Overview
- Headquarters
- Medford, NJ
- Total Firm Assets
- $131 million
- Average High-Net-Worth Client Portfolio Size
- $2.1 million
Fee Disclosure
BROCHURE
| Min | Max | Disclosed Annual Rate |
|---|---|---|
| $0 | $500,000 | 1.50% |
| $500,001 | $1,000,000 | 1.25% |
| $1,000,001 | and above | 1.00% |
Estimated Annual Advisory Fees
| Portfolio Value | Estimated Annual Fee | Effective Fee Rate |
|---|---|---|
| $1 million | $13,750 | 1.38% |
| $5 million | $53,750 | 1.08% |
| $10 million | $103,750 | 1.04% |
| $50 million | $503,750 | 1.01% |
| $100 million | $1,003,750 | 1.00% |
Actual fees may vary; other investment costs may apply.
Clients
- High-Net-Worth Share of Firm Assets
- 66.99%
- Number of High-Net-Worth Clients
- 41
- Total Client Accounts
- 560
- Discretionary Accounts
- 559
- Non-Discretionary Accounts
- 1
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 304935
Primary Brochure: BROCHURE (2026-04-13)
View Document Text
Family Wealth Partners, LLC
A SEC Registered Investment Adviser
152 Himmelein Road, Suite 700
Medford, NJ 08055
APRIL 2026
This brochure provides information about the qualifications and business practices of
Family Wealth Partners, LLC (“Family Wealth Partners”). If you have any questions
about the content of this brochure, please contact us at 609-975-8389. The information
in this brochure has not been approved or verified by the United States Securities and
Exchange Commission or by any state securities authority.
Additional information about Family Wealth Partners is also available on the SEC’s
website at www.adviserinfo.sec.gov.
SEC and/or state registration does not imply a certain level of skill or training.
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Material Changes
Family Wealth Partners has not had any material changes to its advisory business or personnel since
the filing of its Annual ADV Amendment in 2025.
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TABLE OF CONTENTS
Item 4. Advisory Business ......................................................................................................... 4
Item 5. Fees and Compensation ................................................................................................ 4
Item 6. Performance Based Fees and Side by Side Management ............................................ 6
Item 7. Types of Clients ............................................................................................................ 6
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss..................................... 7
Item 9. Disciplinary Information .............................................................................................. 8
Item 10. Other Financial Industry Activities and Affiliations ................................................... 8
Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading ...................................................................................................................................... 9
Item 12. Brokerage Practices ..................................................................................................... 9
Item 13. Review of Accounts ....................................................................................................11
Item 14. Client Referrals and Other Compensation ................................................................. 11
Item 15. Custody ...................................................................................................................... 12
Item 16. Investment Discretion ............................................................................................... 12
Item 17. Voting Client Securities ............................................................................................. 12
Item 18. Financial Information ................................................................................................ 12
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Item 4. Advisory Business
Family Wealth Partners offers wealth management services to individual and high net worth clients as
well as small businesses. The firm prides itself on its investment strategies, client service, and ongoing
commitment to bringing innovative solutions to its clients’ financial lives. Family Wealth Partners was
founded in July 2019 and is owned by Mark Finelli. Mr. Finelli has more than twenty (20) years of
experience as a Financial Advisor with major brokerage firms.
Currently, Family Wealth Partners provides discretionary wealth management to approximately
$131,000,000.00 in assets under management.
This Disclosure Brochure describes the business of Family Wealth Partners. Certain sections will also
describe the activities of Supervised Persons. Supervised Persons are any of Family Wealth Partners’ officers,
partners, directors (or other persons occupying a similar status or performing similar functions), or
employees, or any other person who provides investment advice on Family Wealth Partners’ behalf
and is subject to Family Wealth Partners’ supervision or control.
Wealth Management Services:
Family Wealth Partners provides investment management services on a discretionary and non-
discretionary basis according to the investment objectives of the client and in accordance with the
terms and conditions of the Investment Advisory Agreement between the Family Wealth Partners and
the client. Based upon the client’s stated investment objectives, Family Wealth Partners’ investment
management focuses on the use of Portfolio Models in order to provide investment returns consistent
with clients’ investment goals and objectives. Based upon a particular Model Portfolio, Family Wealth
Partners will invest client’s accounts in certain percentages amongst numerous asset classes (e.g.
stocks, corporate and government bonds, ETFs, mutual funds) in order to maximize client’s
investment returns while achieving lower volatility within pre-determined risk parameters.
