A. Prestige Wealth Management Group, LLC (the “Registrant”) is a limited liability
company that was formed in October 1994 in the state of New Jersey. The Registrant
became registered as an Investment Adviser Firm in March 1995. Roy Williams is the
sole owner and the Registrant’s Managing Member.
B.
INVESTMENT ADVISORY SERVICES
The Registrant provides discretionary investment advisory services on a wrap or non-
wrap fee basis. (See discussion below). If a client determines to engage the Registrant on
a wrap fee basis the client will pay a single fee for bundled services (i.e., investment
advisory, brokerage, custody). The services included in a wrap fee agreement will depend
upon each client’s particular need. If the client determines to engage the Registrant on a
non-wrap fee basis the client will select individual services on an unbundled basis, paying
for each service separately (i.e., investment advisory, brokerage, custody).
Registrant's annual investment advisory fee shall include investment advisory services,
and, to the extent specifically requested by the client, financial planning and consulting
services. In the event that the client requires extraordinary planning and/or consultation
services (to be determined in the sole discretion of the Registrant), the Registrant may
determine to charge for such additional services, the dollar amount of which shall be set
forth in a separate written notice to the client.
NON-WRAP FEE BASIS
The Registrant provides discretionary investment advisory services on a non-wrap fee
basis. The Registrant’s annual investment advisory fee shall be based upon a percentage
(%) of the market value and type of assets placed under the Registrant’s management,
generally between 0.45% and 1.95%.
PRESTIGE WEALTH WRAP FEE PROGRAM
The Registrant provides investment management services on a wrap fee basis through its
investment management wrap fee program (the “Program”). The services offered under,
and the corresponding terms and conditions pertaining to, the Program are discussed in
the Wrap Fee Program Brochure, a copy of which is presented to all prospective Program
participants. Under the Program, the Registrant is able to offer participants discretionary
investment management services, for a single specified annual Program fee, inclusive of
trade execution, custody, reporting, and the Registrant’s investment management fees.
However, clients may incur additional fees as set forth below.
The current annual Program fee ranges from 0.50% to 1.95%, depending upon the
amount and type of the Program assets. The terms and conditions for client participation
in the Program are set forth in detail in the Wrap Fee Program Brochure, which is
presented to all prospective Program participants in accordance with the disclosure
requirements of Part 2A Appendix 1 of Form ADV.
All prospective Program participants should read both the Registrant’s Brochure and the
Wrap Fee Program Brochure, and ask any corresponding questions that they may have,
prior to participation in the Program.
Wrap Program. Under Registrant’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, the Registrant 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 Registrant’s Wrap Fee Program Brochure.
Conflict of Interest: Because wrap program transaction fees and/or commissions are
being paid by Registrant to the account custodian/broker-dealer, Registrant has an
economic incentive to maximize its compensation by seeking to minimize the number of
trades in the client's account. See separate Wrap Fee Program Brochure.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
The Registrant may be engaged to provide financial planning and/or consulting services
(including investment and non-investment related matters, including estate planning,
insurance planning, etc.) on a stand-alone separate fee basis.
Prior to engaging the Registrant to provide planning or consulting services, clients are
generally required to enter into a Financial Planning and Consulting Agreement with
Registrant setting forth the terms and conditions of the engagement (including
termination), describing the scope of the services to be provided, and the portion of the
fee that is due from the client prior to Registrant commencing services.
If requested by the client, Registrant may recommend the services of other professionals
for implementation purposes, including the Registrant’s representatives in their individual
capacities as registered representatives of Triad Advisors and/or licensed insurance
agents. The Registrant may also recommend the services of Prestige Accounting Services
Group (“PASG”), an affiliated accounting firm. (See disclosure at Item 10.C). The client
is under no obligation to engage the services of any such recommended professional. The
client retains absolute discretion over all such implementation decisions and is free to
accept or reject any recommendation from the Registrant.
If the client engages any recommended unaffiliated professional, and a dispute arises
thereafter relative to such engagement, the client agrees to seek recourse exclusively from
and against the engaged professional. At all times, the engaged licensed professional (i.e.,
attorney, accountant, insurance agent, etc.), and not the Registrant, shall be responsible
for the quality and competency of the services provided.
Each client is advised that it remains the client’s responsibility to promptly notify the
Registrant if there is ever any change in client’s financial situation or investment
objectives for the purpose of reviewing, evaluating or revising Registrant’s previous
recommendations and/or services.
