Overview
- Headquarters
- Glen Cove, NY
- Total Firm Assets
- $112 million
- Average High-Net-Worth Client Portfolio Size
- $1.3 million
- Minimum Account Size
- $100,000
Fee Structure
Primary Fee Schedule (ADV PART 2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.00% |
| $1,000,001 | $2,000,000 | 0.90% |
| $2,000,001 | $3,000,000 | 0.80% |
| $3,000,001 | $4,000,000 | 0.70% |
| $4,000,001 | $5,000,000 | 0.60% |
| $5,000,001 | and above | 0.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $40,000 | 0.80% |
| $10 million | $65,000 | 0.65% |
| $50 million | $265,000 | 0.53% |
| $100 million | $515,000 | 0.52% |
Clients
- High-Net-Worth Share of Firm Assets
- 61.72%
- Number of High-Net-Worth Clients
- 52
- Total Client Accounts
- 384
- Non-Discretionary Accounts
- 384
Services Offered
Services: Portfolio Management for Individuals, Pension Consulting, Investment Advisor Selection
Regulatory Filings
- SEC CRD Number
- 168081
Additional Brochure: ADV PART 2A (2026-07-24)
View Document Text
Abbondandolo Wealth
Management Corp
Firm Brochure - Form ADV Part 2A
This brochure provides information about the qualifications and business practices of Abbondandolo Wealth
Management Corp. If you have any questions about the contents of this brochure, please contact us at (516) 674-
9229 or by email at: vito@awmny.com. 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 Abbondandolo Wealth Management Corp is also available on the SEC’s website
at www.adviserinfo.sec.gov. Abbondandolo Wealth Management Corp’s CRD number is: 168081
220B Glen Cove Ave,
Glen Cove, New York, 11542
(516) 674-9229
www.awmny.com
vito@awmny.com
Registration does not imply a certain level of skill or training.
Version Date: 07/24/2026
Item 2: Material Changes
The material changes in this brochure from the last annual updating amendment of
Abbondandolo Wealth Management Corp on 01/23/2026 are described below. Material
changes relate to Abbondandolo Wealth Management Corp. policies, practices or conflicts of
interests only.
• Abbondandolo Wealth Management Corp disclosed its affiliation to Abbondandolo
& Co. CPAs & Advisors (Item 10).
• Abbondandolo Wealth Management Corp updated its assets under management to
disclose discretion (Item 4).
• Abbondandolo Wealth Management Corp has updated its brochure to provide
additional disclosures regarding its advisory services conducted through the SEI
investment platform, including related investment limitations, conflicts of interest,
brokerage practices, investment risks, and discretionary authority (Items 4, 8, 12, and
14).
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Item 3: Table of Contents
Item 1: Cover Page
Item 2: Material Changes ....................................................................................................................................2
Item 3: Table of Contents ....................................................................................................................................3
Item 4: Advisory Business ..................................................................................................................................4
Item 5: Fees and Compensation .........................................................................................................................6
Item 6: Performance-Based Fees and Side-By-Side Management .................................................................7
Item 7: Types of Clients.......................................................................................................................................7
Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss ...................................8
Item 9: Disciplinary Information ..................................................................................................................... 10
Item 10: Other Financial Industry Activities and Affiliations ..................................................................... 11
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........... 12
Item 12: Brokerage Practices ............................................................................................................................ 12
Item 13: Reviews of Accounts .......................................................................................................................... 14
Item 14: Client Referrals and Other Compensation ...................................................................................... 15
Item 15: Custody ................................................................................................................................................ 16
Item 16: Investment Discretion ........................................................................................................................ 16
Item 17: Voting Client Securities (Proxy Voting) .......................................................................................... 17
Item 18: Financial Information ......................................................................................................................... 17
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Item 4: Advisory Business
A. Description of the Advisory Firm
Abbondandolo Wealth Management Corp is an SEC Registered Investment
Advisor organized in the state of New York. The firm was founded in May of
2013, and the principal owner is Vito Abbondandolo.
B. Types of Advisory Services
Abbondandolo Wealth Management Corp (hereinafter "AWM") provides
investment advisory services based on a strategic asset allocation approach. Since
our inception we have operated as a fee-only firm.
AWM provides investment advisory services solely through the SEI investment
platform. SEI provides access to a variety of investment options, including
investment strategies managed by third-party investment managers, mutual funds,
exchange-traded funds ("ETFs"), and other investment vehicles available through
the platform.
