NewSquare became registered with the Securities
and Exchange Commission on January 13, 2010
and commenced business as an investment
adviser on that date.
NewSquare’s Principal Owners are as follows:
Joseph Vincent Naselli
The Eleanor Mae Daniels Trust
Gary Earl Daniels Trustee
Jesse Hart Daniels Trustee
Claire Daniels Trustee
The managers of NewSquare are as follows:
Joseph S. Rizzello, Chief Executive Officer
Mr. Rizzello brings substantial industry
experience and expertise to the NewSquare
Capital organization. He’s been instrumental in
NewSquare’s growth. Joseph is recognized as an
industry innovator and was prominent in the lead-
up to the creation of exchange-traded funds
(ETFs), a security type that continues to
experience substantial growth.
As NewSquare Capital’s Chairman, Mr. Rizzello
caps a distinguished 40+ year career in financial
services, including senior positions with top-tier
organizations that include: CEO, Board Chairman
of the National Stock Exchange, Jersey City: co-
founder of The Mind Capital Group, Philadelphia;
President of Pershing Trading Company, Jersey
City; a principal in charge of Vanguard Brokerage
Services, Malvern Pa; and Executive Vice President
of the Philadelphia Stock Exchange.
Christy L Hart, Director of Operations
In her former role as a Client Experience
Consultant at Creative Financial, Christy worked
with high-net-worth clients and businesses,
tailoring each service plan to build and sustain
strong client relationships. She was integral in
many areas, including identifying and addressing
client needs, connecting clients to thought
leadership and events, and implementing firm-
wide project management.
Christy is a graduate of West Chester University
where she earned Bachelors of Science Degree in
Elementary Education.
Ryan Kirk, CFA, President and Head of Portfolio
Management
Ryan is in charge of the day-to-day trade
management of all NewSquare Portfolios. He
works closely with all team members supporting
the daily management of all accounts. Other
responsibilities include monitoring asset
allocation, monitoring cash balances, account
rebalancing and trade execution, account
reporting, and research. Ryan has over 15 years
of experience in the financial industry. Prior to
joining NewSquare Capital, he gained his initial
experience at Aberdeen Asset Management. He
holds a BS in Business Management from the
University of Scranton. He has earned the
Chartered Financial Analyst (CFA) designation and
is a member of the CFA Society of Philadelphia.
Lee S. Grout, CFA, Senior Portfolio Manager
With 30+ years in the investment industry, Lee
joined NewSquare at the end of 2019. As the
portfolio manager for several of NewSquare’s
portfolios, Lee oversees both investment research
and portfolio management for solutions that are
designed to meet a wide range of investor needs.
Lee was most recently Portfolio Manager at
Chartwell Investment Partners, Berwyn,
Pennsylvania. Prior to that, he spent 14 years as
Portfolio Manager and Head of Investment
Research at the Killen Group, Inc., also in Berwyn.
He served as Secretary of the Board of Directors
and held an ownership interest in the firm. Lee’s
investment research career dates from 1994,
when he joined McCabe Capital Managers, King of
Prussia, Pennsylvania, as a research analyst. He
started his investment industry career in 1993 as
a Mutual Fund Accountant with SEI Corporation in
Oaks, Pennsylvania.
Lee is a Chartered Financial Analyst and a member
of the CFA Institute and CFA Society of
Philadelphia. He earned a Bachelor of Business
Administration degree in Finance from Bishop’s
University, Lennoxville, Quebec.
Miguel L. Biamon, Senior Fixed Income Portfolio
Manager
Miguel started with NewSquare in July 2018 and
brings with him over 25+ years of industry
experience. He manages our fixed income
portfolios as well as bond trading. Miguel
previously worked at M&T Bank, Bryn Mawr Trust
and Blue Bell Private Wealth Management.
Matthew Wilson, Chief Compliance Officer
Matt Wilson has been the NewSquare CCO since
April 1, 2016. He succeeded William R. Meck who
had previously served as CCO. Matt served as
assistant CCO since the founding of NewSquare in
2010. He attended Pennsylvania State University
and received a Bachelor of Science Degree
(Finance) in 2000. Matt is responsible for the top-
down design of all RIA-related compliance
procedures and their implementation.