MISCELLANEOUS
Limitations of Financial Planning and Non-Investment Consulting/Implementation
Services. As indicated above, to the extent requested by a client, Registrant may provide
financial planning and related consulting services. Neither the Registrant nor its
investment adviser representatives assist clients with the implementation of any financial
plan, unless they have agreed to do so in writing. The Registrant does not monitor a
client’s financial plan, and it is the client’s responsibility to revisit the financial plan with
the Registrant, if desired.
The Registrant may provide financial planning and related consulting services regarding
non-investment related matters, such as estate planning, tax planning, insurance, etc.
Registrant does not serve as a law firm or accounting firm, and no portion of its services
should be construed as legal or accounting services. Accordingly, Registrant does not
prepare estate planning documents or tax returns.
To the extent requested by a client, Registrant may recommend the services of other
professionals for certain non-investment implementation purposes (i.e., attorneys,
accountants, insurance agents, etc.), including representatives of Registrant in their
separate individual capacities as representatives Triad Advisors, a FINRA member
broker-dealer (“Triad”) and/or as licensed insurance agents. The Registrant may also
recommend the services of Prestige Accounting Services Group (“PASG”), an affiliated
accounting firm. The client is under no obligation to engage the services of any such
recommended professional. The client retains absolute discretion over all such decisions
and is free to accept or reject any recommendation from Registrant and/or its
representatives.
If the client engages any recommended unaffiliated professional, and a dispute arises
thereafter relative to such engagement, the client agrees to seek recourse exclusively from
and against the engaged professional. At all times, the engaged licensed professional(s)
(i.e., attorney, accountant, insurance agent, etc.), and not the Registrant, shall be
responsible for the quality and competency of the services provided.
Affiliated Investment Advisor and Unified Managed Accounts. The Registrant is
affiliated with Prestige Wealth Services Group, Inc., d/b/a The Pillar Strategies, an SEC
registered investment advisory firm (SEC No. 801-77623) (“Pillar Strategies”). Pillar
Strategies sponsors Unified Management Accounts (“UMAs”).
The Registrant may allocate on a discretionary basis or recommend on a non-
discretionary basis that a client allocate a portion of their investment assets in one or
more of the UMAs sponsored by Pillar Strategies. As the sponsor for the various UMAs,
Pillar Strategies is responsible for portfolio trading, re-balancing, reporting and other
administrative responsibilities. The Registrant shall continue to render investment
advisory services to the client relative to the ongoing monitoring and review of account
performance, asset allocation and client investment objectives.
Factors which the Registrant shall consider in recommending the UMAs include the
client’s designated investment objective(s), performance, financial strength, reporting,
pricing, and research. Clients with assets in Pillar Strategies’ UMAs shall incur
additional management fees associated with the UMAs, which are set forth on the Pillar
Strategies’ ADV Part 2A. No client is under any obligation to engage the services of
Pillar Strategies or to allocate a portion of their investment management accounts in the
UMAs sponsored by Pillar Strategies. A client who doesn’t wish to incur additional fees
should direct the Registrant, in writing, not to invest in the UMAs.
Cash Positions. Registrant treats cash as an asset class. As such, all cash positions
(money markets, etc.) shall be included as part of assets under management for purposes
of calculating the Registrant’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), the Registrant 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, Registrant’s advisory fee could exceed the interest paid by the client’s money
market fund.
Cash Sweep Accounts. Certain account custodians can require that cash proceeds from
account transactions or new deposits, be swept to and/or initially maintained in a
specific custodian designated sweep account. The yield on the sweep account will
generally be lower than those available for other money market accounts. When this
occurs, to help mitigate the corresponding yield dispersion Registrant shall (usually
within 30 days thereafter) generally (with exceptions) purchase a higher yielding money
market fund (or other type security) available on the custodian’s platform, unless
Registrant reasonably anticipates that it will utilize the cash proceeds during the
subsequent 30-day period to purchase additional investments for the client’s account.
Exceptions and/or modifications can and will occur with respect to all or a portion of the
cash balances for various reasons, including, but not limited to the amount of dispersion
between the sweep account and a money market fund, the size of the cash balance, an
indication from the client of an imminent need for such cash, or the client has a
demonstrated history of writing checks from the account.