AWM's role is to evaluate each client's financial circumstances, investment
objectives, risk tolerance, time horizon, liquidity needs, and other relevant factors
and recommend investment strategies available through SEI that are consistent
with the client's Investment Policy Statement. AWM does not independently select
investment managers outside of the SEI platform as part of its advisory services.
AWM relies on SEI's resources, including its research, selection, and ongoing due
diligence process with respect to third-party investment managers available
through the SEI platform. AWM reviews the investment options available through
SEI and determines whether a recommended investment strategy is appropriate
based on the client's individual circumstances.
Investment Supervisory Services
AWM offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. AWM creates an Investment
Policy Statement for each client, which outlines the client’s current situation (income,
tax levels, and risk tolerance levels) and then constructs an asset allocation plan to aid
in the selection of a portfolio that matches each client’s specific situation.
Investment Supervisory Services include, but are not limited to, the following:
•
•
•
Investment strategy •
•
Asset allocation
•
Risk tolerance
Personal investment policy
Regular portfolio monitoring
Tax Management
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AWM evaluates the current asset allocation of each client with respect to their risk
tolerance levels and time horizon. AWM will request discretionary authority from
clients when required in order to modify asset allocations without permission from
the client prior. Risk tolerance levels are documented in the Investment Policy
Statement, which is given to each client.
Services Limited to Specific Types of Investments
AWM's investment recommendations are limited to the investment products,
investment strategies, mutual funds, ETFs, and third-party investment managers
available through the SEI investment platform.
Because AWM utilizes SEI as its investment platform, AWM generally does not
recommend investment products, securities, or investment managers that are not
available through SEI. Clients should understand that other investment opportunities
may be available outside of the SEI platform; however, those options are generally not
considered as part of AWM's advisory services.
C. Client Tailored Services and Client Imposed Restrictions
AWM offers the same suite of services to all of its clients. However, specific client
investment strategies and their implementation are dependent upon the client
Investment Policy Statement which outlines each client’s current situation (income, tax
levels, and risk tolerance levels) and is used to construct a client specific plan to aid in
the selection of a portfolio that matches restrictions, needs, and targets.
AWM tailors investment recommendations to each client's individual circumstances,
including financial goals, investment objectives, risk tolerance, time horizon, liquidity
needs, and other relevant considerations. While AWM utilizes the SEI platform for
investment implementation, recommendations are made based on each client's
specific situation.
Clients may impose restrictions on investing in certain securities or types of securities
in accordance with their values or beliefs. However, because AWM utilizes the SEI
platform, client-imposed restrictions may limit the investment options available for
recommendation and may affect AWM's ability to implement certain investment
strategies.
If the restrictions prevent AWM from properly servicing the client account, or if the
restrictions would require AWM to deviate from its standard suite of services, AWM
reserves the right to end the relationship.
D. Wrap Fee Programs
AWM does not participate in wrap fee programs.
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E. Amounts Under Management
As of June 2026, our clients’ assets under management totaled $125,093,257 which
were comprised as followed:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$ 0.00
June 2026
$ 125,093,257
Item 5: Fees and Compensation
A. Fee Schedule
AWM is a fee-only investment advisor. We do not receive compensation from any
investment vehicle. We have no soft dollar arrangements (see item 12) with any
money manager or broker-dealer. We receive fees solely from our clients and
therefore are free from any potential conflicts of interest that other forms of
compensation might create.
Investment Supervisory Services Fees
Total Assets Under Management
Annual Fee
First $1,000,000
1.00%
$1,000,001 - $2,000,000
0.90%
$2,000,001 - $3,000,000
0.80%
$3,000,001 - $4,000,000
0.70%
$4,000,001 - $5,000,000
0.60%
Above $5,000,000
0.50%
These fees are negotiable depending upon the needs of the client and complexity of
the situation and the final fee schedule is attached as Exhibit II of the Investment
Advisory Contract. AWM uses the last day of previous month for purposes of
determining the market value of the assets upon which the advisory fee is based. Fees
are paid monthly in arrears. Clients may terminate the contract without penalty, for
full refund, within five business days of signing the contract. Thereafter, clients may
terminate the contract with thirty days’ written notice. The above fees are in addition
to the fees paid to SEI.
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B. Payment of Fees
Payment of Investment Supervisory Fees
Because fees are charged in arrears, no refund policy is necessary. Advisory fees are
withdrawn directly from the client’s accounts with client written authorization.
