A. Describe your advisory firm, including how long it has been in business. Identify your
principal owner(s).
&Wealth Partners is a registered investment advisor firm registered with the Securities and Exchange
Commission as of January 2, 2009.
The Principal Owner of &Wealth Partners is:
Dorie Fain, Managing Member/Chief Compliance Officer.
B. Describe the types of advisory services the firm offers. If the firm holds itself out as
specializing in a particular type of advisory service, explain the nature of that service in
detail. If the firm provides investment advice only with respect to limited types of
investments, explain the type of investment advice firm offers and disclose that the advice is
limited to those types of investments.
&Wealth Partners (the “Registrant”) is an investment adviser providing financial planning, consulting, and
investment management services to individuals, pension and profit sharing plans, trusts, estates, and
charitable organizations. The Registrant, depending upon the engagement, offers its services on a fee basis
which may include hourly and/or fixed fees as well as fees based upon assets under supervision. Prior to
engaging the Registrant to provide any of the foregoing investment advisory services, the client will be
required to enter into one or more written agreements with the Registrant setting forth the terms and
conditions under which the Registrant shall render its services (collectively the “Agreement”).
The Registrant may provide its clients with a broad range of comprehensive financial planning and
consulting services (which may include non-investment related matters). The Registrant will charge a fixed
fee and/or hourly fee for these services. The Registrant's financial planning and consulting fees generally
range from $10,000 to $100,000 on a fixed fee basis and/or from $300 to $1,000 on an hourly rate basis,
depending upon the level and scope of the professional services rendered for financial planning and/or the
consulting services. If the client engages the Registrant for additional investment advisory services, the
Registrant may offset all or a portion of its fees for those services based upon the amount paid for the
financial planning and/or consulting services.
Prior to engaging the Registrant to provide financial planning and/or consulting services, the client will
generally be required to enter into a written agreement with the Registrant setting forth the terms and
conditions of the engagement and describing the scope of the services to be provided. Clients are billed
monthly in arrears for services provided or, in the case of a fixed fee engagement, pursuant to an agreed-
upon written schedule. Either party may terminate the agreement by written notice to the other. In the event
the client terminates the Registrant's financial planning and/or consulting services prior to the Registrant
completing the plan or engagement, the Registrant will invoice the client for services performed up to the
date of termination.
In performing its services, the Registrant shall not be required to verify any information received from the
client or from the client's other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to
rely on such information. The Registrant may recommend the services of itself and/or other professionals
to implement its recommendations. Clients are advised that a conflict of interest exists if the Registrant
recommends its own services. The client is under no obligation to act upon any of the recommendations
made by the Registrant under a financial planning/consulting engagement and/or engage the services of any
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such recommended professional, including the Registrant itself. The client retains absolute discretion over
all such implementation decisions and is free to accept or reject any of the Registrant's recommendations.
Moreover, each client is advised that it remains his/her/its responsibility to promptly notify the Registrant
if there is ever any change in his/her/its financial situation or investment objectives for the purpose of
reviewing, evaluating, or revising the Registrant's previous recommendations and/or services.
In the event the client determines to engage the Registrant to provide investment supervisory services, the
Registrant shall do so on a fee basis. If engaged, the Registrant shall charge an annual fee based upon a
percentage of the market value of the assets being supervised by the Registrant. As discussed in response
to Item 12A (below), the Registrant's annual fee is exclusive of, and in addition to brokerage commissions,
transaction fees, and other related costs and expenses which shall be incurred by the client. However, the
Registrant shall not receive any portion of these commissions, fees, and costs. The Registrant's annual fee
shall be prorated and charged quarterly, in arrears, based upon the market value of the assets on the last day
of the previous quarter. The annual fee is 1.00%.
The Registrant does not impose an account minimum for starting or maintaining an account. However, as
further discussed in response to Item 7 (below), the Registrant generally imposes a minimum annual fee for
its investment management services. The Registrant, in its sole discretion, may negotiate to charge a lesser
management fee based upon certain criteria (i.e., anticipated future earning capacity, anticipated future
additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-
existing client, account retention, pro bono activities, etc.).
The Registrant offers advice on exchange listed-securities, corporate debt securities, commercial paper,
certificate of deposit, municipal securities, variable life insurance, variable annuities, mutual funds, United
States government securities, exchange traded funds (ETFs) and any type of investment held in a client’s
portfolio at the beginning of the advisory relationship. However, the Registrant intends to primarily allocate
its client's investment management assets on a discretionary basis among Independent Managers (as
defined below) and exchange traded funds in accordance with the investment objectives of the client.
As further discussed in response to Item 12A (below), the Registrant shall generally recommend that clients
utilize the brokerage and clearing services of Charles Schwab & Co., Inc. (“Schwab”) for investment
management accounts.
The Registrant may only implement its investment management recommendations after the client has
arranged for and furnished the Registrant with all information and authorization regarding accounts with
appropriate financial institutions. Financial institutions shall include, but are not limited to, Schwab, any
other broker-dealer recommended by the Registrant, broker-dealer directed by the client, trust companies,
banks etc. (collectively referred to herein as the “Financial Institution(s)”).
Clients may incur certain charges imposed by the Financial Institution(s) and other third parties such as
fees charged by Independent Managers (as defined below), custodial fees, charges imposed directly by a
mutual fund or exchange traded fund in the account, which shall be disclosed in the fund's prospectus (e.g.,
fund management fees and other fund expenses), deferred sales charges, oddlot differentials, transfer taxes,
wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities
transactions. Additionally, for assets outside of any wrap fee programs, clients may incur brokerage
commissions and transaction fees. Such charges, fees and commissions are exclusive of and in addition to
the Registrant's fee.
