A. Our Ownership and Structure
Satovsky Asset Management, LLC (“SAM”, the “Adviser”, “we”, “us”, the “firm”, or “our”) is a New York
City based wealth management firm. SAM is a limited liability company, organized in Delaware on March
5, 2007. Jonathan M. Satovsky is the Founder, Chief Executive Officer, and principal owner of the firm. Prior
to starting SAM, Mr. Satovsky was a Senior Investment Adviser at Satovsky & Associates, a franchisee of
Ameriprise Financial, Inc. (formerly American Express Financial Advisors, Inc.) since April 1994, during which
time he provided financial planning and investment advisory services for individuals, pension and profit-
sharing plans, trusts, estates, charitable organizations, and corporations. This background was the
foundation for the continuation of these services for clients for which the Adviser serves.
The Adviser provides holistic financial planning, wealth management, investment management and
advisory services to separately managed accounts of high net worth individuals, trusts and estates,
retirement plans, businesses and charitable organizations (collectively referred to as the “Client”, “Clients”,
“Client Account” or “Client Accounts”) on both a discretionary and non-discretionary basis.
B. Our Services
Investment Management Services
For discretionary accounts, SAM tailors its investment strategy in accordance with a specific Client’s
investment objectives. We provide the Client with advice, guidance and implementation based on the
structure of their balance sheet, cash flow and stated goals. Our process seeks to calibrate Client portfolios
based on their need, capacity and willingness to take risk. This process requires ongoing collaboration and
two-way communication (between the Client and SAM) to adjust to the Client changing circumstances. As
a fiduciary, we seek out solutions with the aim of increasing both the probability of our Clients’ long-term
success and the sustainability of their withdrawals from their portfolio. Client investment guidelines or
Investment Policy Statements (“IPS”) may be amended by agreement with the Client and SAM, based upon
changing market conditions or the needs of the Client. The portfolios may deviate significantly from stated
IPS based on SAM discretion, market conditions and our proprietary research seeking to improve
risk/return characteristics of the portfolios. We have a preference to create a passive structure and ideal
path for each Client seeking to reduce taxes and behavioral risk.
For non discretionary Client Accounts, the same process will occur as outlined above, except that Clients
must approve the initial implementation and all subsequent changes to the asset allocation and trades.
Within our non discretionary capacity, we may purchase or sell securities to meet the cash needs of the
Client (including without limitation the payment of our management fee). These purchases and sales will
be executed in a manner such that the resulting allocations will generally match the allocation and target
range for asset classes in the account prior to the purchase or sale. Our advisory services are tailored to the
objectives and strategies of each Client.
On occasion, SAM will source, conduct due diligence, and recommend Clients to invest directly in third-
party alternative investments. Clients must meet the criteria to invest in such funds and have ample
liquidity to remain invested for a longer-term duration due to the potential liquidity constraints of such
investments.
SAM’s clientele is mostly taxable investors, and thus, ongoing efforts are made for optimal asset location,
tax loss harvesting, trading and structure to balance the client’s lifetime goals and various forms of risk
including longevity risk, inflation, taxes, volatility and client’s temperament which are all balancing factors
in the decision-making processes. SAM allocates assets among various investment strategies, with a bias
toward low-fee, tax advantaged investments typically embodied through a passive approach to markets.
However, where certain inefficiencies present themselves or the Firm believes that a manager or strategy
has an unusual advantage in a marketplace, SAM may suggest and employ other strategies. Where
appropriate, these strategies include the use of independent investment manager(s), mutual funds,
exchange-traded funds (“ETFs”), or other listed securities, in accordance with the investment objectives of
its individual clients. Generally, outside scope of traditional risk profile, SAM may recommend investments
in structured notes to clients that have excess cash reserves as a method to potentially increase yields for
clients relative to their individual goals and circumstances. In addition, SAM may recommend that clients
who are “accredited investors”, invest in privately placed securities, which may include debt, equity, and/or
pooled investment vehicles. Where applicable, the Firm also provides advice about client-selected
securities, legacy positions, or other investments held in client portfolios. Clients can engage SAM to
manage and/or advise on certain investment products that are not maintained at their primary custodian,
such as but not limited to life insurance and annuity contracts and assets held in employer sponsored
retirement plans, stock options, deferred compensation and qualified tuition plans (i.e., 529 plans). In these
situations, SAM directs or recommends the allocation of client assets among the various investment options
available within the product as well as seeking to align balance sheet and asset allocation taking these
outside assets into consideration. These assets are generally maintained at the underwriting insurance
company or the custodian designated by the product’s provider.
SAM consults with clients on an initial and ongoing basis to recalibrate as needed. Clients are advised to
promptly notify SAM if there are changes to their financial situation or if they wish to place any limitations
on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the
management of their accounts if SAM determines, in its sole discretion, the conditions will not materially
impact the performance of a management strategy or prove overly burdensome to the Firm’s management
efforts.
Digital Wealth Management Platform
SAM has partnered with Betterment for Advisors, a digital wealth management platform, through
Betterment, LLC and Betterment Securities, (collectively referred to as “Betterment”).
SAM may recommend this web-based electronic investment advisory program operated and provided by
Betterment to provide services including but not limited to account opening, asset allocation, execution,
rebalancing, daily tax-loss harvesting, asset location and financial projections, where applicable. Under this
arrangement, clients must execute a separate discretionary investment advisory agreement with
Betterment to serve as a sub-advisor. This online agreement provides access to Betterment’s
automated
investment allocation platform as well as Betterment’s brokerage and custodial services which clients can
access these accounts exclusively through Betterment’s website which outlines the terms, conditions and
fees of the relationship.