Advisory fees are prorated if services are rendered for only part of the month.
C. Clients Are Responsible For Third Party Fees
Advisory fees are withdrawn directly from the client’s SEI accounts with client written
authorization. Fees are paid monthly in arrears, the balance in the client’s account on the
last day of the billing period is used to determine the market value of the assets upon
which the advisory fee is based.
Clients are responsible for the payment of all SEI third party fees (i.e. custodian fees,
brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and
distinct from the fees and expenses charged by AWM. Please see Item 12 of this
brochure regarding broker/custodian.
D. Prepayment of Fees
AWM collects its fees in arrears. It does not collect fees in advance.
E. Outside Compensation For the Sale of Securities to Clients
Neither AWM nor its supervised persons accept any compensation for the sale of
securities or other investment products, including asset-based sales charges or service
fees from the sale of mutual funds.
Item 6: Performance-Based Fees and Side-By-Side Management
AWM does not accept performance-based fees or other fees based on a share of capital
gains on or capital appreciation of the assets of a client.
Item 7: Types of Clients
AWM generally provides management supervisory services to the following types of
clients:
❖ Individuals
❖ High-Net-Worth Individuals
❖ Trusts
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There is an account minimum of $100,000, which may be waived or reduced by AWM
in its discretion.
Item 8: Methods of Analysis, Investment Strategies, and Risk of
Investment Loss
A. Methods of Analysis and Investment Strategies
AWM advocates a strategic asset allocation investment approach that does not rely on
short term market forecasts. We recommend that clients diversify their portfolios
across a variety of major asset classes. Variations in the patterns of returns across these
asset classes mitigate the volatility risk at the portfolio level.
AWM implements client investment strategies primarily through the SEI investment
platform. The SEI platform provides access to a variety of investment solutions,
including mutual funds, exchange-traded funds ("ETFs"), and investment strategies
managed by third-party investment managers.
AWM relies on SEI for research, selection, and ongoing due diligence of third-party
investment managers available through the SEI platform. AWM evaluates the
investment options available through SEI and determines whether a particular
investment strategy is appropriate based on the client's investment objectives,
financial circumstances, risk tolerance, and other relevant factors.
AWM’s investment philosophy maintains that an investment portfolio's asset
allocation (choice of asset classes and the allocation of money across them) is a primary
determinant of its long-term investment performance. The markets primarily drive
investment results, rather than exercise of skill in either security selections or market
timing.
Client involvement in the design of the portfolio is critical to their success. AWM
arrives at the allocation for each client through education and consultation with the
client. Once the design process is complete, AWM follows a consistent and disciplined
investment management process for the implementation and ongoing management
of client portfolios in areas such as rebalancing, portfolio review, and review of
available investment strategies through SEI.
For qualified retirement plan clients, we construct investment options for plan
participants through consultation with the plan sponsor. By following the
methodology described above, we arrive at a number of options with varying risk/
return profiles. These portfolio options include various asset classes and investment
management styles that, in total, are expected to offer participants the opportunity to
diversify their retirement investments in a manner appropriate to their objectives, risk
tolerances, and return expectations.
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B. Material Risks Involved
While AWM's investment strategy helps to reduce the risks associated with investing,
it cannot eliminate risk altogether. All investments involve risks, including the
possible loss of principal. During their investment lifetimes, investors should be
prepared to encounter market environments in which they experience losses, perhaps
significant ones.
AWM seeks to mitigate investment risks in client portfolios through the breadth of
diversification across asset classes and across securities within asset classes. By
designing portfolios that capture the benefits of multiple-asset-class investing, we
help our clients pursue their financial goals with less volatility.
Because AWM utilizes SEI as its primary investment platform, AWM's investment
recommendations are limited to the investment products, strategies, mutual funds,
ETFs, and third-party investment managers available through SEI. Investment
opportunities outside of the SEI platform are generally not considered when AWM
provides investment recommendations.
This limitation may prevent AWM from recommending certain investment products,
strategies, or investment managers that may otherwise be appropriate for a client's
objectives but are not available through SEI. In addition, AWM relies on SEI's
research, selection, and due diligence processes with respect to third-party investment
managers available through the platform. If SEI's research, evaluation, or selection
process does not identify appropriate investment strategies or managers, client
portfolios may be adversely affected.