The Registrant's Agreement and/or the separate agreement with the Financial Institution(s) may authorize
the Registrant through the Financial Institution(s)
to debit the client's account for the amount of the
Registrant's fee and to directly remit that management fee to the Registrant in accordance with applicable
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custody rules. The Financial Institution(s) recommended by the Registrant have agreed to send a statement
to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of
management fees paid directly to the Registrant.
The Registrant may also recommend that certain clients authorize the active discretionary management of
a portion of their assets by and/or among certain independent investment manager(s) based upon the stated
investment objectives of the client. The terms and conditions under which the client shall engage the
Independent Manager(s) shall be set forth in separate written agreements between (1) the client and the
Registrant and (2) the client and the designated Independent Manager(s). The Registrant shall continue to
render advisory services to the client relative to the ongoing monitoring and review of account performance,
for which the Registrant shall receive an annual advisory fee which is based upon a percentage of the market
value of the assets being managed by the designated Independent Manager(s). Factors that the Registrant
shall consider in recommending Independent Manager(s) include the client's stated investment objective(s),
management style, performance, reputation, financial strength, reporting, pricing, and research.
The investment management fees charged by the designated Independent Manager(s), together with the
fees charged by the corresponding designated broker-dealer/custodian of the client's assets, will be
exclusive of, and in addition to, the Registrant's investment advisory fee set forth above. As discussed
above, the client may incur additional fees than those charged by the Registrant, the designated Independent
Manager(s), and corresponding broker-dealer and custodian.
In addition to the Registrant's written disclosure statement, the client shall also receive the written disclosure
statement of the designated Independent Manager(s). Certain Independent Manager(s) may impose more
restrictive account requirements and varying billing practices than the Registrant. In such instances, the
Registrant may alter its corresponding account requirements and/or billing practices to accommodate those
of the Independent Manager(s).
If the Registrant refers a client to certain Independent Manager(s) the Independent Manager(s) shall charge
the client separately for their management fee as stated above. The Registrant shall also be compensated
for its services by charging the client a percentage of assets under management fee also discussed above.
The Registrant also may render non-discretionary investment management services to clients relative to:
(1) variable life/annuity products that they may own, and/or (2) their individual employer sponsored
retirement plans. In so doing, the Registrant either directs or recommends the allocation of client assets
among the various mutual fund subdivisions that comprise the variable life/annuity product or the
retirement plan. The client assets shall be maintained at either the specific insurance company that issued
the variable life/annuity product which is owned by the client, or at the custodian designated by the sponsor
of the client's retirement plan.
When Registrant provides investment advice to you regarding your retirement plan account or individual
retirement account, Registrant are fiduciaries within the meaning of Title I of the Employee Retirement
Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. The way Registrant makes money creates some conflicts with your interests, so we operate under
a special rule that requires us to act in your best interest and not put our interest ahead of yours.
As a fiduciary, Registrant must provide advice in the “Best Interest” of the Retirement Investor; charge
“reasonable” compensation for the services provided to you; and, not make misleading statements about
investment transactions, compensation, and conflicts of interest.
The client may make additions to and withdrawals from the account at any time, subject to the Registrant's
right to terminate an account. Clients may withdraw account assets on notice to the Registrant, subject to
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the usual and customary securities settlement procedures. However, the Registrant designs its portfolios as
long-term investments and asset withdrawals may impair the achievement of a client's investment
objectives.
For the initial quarter of investment management services, the first quarter's fees shall be calculated on a
pro rata basis. The Agreement between the Registrant and the client will continue in effect until terminated
by either party pursuant to the terms of the Agreement. The Registrant's annual fee shall be prorated through
the date of termination and any remaining balance shall be charged or refunded to the client, as appropriate,
in a timely manner.
Additions may be in cash or securities provided that the Registrant reserves the right to liquidate any
transferred securities, or decline to accept particular securities into a client's account. The Registrant may
consult with its clients about the options and ramifications of transferring securities. However, clients are
advised that when transferred securities are liquidated, they are subject to transaction fees, fees assessed at
the mutual fund level (i.e. contingent deferred sales charge) and/or tax ramifications.
The Registrant's clients are advised to promptly notify the Registrant if there are ever any changes in their
financial situation or investment objectives or if they wish to impose any reasonable restrictions upon the
Registrant's management services.
Neither the Registrant nor the client may assign the Agreement without the consent of the other party.
Transactions that do not result in a change of actual control or management of the Registrant shall not be
considered an assignment.
A copy of the Registrant's privacy policy notice and a written disclosure statement that meets the
requirements of Rule 204-3 of the Investment Advisers Act of 1940, as amended (“Advisers Act”), shall be
provided to each client prior to or contemporaneously with the execution of the Agreement.
C. Explain whether (and, if so, how) the firm tailors advisory services to the individual needs
of clients. Explain whether clients may impose restrictions on investing in certain securities
or types of securities.
The Registrant will tailor its advisory services to its client’s individual needs based on meetings and
completion of a client profile. If clients wish to impose certain restrictions on investing in certain securities
or types of securities, the Advisor will address those restrictions with the client to have a clear understanding
of the client’s requirements.
D. If the firm participates in wrap fee programs by providing portfolio management
services, (1) describe the differences, if any, between how the firm manages wrap fee accounts
and how it manages other accounts, and (2) explain that the firm receives a portion of the
wrap fee for its services.
The Registrant does not provide portfolio management services to wrap fee programs.
E. If the firm manages client assets, disclose the amount of client assets it manages on a
discretionary basis and the amount of client assets on a non-discretionary basis. Disclose the
date “as of” which it calculated the amounts.
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The Registrant manages client assets and as of December 31, 2022 has the following assets under
supervision:
Discretionary assets: $ 172,170,654
Non-discretionary assets: $ 148,699,705