Financial Planning Services:
In limited situations, Family Wealth Partners may provide financial planning and consultation services
on a standalone basis that does not include investment management services. (e.g., review of goals
and objectives, analysis and recommendations for cash flow planning, asset allocation/investment
planning, income tax planning, insurance planning, estate planning, retirement planning, education
planning, real estate/mortgage planning, etc.).
Item 5. Fees and Compensation
Family Wealth Partners offers its services on a fee basis, which may include fixed fees, as well as fees
based upon assets under management. Additionally, certain of Family Wealth Partners’ Supervised
Persons, in their individual capacities, may offer insurance products under a commission arrangement.
For all services, Family Wealth Partners’ annual fee is exclusive of, and in addition to brokerage
commissions, transaction fees, and other related costs and expenses which are incurred by the client.
Family Wealth Partners does not, however, receive any portion of these commissions, fees, and costs.
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Investment Management Fees:
Family Wealth Partners’ investment management fee schedule (“Advisory Fees”) for accounts
managed by Family Wealth Partners is based on a percentage of assets (generally net of any debit
balances) and is set forth below. The Advisory Fees represent the highest fee that may be charged
absent special circumstances:
Advisory Assets Annual Fee
0 - $500,000 1.50%
$500,001 - $1,000,000
1.25%
All assets in excess of $1 million 1.00%
Family Wealth Partners’ Advisory Fees shall also be prorated and paid monthly, in arrears, based upon
the market value of the assets on the last business day of the previous quarter. Family Wealth Partners’
actual fees may be negotiated, and a client may pay more or less than similar clients depending on the
particular circumstances of the client, which may include considerations related to size of the client’s
account, additional and/or differing levels of service or as negotiated. Clients that negotiate fees may
end up paying a higher fee than that set forth in the fee schedules above as a result of fluctuations in
the client’s assets under management and/or account performance.
Financial Planning Fees:
In very limited situations where Family Wealth Partners is engaged solely for Financial
Planning/Consulting, the firm’s financial planning and consulting fees are negotiable, but generally
are $300 on an hourly rate basis depending upon the level and scope of the service(s) required and the
professional(s) rendering the service(s). Prior to engaging Family Wealth Partners to provide financial
planning or consulting services, clients will be required to enter into a Financial Planning Agreement with
Family Wealth Partners setting forth the terms and conditions of the engagement.
Fees Charged by Financial Institutions
Family Wealth Partners generally recommends that clients utilize the brokerage and clearing services
of Charles Schwab & Co., Inc., member FINRA/SIPC (“Schwab”) for investment management
accounts.
Family Wealth Partners may only implement its investment management recommendations after the
client has arranged for and furnished Family Wealth Partners with all information and authorization
regarding accounts with appropriate financial institutions. Clients may incur certain charges imposed
by the Financial Institutions and other third parties such as fees charged by Independent Managers ,
custodial fees, charges imposed directly by a mutual fund or ETF in the account, which are disclosed
in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges,
odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on
brokerage accounts and securities transactions.
Additionally, clients may incur brokerage commissions and transaction fees. Such charges, fees and
commissions are exclusive of and in addition to Family Wealth Partners’ fee. Family Wealth Partners’
Agreement and the separate agreement with any Financial Institutions may authorize Family Wealth
Partners or Independent Managers to debit the client’s account for the amount of Family Wealth
Partners’ fee and to directly remit that management fee to Family Wealth Partners or the Independent
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Managers. Any Financial Institutions recommended by Family Wealth Partners 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 Family Wealth Partners. Alternatively, clients may
elect to have Family Wealth Partners send an invoice for payment.
Fees for Management During Partial Monthly Service
For the initial period of investment management services, the fees are calculated on a pro rata basis.
The Agreement between Family Wealth Partners and the client will continue in effect until terminated
by either party pursuant to the terms of the Agreement. Family Wealth Partners’ fees are charged in
arrears so that any termination date shall be prorated and deducted from any remaining balance
charged to the client. Clients may make additions to and withdrawals from their account at any time,
subject to Family Wealth Partners’ right to terminate an account. Additions may be in cash or securities
provided that Family Wealth Partners reserves the right to liquidate any transferred securities or
decline to accept particular securities into a client’s account.
