We are dedicated to providing individuals and other types of clients with a wide array of investment
advisory services. Our firm is a Limited Liability Company formed in the State of Massachusetts. Our firm
has been in business since February 2001, and an investment adviser since 2012. Our firm is owned by
AAFCPAs, Inc.
Advisory Services We Offer
Asset Management:
We emphasize continuous and regular account supervision. As part of our asset management service, we
generally propose an investment portfolio, consisting of individual stocks or bonds, exchange traded funds
(“ETFs”), options, mutual funds and other public and private securities or investments. The client’s
individual investment strategy is tailored to their specific needs and may include some or all of the
previously mentioned securities. Each portfolio will be initially designed to meet a particular investment
goal, which we determine to be suitable to the client’s circumstances. Each client shall also have the
opportunity to place reasonable restrictions on the types of investments to be held in the portfolio.
Once the appropriate portfolio has been determined and agreed upon, we will work with the client to
establish or transfer investment accounts so we can manage the client’s investment portfolio. Once the
relevant accounts are under our management, we review the client’s investment portfolio at least
quarterly and if necessary, rebalance the portfolio based upon the client’s individual needs, stated goals,
and objectives.
Sub-Advisor Accounts:
Under limited circumstances, we may use a third-party platform manager, Envestnet Asset Management,
Inc. (“Platform Manager”) or third-party investment advisory firm(s) or individual advisor(s) (“Asset
Manager”) to aid in the implementation of the investment portfolio designed by our firm. We feel that it
is important for clients to understand that the use of a Platform Manager or Asset Manager will be
reserved for unique situations such as clients who specifically request the use of a Platform Manager or
Asset Manager and those clients whose accounts are so small that our firm would only be able to continue
to act in a fiduciary manner by placing them with a Platform Manager or Asset Management. This is not a
add-on service or one that we will regularly recommend.
In these limited situations, before we select or agree to using a Platform Manager or Asset Manager for
the client’s accounts, we will ensure that the chosen party is properly licensed or registered. We will not
offer advice on any specific securities or other investments in connection with this limited aspect of our
service. We will, however, provide initial due diligence on the Platform Manager or Asset Manager and
ongoing reviews of their management of client accounts. We will also periodically review reports provided
to clients by the Platform Manager or Asset Manager at least annually. We will also contact clients from
time to time to review their financial situation and objectives, communicate information to the Platform
Manager or Asset Manager as warranted, and assist clients in understanding and evaluating the services
provided by the Platform Manager or Asset Manager. Clients working with a Platform Manager or Asset
Manager should also be aware that they, and not our firm, may periodically rebalance or adjust the client’s
accounts. If the client experiences any significant changes to his/her financial or personal circumstances,
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investment objectives, or account restrictions that could affect their financial standing, the client must
notify us so that we can consider such information in managing the client’s investments and whether the
Platform Manager or Asset Manager is still appropriate for their situation.
Pontera® Held Away Accounts:
In certain instances, our firm will provide an additional service for client’s held away accounts through the
Pontera platform (“the platform”). The accounts are not directly held in our custody (i.e., held away), but
are ones wherein we still have discretion, and may leverage an Order Management System to implement
tax-efficient asset location and opportunistic rebalancing strategies on behalf of the client. These are
primarily 401(k) accounts, PS Plans, 403bs, HSA’s, and other assets we do not custody and cannot manage
through our Asset Management service.
If our firm offers a client this service, then a link will be provided to the client allowing them to connect
an account(s) to the platform. Once the client’s account(s) are connected to the platform, our firm will
review their current account allocations. Our firm will then review these accounts on a regular basis and
when deemed necessary, our firm will rebalance the account considering client investment goals and risk
tolerance. Any change in allocations will consider current economic and market trends.
Pension Consulting:
We provide pension consulting services to employer plan sponsors plan trustees on an one time/ongoing
basis. Generally, such pension consulting services consist
of assisting employer plan sponsors in
establishing, monitoring and reviewing their company's participant-directed retirement plan. As the
needs of the plan sponsor dictate, areas of advising could include: investment options, plan structure and
participant education. Pension Consulting services typically include:
• Establishing an Investment Policy Statement – Our firm will assist in the development of a
statement that summarizes the investment goals and objectives along with the broad strategies
to be employed to meet the objectives.
• Investment Options – Our firm will work with the Plan Sponsor to evaluate existing investment
options and make recommendations for appropriate changes.
• Investment Monitoring – Our firm will be available to monitor the performance of the investments
and notify the client in the event of over/underperformance and in times of market volatility.
In providing services for pension consulting, we do not provide any advisory services with respect to the
following types of assets: employer securities, real estate (excluding real estate funds and publicly traded
REITS), participant loans, non-publicly traded securities or assets, other illiquid investments, or brokerage
window programs (collectively, “Excluded Assets”). All pension consulting services shall be in compliance
with the applicable state laws regulating retirement consulting services. This applies to client accounts
that are pension or other employee benefit plans (“Plan”) governed by the Employee Retirement Income
Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and we accept
appointments to provide our services to such accounts, we acknowledge that we are a fiduciary within
the meaning of Section 3(21) of ERISA (but only with respect to the provision of services described in
section 1 of the Pension Consulting Agreement).
Financial Planning & Consulting:
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We provide a variety of financial planning and consulting services to individuals, families, non-profits,
foundations and other clients regarding the management of their financial resources based upon an
analysis of the client’s current situation, goals, and objectives. Generally, such financial planning services
will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s
financial goals and objectives. This planning or consulting may encompass one or more of the following
areas: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning, Education
Planning, Cash Flow Analysis, Corporate and Personal Tax Planning, Corporate Structure, Real Estate
Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, Business and Personal
Financial Planning.
Our written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients. For example,
recommendations may be made that the clients begin or revise investment programs, create or revise
wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish
education or charitable giving programs. It should also be noted that we refer clients to an accountant,
attorney or other specialist, as necessary for non-advisory related services. For written financial planning
engagements, we provide our clients with a written summary of their financial situation, observations,
and recommendations. For financial consulting engagements, we usually do not provide our clients with
a written summary of our observations and recommendations as the process is less formal than our
planning service. Plans or consultations are typically completed within six (6) months of the client signing
a contract with us, assuming that all the information and documents we request from the client are
provided to us promptly. Implementation of the recommendations will be at the discretion of the client.
Tailoring of Advisory Services
We offer individualized investment advice to clients utilizing our firm’s Asset Management services.
Additionally, we offer general investment advice to clients utilizing our Financial Planning and Consulting
and Pension Consulting services as well as clients that we refer to a third-party money manager. Each
client has the opportunity to place reasonable restrictions on the types of investments to be held in the
portfolio. Restrictions on investments in certain securities or types of securities may not be possible due
to the level of difficulty this would entail in managing the account. Restrictions would be limited to our
Asset Management services. We do not manage assets through our other services.
Participation in Wrap Fee Programs
Our firm does not offer or sponsor a wrap fee program.
Regulatory Assets Under Management
As of December 31, 2023, we manage $390,925,803 on a discretionary basis and $116,217,791 on a
non-discretionary basis.