The above does not apply to the cash component maintained within a Registrant actively
managed investment strategy (the cash balances for which shall generally remain in the
custodian designated cash sweep account), an indication from the client of a need for
access to such cash, assets allocated to an unaffiliated investment manager and cash
balances maintained for fee billing purposes.
The client shall remain exclusively responsible for yield dispersion/cash balance
decisions and corresponding transactions
for cash balances maintained in any Registrant
unmanaged accounts.
Use of Mutual and Exchange Traded Funds. Most mutual funds and exchange traded
funds are available directly to the public. Therefore, a prospective client can obtain many
of the funds that may be utilized by Registrant independent of engaging Registrant as an
investment advisor. However, if a prospective client determines to do so, he/she will not
receive the Registrant’s initial and ongoing investment advisory services.
In addition to Registrant’s investment advisory fee described below, and transaction
and/or custodial fees discussed below, clients will also incur, relative to all mutual fund
and exchange traded fund purchases, charges imposed at the fund level (e.g.,
management fees and other fund expenses).
Portfolio Activity. Registrant has a fiduciary duty to provide services consistent with the
client’s best interest. As part of its investment advisory services, Registrant 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, fund
manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s
investment objective. Based upon these factors, there may be extended periods of time
when Registrant determines that changes to a client’s portfolio are neither necessary nor
prudent. Clients nonetheless remain subject to the fees described in Item 5 below during
periods of account inactivity.
Retirement Plan Rollovers – No Obligation / 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 Registrant recommends that
a client roll over their retirement plan assets into an account to be managed by Registrant,
such a recommendation creates a conflict of interest if Registrant will earn new (or
increase its current) compensation as a result of the rollover. If Registrant provides a
recommendation as to whether a client should engage in a rollover or not, Registrant 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 client is under any obligation to roll over retirement plan assets
to an account managed by Registrant.
eMoney Account Aggregation. In conjunction with the services provided by eMoney
Advisor Platform (“eMoney”), the Registrant may also provide periodic comprehensive
reporting services, which can incorporate all of the client’s investment assets including
those investment assets that are not part of the assets managed by the Registrant (the
“Excluded Assets”). The Registrant’s service relative to the Excluded Assets is limited to
reporting services only, which does not include investment implementation. Because the
Registrant does not have trading authority for the Excluded Assets, to the extent
applicable to the nature of the Excluded Assets (assets over which the client maintains
trading authority vs. trading authority designated to another investment professional), the
client (and/or the other investment professional), and not the Registrant, shall be
exclusively responsible for directly implementing any recommendations relative to the
Excluded Assets. Rather, the client and/or their other advisors that maintain trading
authority, and not the Registrant, shall be exclusively responsible for the investment
performance of the Excluded Assets. Without limiting the above, the Registrant shall not
be responsible for any implementation error (timing, trading, etc.) relative to the
Excluded Assets. In the event the client desires that the Registrant provide investment
management services (whereby the Registrant would have trading authority) with respect
to the Excluded Assets, the client may engage the Registrant to do so pursuant to the
terms and conditions of the Investment Advisory Agreement between the Registrant and
the client.
In addition, the eMoney platform also provides access to other types of information,
including financial planning concepts, which should not, in any manner whatsoever, be
construed as services, advice, or recommendations provided by Registrant.
Separately Managed Account Programs. Registrant may allocate a portion of a
client’s investment assets among unaffiliated Separately Managed Account programs in
accordance with the client’s designated investment objective(s). In such situations, the
Separately Managed Account Manager shall have day-to-day responsibility for the active
discretionary management of the allocated assets. The Registrant shall continue to render
investment advisory services to the client relative to the ongoing monitoring and review
of account performance, asset allocation and client investment objectives. Factors which
the Registrant shall consider in recommending Separately Managed Account programs
include the client’s designated investment objective(s) as applied to the Separately
Managed Account program: management style, performance, reputation, financial
strength, reporting, pricing, and research. The investment management fee charged by the
separate account manager is separate from, and in addition to, the Registrant’s investment
advisory fee for clients who have engaged the Registrant on a non-wrap basis.
Independent Managers. The Registrant may allocate a portion of the client’s investment
assets among unaffiliated independent investment managers in accordance with the
client’s designated investment objective(s). In such situations, the Independent
Manager(s) shall have day-to-day responsibility for the active discretionary management
of the allocated assets, including, to the extent applicable, proxy voting responsibility.