Clients may withdraw account assets on notice to Family Wealth Partners, subject to the usual and
customary securities settlement procedures. However, Family Wealth Partners designs its portfolios
as long-term investments, and the withdrawal of assets may impair the achievement of a client’s
investment objectives. Family Wealth Partners 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.
Commissionable Securities Sales
Representative(s) of our firm are registered representatives of Purshe Kaplan Sterling Investments,
Inc (“PKS”), member FINRA/SIPC. As such they are able to accept compensation for the sale of
securities or other investment products, including distribution or service (“trail”) fees from the sale of
mutual funds. Clients should be aware that the practice of accepting commissions for the sale of
securities presents a conflict of interest and gives our firm and/or our representatives an incentive to
recommend investment products based on the compensation received. Our firm generally addresses
commissionable sales conflicts that arise when explaining to clients that these sales create an incentive
to recommend based on the compensation to be earned and/or when recommending commissionable
mutual funds, explaining that “no-load” funds are also available
Item 6. Performance-Based Fees and Side-by-Side Management
Family Wealth Partners does not charge a performance-based fee.
Item 7. Types of Clients
Family Wealth Partners provides its services to individuals, trusts, estates, and business entities.
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
Family Wealth Partners’ primary methods of analysis are fundamental and technical:
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Fundamental analysis involves the fundamental financial condition and competitive position of a
Company or asset class. Family Wealth Partners may analyze the financial condition, capabilities of
management, earnings, new products, and services, as well as the company’s or asset class’ markets
and position amongst its competitors in order to determine the recommendations made to clients.
The primary risk in using fundamental analysis is that while the overall health and position of a
company or asset class may be good, market conditions may negatively impact the security
Technical analysis involves the analysis of past market data rather than specific company data in
determining the recommendations made to clients. Technical analysis may involve the use of charts
to identify market patterns and trends which may be based on investor sentiment rather than the
fundamentals of the company. The primary risk in using technical analysis is that spotting historical
patterns may not help to predict such patterns in the future. Even if the pattern will eventually reoccur,
there is no guarantee that Family Wealth Partners will be able to accurately predict such a reoccurrence.
Investment Strategies
Family Wealth Partners customizes its asset management strategies based on individual needs and
concerns of their clients. While Family Wealth Partners offers each of the services described in Item
4 (above), the main focuses of the firm are its diversified portfolio management For its diversified
portfolio management, Family Wealth Partners may recommend a combination of in-house Model
portfolios and Independent Managers depending on the needs and goals of the client. Family Wealth
Partners selects securities and asset managers for the portfolio based on asset allocation decisions and
what suits the client’s needs and goals most appropriately. Specifically, Family Wealth Partners tries
to determine the mix of stock, bonds, money markets, and other investments that it feels offers the
best combination of potential return and risk. At any given time, Family Wealth Partners may allocate
all, a portion, or none of the portfolio’s assets to various areas of the stock, bonds, or alternative
investments.
Risks of Loss
Market Risks
The profitability of a significant portion of Family Wealth Partners’ recommendations may depend to
a great extent upon correctly assessing the future course of price movements of stocks and bonds.
There can be no assurance that Family Wealth Partners will be able to predict those price movements
accurately.
Use of Independent Managers
Family Wealth Partners may recommend the use of Independent Managers for certain clients. Family
Wealth Partners will continue to do ongoing due diligence of such managers, but such
recommendations rely, to a great extent, on the Independent Managers ability to successfully implement
their investment strategy. In addition, Family Wealth Partners does not have the ability to supervise
the Independent Managers on a day-to- day basis other than as previously described in response to Item
4, above.
Management Through Similarly Managed Accounts
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For certain clients, Family Wealth Partners may manage portfolios by allocating portfolio assets among
various securities on a discretionary basis using one or more of its proprietary investment strategies
(collectively referred to as “investment strategy”). In so doing, Family Wealth Partners buys, sells, and
exchanges and/or transfers securities based upon the investment strategy. Family Wealth Partners’
management using the investment strategy complies with the requirements of Rule 3a- 4 of the
Investment Company Act of 1940, as amended. Rule 3a-4 provides similarly managed accounts, such
as the investment strategy, with a safe harbor from the definition of an investment company. Securities
in the investment strategy are usually exchanged and/or transferred without regard to a client’s individual
tax ramifications. Certain investment opportunities that become available to Family Wealth Partners’
clients may be limited. As further discussed in response to Item 12B (below), Family Wealth Partners
allocates investment opportunities among its clients on a fair and equitable basis.