*Please Note: Limitations. The achievement of
any professional designation, certification, degree,
or license, membership in any professional
organization, or any amount of prior experience
or success, should not be construed by a client or
prospective client as a guarantee that he/she will
experience a certain level of results or satisfaction
if NewSquare is engaged, or continues to be
engaged, to provide investment advisory services.
NewSquare’s advisory services are provided as
part of a wrap fee program (the “Program”) and
are mainly focused around designing and
implementing diversified portfolios of primarily
exchange traded funds, individual equity
securities and selected fixed income securities.
These services are designed to be consistent with
to each client’s designated goals and objectives.
The Portfolios are strategic asset allocation
portfolios with global diversification.
Considerations include risk tolerance, time
horizon, income needs, liquidity needs, tax
sensitivity, and other factors.
NewSquare will offer clients the ability to engage
NewSquare on a discretionary basis in portfolios
of primarily exchange traded funds, individual
equity securities and fixed income securities. In
conjunction with the client’s MMLIS
representative (see below), each client will
receive individual service based on their needs
and risk tolerances. Clients may impose
restrictions on investing in certain securities or
types of securities. NewSquare will manage
client’s assets consistent with one or more of its
asset allocation strategies.
Under the Program, assets are held in a brokerage
account at Schwab Advisor Services (“Schwab”),
or Fidelity Brokerage Services, LLC (“Fidelity”).
This account shall be known as the Program
Account. Beginning in 2017, NewSquare
underwent a transition of custodians. Accounts
were transitioned from MML Investor Services
(“MMLIS”) to Schwab. All new accounts will be
opened at Schwab or Fidelity. Any account that
remained at MMLIS after March 31, 2018 was
transitioned to a standard brokerage account that
is no longer managed by NewSquare Capital.
As part of the Program, NewSquare has entered
into a co-advisory agreement with MMLIS
pursuant to which the two companies act as co-
advisors to clients who open investment advisory
accounts at NewSquare. Per the terms of the Co-
Investment Advisory Agreement, MMLIS is
generally responsible for the initial and ongoing
day-to-day relationship with the client, including
the initial and ongoing determination of client
suitability for NewSquare’s asset allocation
strategies. In such co-advisory engagements,
NewSquare is responsible for managing the
client’s assets consistent with one or more of its
asset allocation strategy(ies), as communicated to
by MMLIS. This Brochure describes NewSquare’s
duties and responsibilities. For a description of
MMLIS’ duties and responsibilities, please see
MMLIS’ Form ADV 2A Brochure.
The client relationship is typically managed by
Investment Adviser Representatives (“IARs”) of
MMLIS. IARs (with the assistance of NewSquare
management or employees if requested),
generally meet with clients, discuss the clients’
goals and objectives and assist the clients in the
development, management and implementation of
the clients’ wealth management program. IARs do
not, however, manage NewSquare portfolios for
clients. Rather, NewSquare portfolios are
managed by Portfolio Managers of NewSquare.
In limited instances, NewSquare could determine
to permit the client to retain NewSquare directly
(separate from MMLIS Co-Advisory Agreement) to
manage client’s assets, on a discretionary basis
consistent the client’s goals, objectives, and risk
tolerance. In such relationships, the client would
execute a Discretionary Investment Management
Agreement with NewSquare and a Brokerage
Account Agreement with Schwab or Fidelity
(Program Account). In such limited
circumstances, client portfolios will be managed
by NewSquare, on a discretionary basis.
NewSquare is both the sponsor and the portfolio
manager of the Program and the Program is
structured as a wrap account. A wrap account is a
type of individually managed account in which
most expenses that are typical of a managed
account are combined into one (a wrap) fee. This
includes the management fee, the brokerage
commissions, custodial fee and other expenses.
The wrap fee does not cover certain fees such as
markup/markdowns, transfer of asset fees,
reorganization fees, wire or check fees.