Registrant shall continue to render investment supervisory services to the client relative
to the ongoing monitoring and review of account performance, asset allocation and client
investment objectives. Factors that Registrant shall consider in recommending
Independent Manager(s) include the client’s designated investment objective(s),
management style, performance, reputation, financial strength, reporting, pricing, and
research. The investment management fee charged by the Independent Manager(s) is
separate from, and in addition to, Registrant’s investment advisory fee disclosed at Item 5
below.
Socially Responsible (ESG) Investing Limitations. Socially Responsible Investing
involves the incorporation of Environmental, Social and Governance (“ESG”)
considerations into the investment due diligence process. ESG investing incorporates a
set of criteria/factors used in evaluating potential investments: Environmental (i.e.,
considers how a company safeguards the environment); Social (i.e., the manner in which
a company manages relationships with its employees, customers, and the communities
in which it operates); and Governance (i.e., company management considerations). The
number of companies that meet an acceptable ESG mandate can be limited when
compared to those that do not and could underperform broad market indices. Investors
must accept these limitations, including potential for underperformance.
Correspondingly, the number of ESG mutual funds and exchange-traded funds are
limited when compared to those that do not maintain such a mandate. As with any type of
investment (including any investment and/or investment strategies recommended and/or
undertaken by Registrant), there can be no assurance that investment in ESG securities or
funds will be profitable or prove successful. Registrant does not maintain or advocate an
ESG investment strategy but will seek to employ ESG if directed by a client to do so. If
implemented, Registrant shall rely upon the assessments undertaken by the unaffiliated
mutual fund, exchange traded fund or separate account portfolio manager to determine
that the fund’s or portfolio’s underlying company securities meet a socially responsible
mandate.
Client Obligations. In performing its services, Registrant 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 the Registrant if there is ever any change in their
financial situation or investment objectives for the purpose of reviewing, evaluating or
revising Registrant’s previous recommendations and/or services.
Cybersecurity Risk. The information technology systems and networks that Registrant
and its third-party service providers use to provide services to Registrant’s clients employ
various controls, which are designed to prevent cybersecurity incidents stemming from
intentional or unintentional actions that could cause significant interruptions in
Registrant’s operations and result in the unauthorized acquisition or use of clients’
confidential or non-public personal information. Clients and Registrant are nonetheless
subject to the risk of cybersecurity incidents that could ultimately cause them to incur
losses, including for example: financial losses, cost and reputational damage to respond
to regulatory obligations, other costs associated with corrective measures, and loss from
damage or interruption to systems. Although Registrant has established procedures to
reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will
always be successful, especially considering that Registrant does not directly control the
cybersecurity measures and policies employed by third-party service providers. Clients
could incur similar adverse consequences resulting from cybersecurity incidents that
more directly affect issuers of securities in which those clients invest, broker-dealers,
qualified custodians, governmental and other regulatory authorities, exchange and other
financial market operators, or other financial institutions.
Disclosure Statement. A copy of the Registrant’s written Brochure as set forth on Part 2
of Form ADV (and as applicable, any Separately Managed Account Manager’s written
Brochure as set forth on Part 2 of Form ADV and the Registrant’s Client Relationship
Summary as set forth on Form CRS) shall be provided to each client prior to, or
contemporaneously with, the execution of the Investment Advisory Agreement.
C. The Registrant shall provide investment advisory services specific to the needs of each
client. Prior to providing investment advisory services, an investment adviser
representative will ascertain each client’s investment objective(s). Thereafter, the
Registrant shall allocate and/or recommend that the client allocate investment assets
consistent with the designated investment objective(s). The client may, at any time,
impose reasonable restrictions, in writing, on the Registrant’s services.
D. There is no significant difference between how the Registrant manages wrap fee accounts
and non-wrap fee accounts. However, as stated above, if a client determines to engage the
Registrant on a wrap fee basis the client will pay a single fee for bundled services (i.e.,
investment advisory, brokerage, custody) (See Item 4.B). The services included in a wrap
fee agreement will depend upon each client’s particular need. If the client determines to
engage the Registrant on a non-wrap fee basis the client will select individual services on
an unbundled basis, paying for each service separately (i.e., investment advisory, separate
account manager fees, brokerage, custody, etc.).
When managing a client’s account on a wrap fee basis, the Registrant 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.
E. As of Mach 1, 2024, the Registrant had approximately $493,880,715 in assets under
management on a discretionary basis and $4,608,466 in assets on a non-discretionary
basis.