General Risk of Loss
Investing in securities involves the risk of loss. Clients should be prepared to bear such loss.
Item 9. Disciplinary Information
Family Wealth Partners is required to disclose the facts of any legal or disciplinary events that are
material to a client’s evaluation of its advisory business or the integrity of management. Family Wealth
Partners does not have any required disclosures to this Item.
Item 10. Other Financial Industry Activities and Affiliations
Family Wealth Partners is required to disclose any relationship or arrangement that is material to its
advisory business or to its clients with certain related persons. Family Wealth Partners has described
such relationships and arrangements below.
Receipt of Insurance Commissions
Certain of Family Wealth Partners’ Supervised Persons, in their individual capacities, are also licensed
insurance agents with various insurance companies, and in such capacity, may recommend, on a fully-
disclosed commission basis, the purchase of certain insurance products. While Family Wealth Partners
does not sell such insurance products to its investment advisory clients, Family Wealth Partners does
permit its Supervised Persons, in their individual capacities as licensed insurance agents, to sell
insurance products to its investment advisory clients. A conflict of interest exists when Family Wealth
Partners’ Supervised Persons recommends insurance products and receives compensation.
Registered Representative of Broker-Dealer:
Certain of Family Wealth Partners’ Supervised Persons, in their individual capacities, are registered
representatives of PKS a SEC registered, FINRA Member broker-dealer. Brokerage commissions may
be charged by PKS to effect securities transactions and thereafter, a portion of these commissions
may be paid by PKS to Family Wealth Partners’ Supervised Persons. Prior to effecting any
transactions, the client will be required to enter directly into an account agreement with PKS. The
brokerage commissions charged by PKS may be higher or lower than those charged by other broker-
dealers. In addition, certain of the Family Wealth Partners’ Supervised Persons may also receive
additional ongoing 12b-1 fees from the mutual fund company.
A conflict of interest exists to the extent that Family Wealth Partners recommends the purchase of
securities through PKS wherein its Supervised Persons receive commissions or other additional
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compensation as a result of clients purchasing securities based upon such recommendations. Family
Wealth Partners mitigates this risk by always acting in the best interests of its clients.
Item 11. Code of Ethics
Family Wealth Partners and persons associated with Family Wealth Partners(“Associated Persons”)
are permitted to buy or sell securities that it also recommends to clients consistent with Family Wealth
Partners’ policies and procedures. Family Wealth Partners has adopted a code of ethics that sets forth
the standards of conduct expected of its associated persons and requires compliance with applicable
securities laws (“Code of Ethics”). In accordance with Section 204A of the Investment Advisers Act of
1940 (the “Advisers Act”), its Code of Ethics contains written policies reasonably designed to prevent
the unlawful use of material non-public information by Family Wealth Partners or any of its associated
persons. The Code of Ethics also requires that certain of Family Wealth Partners’ personnel (called
“Access Persons”) report their personal securities holdings and transactions and obtain pre-approval of
certain investments such as initial public offerings and limited offerings.
Unless specifically permitted in Family Wealth Partners’ Code of Ethics, none of Family Wealth Partners’
Access Persons may effect for themselves or for their immediate family (i.e., spouse, minor children, and
adults living in the same household as the Access Person) any transactions in a security which is being
actively purchased or sold or is being considered as such on behalf of Family Wealth Partners’ clients.
When Family Wealth Partners is purchasing or considering purchasing any security on behalf of a
client, no Access Person may effect a transaction in that security prior to the completion of the purchase
or until a decision has been made not to purchase such security. Similarly, when Family Wealth
Partners is selling or considering the sale of any security on behalf of a client, no Access Person may
effect a transaction in that security prior to the completion of the sale or until a decision has been
made not to sell such security.
Clients and prospective clients may contact Family Wealth Partners to request a copy of its Code of
Ethics.
