, if there is ever any change in their financial
situation or investment objectives.
Retirement Rollovers. A client or prospective client leaving an employer typically has four
options regarding an existing retirement plan (and may engage in a combination of these
options): (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) roll
over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which
could, depending upon the client’s age, result in adverse tax consequences). If AWM
recommends that a client roll over their retirement plan assets into an account to be managed
by AWM, such a recommendation creates a conflict of interest if AWM will earn a new (or
increase its current) advisory fee as a result of the rollover. No client is under any obligation
to roll over retirement plan assets to an account managed by AWM.
ERISA / IRC Fiduciary Acknowledgment. When AWM provides investment advice to a
client regarding the client’s retirement plan account or individual retirement account, it does
so as 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. The way AWM makes money creates some conflicts with
client interests, so AWM operates under a special rule that requires it to act in the client’s
best interest and not put its interests ahead of the client’s.
Under this special rule's provisions, AWM must:
• Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put its financial interests ahead of the client’s when making recommendations
(give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that AWM gives advice that is in
the client’s best interest;
• Charge no more than is reasonable for AWM’s services; and
• Give the client basic information about conflicts of interest.
AWM will tailor a program for each individual client. This will include an interview
session to get to know the client’s specific needs and requirements as well as a plan that will
be executed by AWM on behalf of the client. AWM may use model allocations together
with a specific set of recommendations for each client based on their personal restrictions,
needs, and targets. 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
AWM from properly servicing the client account, or if the restrictions would require AWM
to deviate from its standard suite of services, AWM reserves the right to end the
relationship.
Review of financial circumstances including assessment of retirement strategy, education
goals and other funding requirements.
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. AWM
does not sponsor or participate in wrap fee programs.
AWM has the following assets under management:
C. Client Tailored Services and Client Imposed Restrictions
D. Wrap Fee Programs
E. Assets Under Management
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$698,775,893 $ 0 December 3 1 , 2023
Clients may utilize our firm to prepare personal income and gift tax returns. For those
who do so, a separate fee is quoted and collected. In the case of certain clients, this fee may
be allocated from the asset advisory fee already paid by the client.
Portfolio Management Fees
Total Assets Under Management Annual Fees
$0 - $3,000,000 1.00%
$3,000,000 - $10,000,000 0.60%
$10,000,000 - $25,000,000 0.40%
$25,000,000 - ALL 0.30%
The advisory fee is calculated using the value of the assets in the Account on the last
business day of the prior billing period. Account values for fee calculation purposes are
derived from AWM’s billing platform, which sources valuation information from a single
provider. As such, values used for AWM fee calculation may deviate from values shown
on custodian account statements and related documents for a variety of reasons, such as
differing treatment of accrued dividends and other earnings, settlement timing
differences, and other factors.
These fees are generally negotiable and the final fee schedule will be memorialized in the
client’s advisory agreement. Alternative annual fee arrangements, such as fixed fees, may
be agreed upon between AWM and the client. Certain clients may also be engaged under
legacy fee structures or arrangements that are no longer offered to new clients and are
not discussed herein. All clients are advised to refer to their advisory agreement with
AWM, and any supplements and amendments thereto, for specific details regarding their
fee arrangement.
Clients may terminate the agreement without penalty for a full refund of AWM's fees
within five business days of signing the Investment Advisory Contract. Thereafter, clients
may terminate the Investment Advisory Contract generally with 30 days' written notice.
Selection of Other Advisers Fees