ERISA PLANS: NewSquare may be directly
engaged by Plan sponsors to provide non-
discretionary and discretionary advisory services
to ERISA retirement plans. In such event,
NewSquare would serve as an investment
fiduciary as that term is defined under The
Employee Retirement Income Security Act of 1974
(“ERISA”)-either a 3(21) fiduciary for non-
discretionary engagements or a 3(38) fiduciary
for discretionary engagements. In either
engagement, NewSquare will generally provide
services on an “assets under management” fee
basis per the terms and conditions of an
Investment Advisory Agreement or a Retirement
Plan Services Agreement between the Plan and
NewSquare.
CONFLICTS OF INTEREST AND
MISCELLANEOUS DISCLOSURES:
NewSquare may perform advisory services for
various clients and may give advice or take actions
for another client that differs from the advice
given or the timing or the nature of any action
taken for the Account.
Incentive Units and Other Benefits: Conflicts of
Interest: Regardless of whether a client
engages NewSquare directly, or, in its co-
advisory capacity with MMLIS, the client’s
MMLIS IAR is compensated with a portion of
the Program fee. In addition to a portion of the
Program fee, the IAR can also receive Sale of
Company incentive units from NewSquare (the
“Units”). The Units provide the IAR with non-
voting, company liquidation participation
units, upon the sale of NewSquare or the IAR’s
death, disability, or retirement. The receipt of
the Units provide the IAR with an economic
incentive to allocate client assets to the
Program. Because of this economic incentive,
the IAR has a conflict of interest when
allocating assets to the Program. In addition,
MMLIS IARs who allocate more than
$25million of assets to the Program qualify to
receive bonus compensation from NewSquare.
The amount of bonus compensation increases
with the amount of assets allocated to the
Program. The bonus can be as high as a thirty
percent (30%) discount of the NewSquare
portion of the Program Fee. The IAR shall
retain such bonus rather than utilize same to
reduce the client’s Program fee. The potential
for receipt of bonus compensation presents an
added conflict of interest by providing the IAR
with an incentive to allocate more assets to the
Program. Separate from the Units, NewSquare
can, from time to time, provide additional
benefits to the IARs, the providing of which by
NewSquare, and receipt of which by the IARs,
also presents a conflict of interest. The
benefits can include occasional business
entertainment including meals, invitations to
sporting events, including golf tournaments
and other forms of entertainment, some of
which can accompany educational
opportunities or guest speaker events. Please
Note: No prospective client is required to
allocate assets to the Program. ANY
QUESTIONS: NewSquare’s Chief Compliance
Officer, Matthew Wilson, remains available to
address any questions regarding the above
conflict of interest. PLEASE also see disclosure
set forth on MMLIS’s written disclosure
Brochure (Part 2A of Form ADV) regarding
incentives provided to its IARs.
Wrap Program-Conflict of Interest. NewSquare
provides services on a wrap fee basis as a wrap
program sponsor. Under NewSquare’s wrap
program, the client generally receives investment
advisory services, the execution of securities
brokerage transactions, custody and reporting
services for a single specified fee. When managing
a client’s account on a wrap fee basis, NewSquare
shall receive as payment for its investment
advisory services, the balance of the wrap fee after
all other costs incorporated into the wrap fee have
been deducted. Participation in a wrap program
may cost the client more or less than purchasing
such services separately. The terms and
conditions of a wrap program engagement are
more fully discussed in NewSquare’s Wrap Fee
Program Brochure.
Conflict of Interest: Because wrap program
transaction fees and/or commissions are being
paid by NewSquare to the account
custodian/broker-dealer, NewSquare could have
an economic incentive to minimize the number of
trades in the client's account. See separate Wrap
Fee Program Brochure. Please Note: This conflict
of interest does not apply to accounts managed
under an Asset-Based Pricing Arrangement, as
further detailed below. At this time, NewSquare
has all accounts setup as Transaction-Based
Pricing due to zero cost commission / transaction
fees with the custodians. Although the
recommended custodians do not currently charge
commission/transaction fees for the types of
securities purchased by NewSquare for client
accounts, NewSquare does incur other types of
transaction-related fees payable to the account
custodian that are absorbed by NewSquare as part
of the wrap program fee.