SEI may make available proprietary investment products in addition to unaffiliated
investment options. To the extent SEI proprietary mutual funds, ETFs, or other
investment products are available through the SEI platform and determined by AWM
to be appropriate for a client, AWM may recommend such investments. This creates
a potential conflict of interest because SEI or its affiliates may receive compensation
or otherwise benefit from assets invested in proprietary products available through
the platform.
Because of the diversification used in our investment strategy, our clients likely will
face a unique behavioral risk that would not be present if they chose a more traditional
U.S. stock and bond portfolio. We refer to this risk as "frame-of-reference" risk. It refers
to the difficulty that a U.S.-based investor may have adhering to a globally diversified
strategy during periods when the investor's domestic market is outperforming the
global strategy.
C. Risks of Specific Securities Utilized
When implementing client investment strategies, AWM generally uses pooled
vehicles, such as open-end mutual funds and exchange-traded funds ("ETFs"), and
may recommend separate account managers where appropriate. AWM does not make
recommendations of individual stocks or individual bonds.
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Mutual funds and ETFs are subject to risks associated with the underlying securities
held by the fund, including market risk, interest rate risk, credit risk, liquidity risk,
and other investment-specific risks. The value of mutual funds and ETFs will fluctuate
based on the performance of their underlying investments and market conditions.
Investments managed by third-party investment managers available through SEI are
subject to risks associated with the investment strategies employed by those
managers. Although SEI conducts research and due diligence regarding available
third-party managers, there is no guarantee that any selected manager or investment
strategy will achieve its investment objective.
Fixed income investments are subject to risks including interest rate risk, credit risk,
inflation risk, and the risk of loss of principal. Equity investments are subject to market
risk, including the potential loss of principal due to changes in market conditions,
economic conditions, or company-specific factors.
All investments involve risk, and past performance is not indicative of future
results.
Item 9: Disciplinary Information
As a Registered Investment Advisor, we are required to disclose any legal or
disciplinary events that might be material to a client's or prospective client's evaluation
of our advisory business or the integrity of our management.
A. Criminal or Civil Actions
AWM and its management have never been named, charged, convicted of, pled no
contest to, or been the subject of any order or judgment in a criminal or civil action in
a domestic, foreign, or military court of competent jurisdiction.
B. Administrative Proceedings
AWM and its management have never been involved in an administrative
proceeding before the SEC or any other federal, state, or foreign financial
regulatory authority.
C. Self-regulatory Organization (SRO) Proceedings
AWM and its management have never been involved in any self-regulatory
organization (SRO) proceeding.
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Item 10: Other Financial Industry Activities and Affiliations
A. Registration as a Broker/Dealer or Broker/Dealer Representative
Neither AWM nor its representatives are registered as, or have pending applications to
become, a broker/dealer or a representative of a broker/dealer.
B. Registration as a Futures Commission Merchant, Commodity Pool
Operator, or a Commodity Trading Advisor
Neither AWM nor its representatives are registered as or have pending applications
to become either a Futures Commission Merchant, Commodity Pool Operator, or
Commodity Trading Advisor or an associated person of the foregoing entities.
C. Registration Relationships Material to this Advisory Business and
Possible Conflicts of Interests
AWM is affiliated with Abbondandolo & Co. CPAs & Advisors, a certified public
accounting firm. All of AWM's Investment Adviser Representatives ("IARs") are
partners of the accounting firm. This affiliation creates a conflict of interest because
AWM's IARs may have a financial incentive to recommend the accounting firm's
services to advisory clients, and the accounting firm may refer its clients to AWM for
investment advisory services. As a result, AWM and its affiliated accounting firm may
benefit from reciprocal referrals. Clients are under no obligation to engage
Abbondandolo & Co. CPAs & Advisors for accounting or tax services or to retain
AWM for investment advisory services and are free to select any service provider of
their choosing. AWM addresses this conflict through disclosure of the affiliation,
informing clients of their freedom to choose unaffiliated service providers, and
maintaining policies and procedures designed to ensure that all recommendations are
made in the client's best interest and consistent with AWM's fiduciary duty.
D. Selection of Other Advisers or Managers and How This Adviser is
Compensated for Those Selections
We receive fees only from our clients and receive no commissions or compensation
from any other source, including any other investment advisors that we may
recommend.
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Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
A. Code of Ethics
AWM has a written Code of Ethics that covers the following areas: Prohibited
Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted
Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment,
Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance
with Laws and Regulations, Procedures and Reporting, Certification of Compliance,
Reporting Violations, Compliance Officer Duties, Training and Education,
Recordkeeping, Annual Review, and Sanctions. Our Code of Ethics is available free
upon request to any client or prospective client.