Clients provide Betterment with their financial circumstances and other information and their portfolio is
created with asset allocations in exchange-traded funds (ETFs) that match tolerance levels of equity
exposure relative to Client goals-based planning. Betterment then provides investment advice to the client
and directs trades to its affiliate broker-dealer, Betterment Securities (neither client nor SAM can enter
trades).
Advice provided by Betterment is computer-generated, and therefore inherently has several limitations
(including that neither SAM nor Betterment can ensure that the Program can achieve any particular
investment or tax result for any client; the algorithm may rebalance Program accounts without regard to
the then-current market conditions or on a more frequent basis than the client might otherwise expect the
algorithm may not address prolonged market condition changes and the mathematical algorithms
employed are designed properly, updates with new data and can accurately predict future security, market,
industry, and sector performance); SAM will be unable to manage your Program account in a way we may
otherwise advise for advisory accounts we manage; Betterment can amend the terms of the client’s
agreement at any time; A client’s participation in the web-based electronic investment advisory program is
subject to numerous conditions (as noted on the website); Clients must agree to arbitration of any disputes
they may have with Betterment.
SAM’s Digital Wealth Management offering seeks to align clients’ portfolios through a combination of ETFs
to clients’ specific goals and therefore the risk profiling process seeks to consider age, time frame, equity
exposure and rebalanced as tax-efficiently as possible seeking to minimize the Behavioral Gap over a
lifetime, which is the difference between investment returns and investor returns due to behavioral biases.
Institutional, Charitable and Retirement Plan Services
We engage with various endowments, charitable gift trusts, and ERISA plans in a wide range of capacities.
For ERISA plans, this includes serving as a 3(21) fiduciary providing investment recommendations to the
plan sponsor and/or trustee, or as a 3(38) investment manager, relieving the plan sponsor or trustee of
their fiduciary responsibility and assuming the investment management decision making for the plan.
In addition, SAM has adopted policies and procedures designed to comply with the ERISA fiduciary
standards when advising retirement asset rollovers as set forth in the Department of Labor Fiduciary Rule
(‘’DOLE PTE”). Client will be presented with disclosure documents as prescribed by DOL PTE.
Consulting, Financial Planning and Wealth Advisory Services
SAM also is available for a fee to provide certain consulting services with respect to financial planning
services as well as financial advice on non investment related matters such as but not limited to the
following:
General financial oversight
Balance sheet and ongoing cash flow monitoring
Debt Management (Mortgages, Personal/Business Lines of Credit and Margin agreements)
Wealth Transfer and Estate Planning
Income Tax review and Planning
Insurance Review
Employee and Executive Benefits
Concentrated Equity and Business Ownership
Stock Options and Restricted Stock Awards
Pension and Annuity Evaluations
Philanthropy
Behavioral Coaching
Under this arrangement, any recommendations provided by SAM may be implemented at the Client’s sole
discretion with the professional consultants of Client’s choosing, and there is no obligation to engage SAM
for investment advisory services. In performing these services, SAM is not required to verify any
information received from the client or from the client’s other professionals (attorneys, accountants, and
other advisors) and is expressly authorized to rely on such information.
We also may provide certain Investment Only Client Accounts with financial planning services as well as
financial advice on non investment related matters such as those listed above. To the extent we provide
any financial consulting services beyond the management of assets, such services are provided as part of,
and incidental to, our management services.
With respect to any financial planning/consulting services provided by SAM, each Client must acknowledge
to us that: (i) such Client is free at all times to accept or reject any of our recommendations, and such Client
acknowledges that such Client has the sole authority with regard to the implementation, acceptance, or
rejection of any recommendation or advice from us; (ii) our recommendations (i.e., estate planning,
retirement planning, insurance, etc.) may be discussed and/or implemented, at such Client’s sole
discretion, with the corresponding professional adviser(s) (i.e., broker, accountant, attorney, etc.) of such
Client’s choosing; (iii) in respect to estate planning and tax planning matters, our role shall be that of a
facilitator between such Client and his/her corresponding professional adviser(s); (iv) we are not an
attorney or accountant, and no portion of our services should be interpreted by such Client as legal or tax
advice (rather, such Client should defer to such Client’s attorney and/or accountant with respect to all legal
or tax matters); and (v) such Client will maintain sole responsibility to notify us if there is a change in such
Client’s financial situation or investment objective(s) for the purpose of reviewing/evaluating/revising our
previous recommendations and/or services and/or to address new planning or consulting matters. SAM
recommends the services of itself or other professionals to implement its recommendations. Clients are
advised that a conflict of interest exists if clients engage SAM or Jonathan Satovsky as a registered
representative to provide additional fee-based services (investment management, aggregate customized
reporting, insurance/annuity solutions or special projects). Clients are advised that it remains their
responsibility to notify the Firm of any change in their financial situation or investment objectives for the
purpose of reviewing, evaluating or revising SAM’s previous recommendations and/or services.
SAM does not sponsor nor provide portfolio management services to a wrap fee program.
C. Regulatory Assets Under Management
SAM provides investment management services on a discretionary and/or non‐discretionary basis to each
of our Client Accounts. As of December 31, 2023, we provided investment management services to
$792,106,127 of regulatory assets under management of which $776,546,594 is managed on a
discretionary basis and $15,559,533 is managed on a non‐discretionary basis.