Retirement Rollovers-Potential for Conflict of
Interest: 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 NewSquare
recommends that a client roll over their
retirement plan assets into an account to be
managed by NewSquare, such a recommendation
creates a conflict of interest if NewSquare will
earn an advisory fee on the rolled over assets. No
client is under any obligation to roll over
retirement plan assets to an account managed by
NewSquare. Please Note: NewSquare does not
generally recommend rollovers. However, its co-
adviser (MMLIS see below) could make a rollover
recommendation (the suitability of which for the
client shall be determined by MMLIS), as the result
of which NewSquare could be engaged to manage
the rollover assets. In the unlikely event that
NewSquare makes a rollover recommendation,
NewSquare is acting as a fiduciary 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.
No Financial Planning or Non-Investment
Consulting/Implementation Services.
NewSquare does not provide financial planning
or related consulting services matters such as
estate planning, tax planning, insurance, etc.
NewSquare does not serve as an attorney,
accountant, or insurance agency, and no portion of
our services should be construed as same.
Accordingly, we do not prepare estate planning
documents, tax returns or sell insurance products.
Sub-Advisor / Separate Account Manager
Services: NewSquare may be engaged to serve as
a: (1) sub-adviser to unaffiliated registered
investment advisers; and/or (2) as a separate
account manager on a custodian’s investment
platform. With respect to these two types of
engagements, the unaffiliated investment advisers
that engage NewSquare’s sub-advisory services
and/or assist their clients in selecting NewSquare
as a separate account manager, maintain both the
initial and ongoing day-to-day relationship with
the underlying client, including the initial and
ongoing determination of client suitability for
NewSquare’s investment strategies. NewSquare’s
obligation shall be to manage the client’s account
consistent with the investment strategy
designated by the unaffiliated investment adviser.
In addition, for all such engagements, NewSquare
does not generally have the ability to choose
and/or determine: (1) the custodian and/or
broker-dealer for the client’s account; (2) whether
the services are part of a wrap program or
provided on an unbundled basis; or (3) program
and/or transaction cost pricing. As a result, clients
may pay higher commissions or other transaction
costs or greater spreads, or receive less favorable
net prices, on transactions for the account than
would otherwise be the case through alternative
clearing arrangements recommended by
NewSquare. Higher fees and transaction costs
adversely impact account performance.
Unaffiliated Wrap/Separate Managed Account
programs services: NewSquare may be engaged
to provide investment advisory services as part of
an unaffiliated wrap-fee program/managed
account platform, In these type of engagements,
the unaffiliated investment advisers that engage
NewSquare's services shall maintain both the
initial and ongoing day-to-day relationship with
the underlying investor, including initial and
ongoing determination of the of the investor’s
suitability for NewSquare's designated investment
strategies. In addition, since the
custodian/broker-dealer is determined by the
unaffiliated program/platform sponsor,
NewSquare will be unable to negotiate
commissions and/or transaction costs, and/or
seek better execution. As a result, the investor
could pay higher commissions or other
transaction costs. Higher transaction costs
adversely impact account performance.
PCS Affiliation/Conflict of Interest: NewSquare
representative, Timothy Chisolm, is also an
employee and owner of PCS, a retirement plan
platform provider. Mr. Chisolm, and other
NewSquare representatives based upon the
quality of the PCS platform, recommend PCS to
retirement plan clients for their consideration. No
client is under any obligation to engage PCS. In the
event that a NewSquare client engages PCS, no
portion of PCS’ fees are shared by PCS with
NewSquare. However, given Mr. Chisolm’s
affiliation with PCS, he has an economic incentive
to recommend PCS’ services. This incentive
presents a conflict of interest, since both PCS and
Mr. Chisolm will benefit from such an
engagement. ANY QUESTIONS: NewSquare’s
Chief Compliance Officer, Matthew Wilson,
remains available to address any questions
regarding the above conflict of interest.