B. Recommendations Involving Material Financial Interests
AWM does not recommend that clients buy or sell any security in which a related
person to AWM or AWM has a material financial interest.
C. Investing Personal Money in the Same Securities as Clients
As part of its Code of Ethics, neither AWM nor its representatives will trade in
securities that AWM also recommends to clients.
D. Trading Securities At/Around the Same Time as Clients’ Securities
Please see Item 11C above.
Item 12: Brokerage Practices
A. Factors Used to Select Custodians and/or Broker/Dealers
AWM selects custodians based on various factors, including the availability of
investment products and services, transaction costs, access to mutual funds and
exchange-traded funds ("ETFs"), access to investment managers, operational support
services, reputation, technology capabilities, and the overall value of services
provided relative to the costs incurred.
AWM currently utilizes SEI Private Trust Company ("SEI"), located in Oaks,
Pennsylvania, as the custodian for client accounts.
SEI was selected based on a number of factors, including access to investment
strategies, mutual funds, investment managers, and ETFs; trading and technology
12
capabilities; operational support services; account reporting capabilities; reputation;
and the overall services provided in relation to the costs associated with maintaining
client accounts.
Because AWM utilizes SEI as its primary investment platform and custodian, AWM
generally limits client investment implementation to investment products, strategies,
mutual funds, ETFs, and third-party investment managers available through SEI. As
a result, AWM may not consider or recommend alternative custodians, broker-
dealers, investment platforms, or investment products that are not available through
SEI.
This limitation may create a potential conflict of interest because AWM receives
operational and administrative support services from SEI and has selected SEI as the
platform through which client accounts are maintained and investments are
implemented. Additionally, AWM's use of SEI may prevent AWM from obtaining
services, pricing, investment opportunities, or execution capabilities that may be
available through other custodians or platforms.
AWM believes that SEI provides an appropriate combination of investment access,
technology, operational support, reporting capabilities, and custodial services for
AWM's clients. AWM periodically reviews SEI's services and conducts due diligence
regarding the custodial relationship.
AWM does not charge clients a premium or commission on transactions beyond the
applicable costs imposed by the custodian. AWM does not receive compensation from
SEI based on client transactions.
AWM's clients who maintain accounts on the SEI platform are subject to SEI's cash
sweep program, pursuant to which uninvested cash in client accounts is automatically
swept into a designated program (the 'Sweep Program'). SEI receives compensation
from the Sweep Program
1. Research and Other Soft-Dollar Benefits
AWM does not participate in "soft dollar" arrangements. By virtue of custodian client
assets at SEI, we receive support services that enable us to monitor and service our
client accounts. This support includes:
o a dedicated service group and an account services manager dedicated to our
accounts
o electronic download of trades, balances, prices, and positions in SEl's portfolio
management software
o electronic access to SEl's proprietary internet site and their software-based system.
o client statements, confirmations, and year-end summaries
o
the ability to have advisory fees directly debited from client accounts {in accordance
with Federal and State requirements)
o client access to SEl's online service
13
o discounted or gratis attendance at SEI sponsored conferences, meetings, and other
educational events.
2. Brokerage for Client Referrals
AWM receives no referrals from a broker-dealer or third party in exchange for
using that broker-dealer or third party.
3. Clients Directing Which Broker/Dealer/Custodian to Use
AWM does not trade client’s accounts or recommend broker/custodians, and
therefore does not direct brokerage.
B. Aggregating (Block) Trading for Multiple Client Accounts
AWM does not trade client’s accounts or recommend broker/custodians, and
therefore does not have the ability to block trade purchases across accounts.
Item 13: Reviews of Accounts
A. Frequency and Nature of Periodic Reviews and Who Makes Those
Reviews
AWM regularly reviews client accounts. Our Investment Advisor Representative
(IAR’s) conduct a formal review of client accounts at least annually. (The IAR’s are
identified in out Form ADV 2B, the brochure supplement). For these reviews, the
IAR’s examine the overall portfolio structure as asset allocation to ensure that they are
consistent with the client’s Investment Policy Statement (IPS). The IAR’s also review
each recommended investment position to ensure that it continues to be an
appropriate investment for the portfolio. We also review our clients’ Investment
Policy Statements on an annual basis. In the process we review the clients:
Investment objectives
•
• Time horizon
• Risk tolerance
• Broad portfolio balance
• Asset allocation
• modeled portfolio behavior
• Discretionary authority
Portfolios may be rebalanced as deemed necessary by AWM.