Item 12. Brokerage Practices
As discussed above, in Item 5, Family Wealth Partners generally recommends that clients utilize the
brokerage and clearing services of Schwab. Factors which Family Wealth Partners considers in
recommending the Custodians or any other broker-dealer to clients include their respective financial
strength, reputation, execution, pricing, research, and service. Schwab enables Family Wealth Partners
to obtain many mutual funds without transaction charges and other securities at nominal transaction
charges. The commissions and/or transaction fees charged may be higher or lower than those charged
by other Financial Institutions.
The commissions paid by Family Wealth Partners’ clients comply with Family Wealth Partners’ duty
to obtain “best execution.” Clients may pay commissions that are higher than another qualified
Financial Institutions might charge to effect the same transaction where Family Wealth Partners
determines that the commissions are reasonable in relation to the value of the brokerage and research
services received. In seeking best execution, the determinative factor is not the lowest possible cost,
but whether the transaction represents the best qualitative execution, taking into consideration the full
range of a Financial Institution’s services, including among others, the value of research provided,
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execution capability, commission rates, and responsiveness. Family Wealth Partners seeks competitive
rates but may not necessarily obtain the lowest possible commission rates for client transactions.
Family Wealth Partners periodically and systematically reviews its policies and procedures regarding
its recommendation of Financial Institutions in light of its duty to obtain best execution. The client may
direct Family Wealth Partners in writing to use a particular Financial Institution to execute some or all
transactions for the client. In that case, the client will negotiate terms and arrangements for the account
with that Financial Institution, and Family Wealth Partners will not seek better execution services or
prices from other Financial Institutions or be able to “batch” client transactions for execution through
other Financial Institutions with orders for other accounts managed by Family Wealth Partners. As a
result, the client 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. Subject to
its duty of best execution, Family Wealth Partners may decline a client’s request to direct brokerage if,
in Family Wealth Partners’ sole discretion, such directed brokerage arrangements would result in
additional operational difficulties or violate restrictions imposed by other broker-dealers (as further
discussed below). Transactions for each client generally will be effected independently unless Family
Wealth Partners decides to purchase or sell the same securities for several clients at approximately the
same time. Family Wealth Partners may (but is not obligated to) combine or “batch” such orders to
obtain best execution, to negotiate more favorable commission rates, or to allocate equitably among
Family Wealth Partners’ clients.
To the extent that Family Wealth Partners determines to aggregate client orders for the purchase or
sale of securities, including securities in which Family Wealth Partners’ Supervised Persons may invest,
Family Wealth Partners generally does so in accordance with applicable rules promulgated under the
Advisers Act and no-action guidance provided by the staff of the U.S. Securities and Exchange
Commission. Family Wealth Partners does not receive any additional compensation or remuneration
as a result of the aggregation. In the event that Family Wealth Partners determines that a prorated
allocation is not appropriate under the particular circumstances, the allocation will be made based
upon other relevant factors, which may include: (i) when only a small percentage of the order is
executed, shares may be allocated to the account with the smallest order or the smallest position or to
an account that is out of line with respect to security or sector weightings relative to other portfolios,
with similar mandates; (ii) allocations may be given to one account when one account has limitations
in its investment guidelines which prohibit it from purchasing other securities which are expected to
produce similar investment results and can be purchased by other accounts; (iii) if an account reaches
an investment guideline limit and cannot participate in an allocation, shares may be reallocated to other
accounts (this may be due to unforeseen changes in an account’s assets after an order is placed); (iv)
with respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a
pro rata allocation of a potential execution would result in a de minimis allocation in one or more
accounts, Family Wealth Partners may exclude the account(s) from the allocation; the transactions
may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a small
proportion of an order is executed in all accounts, shares may be allocated to one or more accounts
on a random basis.
Consistent with obtaining best execution, brokerage transactions may be directed to certain broker-
dealers in return for investment research products and/or services which assist Family Wealth Partners
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in its investment decision-making process. Such research generally will be used to service all of Family
Wealth Partners’ clients, but brokerage commissions paid by one client may be used to pay for research
that is not used in managing that client’s portfolio. The receipt of investment research products and/or
services as well as the allocation of the benefit of such investment research products and/or services
poses a conflict of interest because Family Wealth Partners does not have to produce or pay for the
products or services.