Portfolio Activity. NewSquare has a fiduciary
duty to provide services consistent with the
client’s best interest. As part of its investment
advisory services, NewSquare will review client
portfolios on an ongoing basis to determine if any
changes are necessary based upon various factors,
including, but not limited to, investment
performance, market conditions, style drift,
and/or a change in the client’s investment
objective. Based upon these factors, there may be
extended periods of time when NewSquare
determines that changes to a client’s portfolio are
neither necessary, nor prudent. Of course, as
indicated below, there can be no assurance that
investment decisions made by NewSquare will be
profitable or equal any specific performance
level(s).
Please Note: Cash Positions. NewSquare
continues to treat cash as an asset class. As such,
unless determined to the contrary by NewSquare,
all cash positions (money markets, etc.) shall
continue to be included as part of assets under
management for purposes of calculating
NewSquare’s advisory fee. 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), NewSquare may
maintain cash positions for defensive purposes. In
addition, while assets are maintained in cash, such
amounts could miss market advances. Depending
upon current yields, at any point in time,
NewSquare’s advisory fee could exceed the
interest paid by the client’s money market fund.
ANY QUESTIONS: NewSquare’s Chief
Compliance Officer, Matthew Wilson, remains
available to address any questions that a client
or prospective may have regarding the above
fee billing practice.
Donor-Advised Funds. NewSquare may provide
advisory services to donor-advised funds through
an arrangement with Schwab Charitable™, an
unaffiliated non-profit organization. Donor-
advised funds allow clients to contribute assets to
a charitable account which may provide tax
benefits to the client and allow for the client to
support their preferred charity(ies). The client
will be responsible for certain administrative fees
charged by Schwab Charitable™ and will be
informed of any advisory fees charged against the
donor-advised fund prior to NewSquare assuming
management of the account. NewSquare does not
provide tax, legal, or accounting advice. Clients are
advised to speak with the professional(s) of their
choosing prior to directing NewSquare to
contribute assets to a donor-advised fund. More
information on Schwab Charitable™ can be found
at www.schwabcharitable.org.
Transaction-Fee Pricing Arrangements and
Limitations. NewSquare charges an all-inclusive
wrap fee to clients. NewSquare can set an account
either as “Asset-Based” or “Transaction-Based”
pricing with the broker-dealer/custodian, and the
cost of either is paid for by NewSquare and is part
of the all-inclusive wrap fee charged to the client.
Under an “Asset-Based” pricing arrangement, the
broker-dealer/custodian will charge a fixed fee to
NewSquare for all account
commissions/transactions. In the alternative, the
broker-dealer/custodian could charge a separate
commission/transaction for the execution of each
account transaction. This is referred to as a
“Transaction-Based” pricing arrangement.
Transaction fees paid will vary depending upon
the number of and type of transactions that are
placed for the account. For Program Accounts,
regardless of whether there is an Asset-Based or
Transaction-Based pricing, arrangement,
transaction fees and/or commissions are being
absorbed and paid by NewSquare to the account
custodian/broker-dealer. In a Transaction Based
arrangement, NewSquare could have an economic
incentive to minimize the number of trades in the
client's account, thereby creating a conflict of
interest-see below. Currently, as the result of the
continued determination by account custodians
utilized by NewSqaure to not charge on trading
fees on individual equity transactions, including
ETFs (NewSquare’s primary trading vehicle), New
Squared has opted for Transaction-Based pricing.
Account investment decisions are driven by
security selection and anticipated market
conditions, as opposed to the amount of
commission/transaction fees payable to the
account broker-dealer/custodian.
NewSquare charges an all-inclusive wrap fee and
may request at any time to switch between Asset-
Based pricing and Transaction-Based pricing
arrangements with the broker-dealer/custodian,
however, there can be no assurance that the
volume of transactions will be consistent from
year-to-year given changes in market events and
security selection. Therefore, given the variances
in trading volume and pricing arrangements, any
decision by NewSquare to switch between Asset-
Based or Transaction-Based pricing could prove to
be economically disadvantageous, but that cost is
the responsibility of NewSquare.
Assets under Management are calculated as of
December 31, 2023.
Discretionary Assets: $1,559,189,717
Non-Discretionary Assets: None
Total Assets: $1,559,189,717