Firm Description
Darwin Wealth Management, LLC is a registered investment adviser primarily based in Tampa,
Florida. We are organized as a limited liability company under the laws of the State of Florida. We
have been providing investment advisory services since 2012. We are owned by Darwin Partners,
LLC.
We are indirectly owned by Michael Bartolotta, Jeremy Bartolotta, and Michael Sorrentino through
MRM Equity Group Holdings, LLC. MRM Equity Group Holdings, LLC is the direct owner of Darwin
Partners, LLC.
The following paragraphs describe our services and fees. Refer to the description of each
investment advisory service listed below for information on how we tailor our advisory services to
your individual needs. As used in this brochure, the words "we," "our," and "us" refer to Darwin
Wealth Management and the words "you," "your," and "client" refer to you as either a client or
prospective client of our firm.
Portfolio Management Services
We offer discretionary and non-discretionary portfolio management services. Our investment
advice is tailored to meet our clients' needs and investment objectives. If you retain our firm for
portfolio management services, we will meet with you to determine your investment objectives, risk
tolerance, and other relevant information at the beginning of our advisory relationship. We will use
the information we gather to develop a strategy that enables our firm to give you continuous and
focused investment advice and/or to make investments on your behalf. As part of our portfolio
management services, we may customize an investment portfolio for you according to your risk
tolerance and investing objectives. We may also invest your assets according to one or more
model portfolios developed by our firm and/or an unaffiliated investment manager. Once we
construct an investment portfolio for you, or select a model portfolio, we will monitor your portfolio's
performance on an ongoing basis and will rebalance the portfolio as required by changes in
market conditions and in your financial circumstances.
If you participate in our discretionary portfolio management services, we require you to grant our
firm discretionary authority to manage your account. Discretionary authorization will allow us to
determine the specific securities, and the amount of securities, to be purchased or sold for your
account without your approval prior to each transaction. Discretionary authority is typically
granted by the investment advisory agreement you sign with our firm and the appropriate trading
authorization forms. You may limit our discretionary authority (for example, limiting the types of
securities that can be purchased or sold for your account) by providing our firm with your
restrictions and guidelines in writing.
In limited circumstances and in our sole discretion, we may agree to provide non-discretionary
portfolio management services. If you enter into non-discretionary arrangements with our firm, we
must obtain your approval prior to executing any transactions on behalf of your account. You have
an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary
basis.
As part of our portfolio management services, we may invest your assets according to one or more
model portfolios developed by either our firm or another investment manager. These models are
designed for investors with varying degrees of risk tolerance ranging from a more aggressive
investment strategy to a more conservative investment approach. Clients whose assets are
invested in model portfolios may not set restrictions on the specific holdings or allocations within
the model, nor the types of securities that can be purchased in the model. Nonetheless, clients may
impose restrictions on investing in certain securities or types of securities in their account. In such
cases, this may prevent a client from investing in certain models that are managed by our firm.
Additionally, as part of our portfolio management services, we may use one or more sub-advisers
to manage a portion of your account on a discretionary basis. The sub-adviser(s) may use one or
more of their model portfolios to manage your account. We will regularly monitor the performance
of your accounts managed by sub-adviser(s) and may hire and fire any sub-adviser without your
prior approval. We may pay a portion of our advisory fee to the sub-adviser(s) we use; however,
you will not pay our firm a higher advisory fee as a result of any sub-advisory relationships. Models
are subject to an additional model fee. Our fees are disclosed in Item 5 of this brochure.
Web-Based Portfolio Management
In addition to our traditional portfolio management services, we also offer discretionary web-
based portfolio management services. The web-based option is offered through and in
conjunction with the Betterment For Advisors platform ("Betterment"), which is an automated and
interactive web-based investment management system that utilizes algorithms to advise and
manage accounts. These algorithms are developed, overseen, and monitored by Betterment's
investment advisory personnel.
The investment advice rendered through this program is tailored to meet your individual investment
needs and objectives and is delivered exclusively based upon information you submit via an online
investment questionnaire. Your responses to the online investment questionnaire are used to
determine whether the available investment programs offered are appropriate for you generally,
and, if so, to select a particular investment option that fits with your unique investment profile. After
submission of the online investment questionnaire, an investment option will be selected for you.
Subject to our supervision, input, and oversight, Betterment will manage the investment and
reinvestment of your assets within the program, in a manner that is consistent with the Investment
Policy Statement "IPS" we develop for you. The investment and reinvestment of your assets within
the program is managed on a discretionary basis by Betterment and will occur automatically in
accordance with the investment program that has been selected. Betterment will automatically re-
balance your holdings on a periodic basis to maintain the target asset allocation percentages within
the selected investment program. You can change your investment allocations and/or investment
strategy at any time by going online and updating your web-based information.
You will be required to enter into a separate discretionary advisory agreement with Betterment. You
may withdraw assets from your account at any time directly via the web-based portal, subject to the
usual and customary securities settlement procedures. Our investment strategies typically rely on
long- term investment strategies and asset withdrawals may therefore impair the achievement of
your specific investment objectives.
In providing the portfolio management services under this program, all information will be
provided through the web-based portal. Our firm will not verify any information we receive from
you, or your agent(s), and we will rely on the information you provide. It is your responsibility to
promptly
update your account application through the web-based portal if there are ever any
changes in your financial situation or investment objectives for the purpose of reallocating and/or
re-balancing your account.