Software and Support Provided by Financial Institutions
Family Wealth Partners may receive from Schwab, without cost to Family Wealth Partners, computer
software, and related systems support, which allow Family Wealth Partners to better monitor client
accounts maintained at Schwab. Family Wealth Partners may receive the software and related support
without cost because Family Wealth Partners renders investment management services to clients that
maintain assets at Schwab. The software and related systems support may benefit Family Wealth
Partners, but not its clients directly. In fulfilling its duties to its clients, Family Wealth Partners
endeavors at all times to put the interests of its clients first. Clients should be aware, however, that
Family Wealth Partners’ influence Family Wealth Partners’ choice of broker-dealer over another
broker-dealer that does not furnish similar software, systems support, or services. Additionally, Family
Wealth Partners may receive the following benefits from Schwab through their respective investment
adviser divisions: receipt of duplicate client confirmations and bundled duplicate statements; access to
a trading desk that exclusively services its investment adviser participants; access to block trading
which provides the ability to aggregate securities transactions and then allocate the appropriate shares
to client accounts; and access to an electronic communication network for client order entry and
account information.
13. Review of Accounts
For those clients to whom Family Wealth Partners provides wealth management services, Family
Wealth Partners monitors those portfolios as part of an ongoing process while regular account reviews
are conducted on at least an annual basis. Such reviews are conducted by one of Family Wealth
Partners’ investment adviser representatives. All investment advisory clients are encouraged to discuss
their needs, goals, and objectives with Family Wealth Partners and to keep Family Wealth Partners
informed of any changes thereto. Family Wealth Partners contacts ongoing investment advisory clients
at least annually to review its previous services and/or recommendations and to discuss the impact
resulting from any changes in the client’s financial situation and/or investment objectives. Unless
otherwise agreed upon, clients are provided with transaction confirmation notices and regular
summary account statements directly from the broker-dealer or custodian for the client accounts.
Item 14. Client Referrals and Other Compensation
Family Wealth Partners does not have a referral arrangement in which it pays compensation to a third
party for client referrals.
Item 15. Custody
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Family Wealth Partners does not maintain physical custody client assets. Family Wealth Partners
engages several qualified, nationally recognized SEC registered broker-dealers to custody and safe keep
client assets. Family Wealth Partners’ Agreement and/or the separate agreement with any Financial
Institution may authorize Family Wealth Partners through such Financial Institution to debit the client’s
account for the amount of Family Wealth Partners’ fee and to directly remit that management fee to
Family Wealth Partners in accordance with applicable custody rules. The Financial Institutions
recommended by Family Wealth Partners have agreed to send a statement to the client, at least
quarterly, indicating all amounts disbursed from the account.
Family Wealth Partners effects third party asset transfers in client accounts using a Standing Letter of
Authorization (“SLOA”). Pursuant to the SEC No Action Letter, Family Wealth Partners is deemed
to have Custody over these accounts. Accordingly, Family Wealth Partners has instituted procedures
and controls such that it can comply with the seven representations noted in the SEC No-Action letter
and avoid the annual surprise audit requirement.
Item 16. Investment Discretion
Family Wealth Partners generally is granted the authority to exercise discretion on behalf of its clients.
Family Wealth Partners is considered to exercise investment discretion over a client’s account if it can
affect transactions for the client without first having to seek the client’s consent. Family Wealth
Partners is given this authority through a power-of-attorney included in the agreement between Family
Wealth Partners and the client. Clients may request a limitation on this authority (such as certain
securities not to be bought or sold).
Item 17. Voting Client Securities
Family Wealth Partners votes proxies for clients who have given formal permission to their custodians
for this service. Proxies are generally voted according to management’s recommendations except in
cases where a proposal clearly conflicts with clients’ interests in the view of Family Wealth Partners.
In that instance, Family Wealth Partners will notify the client for their approval.
With respect to shareholder class action litigation and similar matters, Family Wealth Partners
generally will not make any filings in connection with any shareholder class action lawsuits involving
securities currently or previously held in clients’ accounts but will forward these notices to clients
when received. Family Wealth Partners recommends that its clients promptly review such materials,
as they identify important deadlines and may require action on the client’s part. Family Wealth Partners
will not be required to notify third party custodians or clients who utilize third party custodians of
shareholder class action lawsuits and similar matters.
Item 18. Financial Information
Family Wealth Partners does not require or solicit the prepayment of more than $500 in fees six
months or more in advance. In addition, Family Wealth Partners is required to disclose any financial
condition that is reasonably likely to impair its ability to meet contractual commitments to clients.
Family Wealth Partners has no disclosures pursuant to this Item.