Selection of Other Advisers
We may recommend that you use the services of a third-party money manager ("TPMM") to
manage all, or a portion of, your investment portfolio. After gathering information about your
financial situation and objectives, we may recommend that you engage a specific TPMM or
investment program. Factors that we take into consideration when making our recommendation(s)
include, but are not limited to, the following: the TPMM's performance, methods of analysis, fees,
your financial needs, investment goals, risk tolerance, and investment objectives. We will monitor
the TPMM(s)' performance to ensure its management and investment style remains aligned with
your investment goals and objectives. The TPMM(s) will actively manage your portfolio and will
assume discretionary investment authority over your account. We will assume discretionary
authority to hire and fire TPMM(s) and/or reallocate your assets to other TPMM(s) where we deem
such action appropriate.
Financial Planning Services
We offer financial planning services which typically involve providing a variety of advisory
services to clients regarding the management of their financial resources based upon an analysis
of their individual needs. These services can range from broad-based financial planning to
consultative or single subject planning. If you retain our firm for financial planning services, we
will meet with you to gather information about your financial circumstances and objectives. Once
we review and analyze the information you provide to our firm we will deliver a written plan to
you, designed to help you achieve your stated financial goals and objectives.
Financial plans are based on your financial situation at the time we present the plan to you, and on
the financial information you provide to us. You must promptly notify our firm if your financial
situation, goals, objectives, or needs change.
You are under no obligation to act on our financial planning recommendations. Should you choose
to act on any of our recommendations, you are not obligated to implement the financial plan
through any of our other investment advisory services. Moreover, you may act on our
recommendations by placing securities transactions with any brokerage firm.
Financial Consulting Services
We offer financial consulting services that primarily involve advising clients on specific financial-
related topics. The topics we address may include, but are not limited to, risk
assessment/management, investment planning, financial organization, or financial decision
making/negotiation.
Pension Consulting Services
We offer pension consulting services to employee benefit plans and their fiduciaries based upon the
needs of the plan and the services requested by the plan sponsor or named fiduciary. In general,
these services may include an existing plan review and analysis, plan-level advice regarding fund
selection and investment options, education services to plan participants, investment performance
monitoring, and/or ongoing consulting. These pension consulting services may be non-discretionary
and advisory in nature. The ultimate decision to act on behalf of the plan shall remain with the plan
sponsor or other named fiduciary.
We may also assist with participant enrollment meetings and provide investment-related
educational seminars to plan participants on such topics as:
• Diversification
• Asset allocation
• Risk tolerance
• Time horizon
Our educational seminars may include other investment-related topics specific to the particular plan.
We may also provide additional types of pension consulting services to plans on an individually
negotiated basis. All services, whether discussed above or customized for the plan based upon
requirements from the plan fiduciaries (which may include additional plan-level or participant-level
services) shall be detailed in a written agreement and be consistent with the parameters set forth in
the plan documents.
Wrap Fee Programs
While we do not sponsor a wrap fee program, we may recommend TPMMs or Sub-advisers that
utilize a wrap fee program. A wrap fee program is a type of investment program that provides
clients with access to several money managers or mutual fund asset allocation models for a single
fee that includes administrative fees, management fees, and commissions. If you participate in a
wrap fee program, you will pay a single fee that includes money management fees, certain
transaction costs, and custodial and administrative costs. The overall cost you will incur if you
participate in a wrap fee program may be higher or lower than you might incur by separately
purchasing the types of securities available in the program.
Types of Investments
We offer advice on equity securities, corporate debt securities (other than commercial paper),
structured notes, certificates of deposit, municipal securities, mutual fund shares, exchange-traded
funds (ETFs), United States government securities, options contracts on securities, fee-based
annuities, cryptocurrency, and money market funds.
Additionally, we may advise you on other various types of investments based on your stated goals
and objectives. We may also provide advice on any type of investment held in your portfolio at the
inception of our advisory relationship.
Since our investment strategies and advice are based on each client's specific financial situation,
the investment advice we provide to you may be different or conflicting with the advice we give to
other clients regarding the same security or investment.
We have entered into agreements with Flourish Digital Assets LLC (“Flourish Digital Assets”) and
Paxos Trust Company, LLC (“Paxos”) to offer certain eligible clients the opportunity to invest in
cryptocurrency through Flourish Crypto accounts offered on the Flourish platform. A Flourish
Crypto account is a cryptocurrency investment account custodied by Paxos through which
investors can trade cryptocurrencies and maintain custody of cryptocurrencies and U.S. dollars.
Clients that invest through a Flourish Crypto account will execute agreements with Flourish
Digital Assets and Paxos. We provide clients with the option of opening client-directed accounts.
Darwin Wealth Management is not affiliated with either Flourish or Paxos.
In February 2022, we began to offer an unregistered structured note products provided by
and issued through affiliates of Longevity Market Assets. As the structured note offering is an
unregistered securities product (also known as a private placement), it is therefore limited to
only certain accredited investors, as defined in Rule 501 of Regulation D promulgated under
the Securities Act of 1933, qualified to purchase units in the offering. Darwin Wealth
Management is not affiliated with Longevity Market Assets.
Client Assets Under Management
As of December 31, 2023, we provide continuous management services for $570,644,163 in client
assets on a discretionary basis.