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B. Factors That Will Trigger a Non-Periodic Review of Client Accounts
On a more frequent basis, various triggering factors can occur that may necessitate
review of client accounts. These factors include, but are not limited to; significant
changes in the general price levels of the various securities markets and significant
additions to or withdrawals from a client's account. The client is encouraged to notify
AWM if changes occur in his/her personal financial situation that might adversely
affect his/her investment plan.
C. Content and Frequency of Regular Reports Provided to Clients
Each client will receive at least quarterly from the custodian, a written report that
details the client’s account including assets held and asset value which will come
from the custodian. AWM itself does not provide clients with reports.
Item 14: Client Referrals and Other Compensation
A. Economic Benefits Provided by Third Parties for Advice Rendered to
Clients (Includes Sales Awards or Other Prizes)
AWM has access to a variety of economic benefits, services, and products in
connection with AWM’s use of SEI’s investment adviser platform. The terms and
availability of these benefits vary among advisors on the SEI platform (including
AWM) depending on the business conducted with SEI and other factors. These
services generally help AWM conduct its advisory business, but each specific benefit
does not necessarily benefit each client.
Beyond access to SEI investment products, these include conferences, seminars and
other educational and networking activities, business entertainment, reimbursement
of travel and attendance expenses, research and other investment support services
(such as client proposal and other financial planning support), technical and
operational solutions (including the SEI Wealth Platform), marketing assistance
(including joint marketing designed to promote SEI’ investment products),
compliance services, human resources consulting, risk management/insurance
assistance, front office, middle office, back office and other administrative support
(including providing clerical staff to assist in the completion of required paperwork),
SEI attendance at client meetings, information technology services, continuity and
succession planning, access to financing and banking options, trust services,
portfolio reporting, automatic rebalancing, tax loss harvesting, waiver or payment of
certain fees (including paying account transfer fees or other charges that AWM or its
clients would incur when changing service providers), vendor discounts, discount
pricing on SEI services, and broader practice management consulting. These benefits
may be provided via SEI, its affiliates, or third parties and may be made available to
AWM at no fee, at a discounted fee, or via financial compensation provided by SEI.
15
Some of these offerings depend on AWM conducting a minimum amount or type of
current or expected future business with SEI, or having a minimum account size or
amount of assets under management with SEI or invested in SEI investment
products. Certain of these services or products, including those provided by or paid
for by SEI, may be used by AWM in connection with its general business activities,
in addition to supporting AWM’s interaction with SEI systems. The benefits,
services, products, or payments discussed herein may be significant to AWM and
create an incentive for the AWM to utilize SEI services or investment products for its
customers rather than other service providers or investment products. However,
AWM strives at all times to put the interests of its clients first, including when
selecting custodians or investment products for clients. AWM is independently
owned and operated; it is not affiliated with SEI.
B. Compensation to Non – Advisory Personnel for Client Referrals
AWM does not compensate non-advisory personnel (solicitors) for client referrals.
Item 15: Custody
When it deducts fees directly from client accounts at a selected custodian, AWM will be
deemed to have limited custody of client’s assets and must have written authorization
from the client to do so. Clients will receive all account statements from their custodian at
least quarterly, and they should carefully review those statements for accuracy.
Item 16: Investment Discretion
For those client accounts where AWM has discretionary authority, clients grant AWM
written discretionary authority over the management of their accounts. AWM's
discretionary authority includes the authority to select, allocate assets among, and make
changes to investment strategies and third-party investment managers available through
the SEI platform without obtaining prior approval from the client for each decision.
The third-party investment managers and investment strategies available through the SEI
platform are responsible for managing the underlying investments and making decisions
regarding the purchase and sale of securities within their respective strategies. AWM does
not generally select individual securities held within client portfolios.
AWM's discretionary authority is exercised consistent with each client's Investment Policy
Statement, investment objectives, risk tolerance, financial circumstances, and the terms of
the advisory agreement.
Details regarding AWM's discretionary authority and the scope of such authority are fully
disclosed to clients prior to establishing an advisory relationship. Discretionary authority
is granted through the execution of the investment advisory agreement and applicable
custodian account documentation.
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Item 17: Voting Client Securities (Proxy Voting)
AWM will not ask for, nor accept voting authority for client securities. Clients will receive
proxies directly from the issuer of the security or the custodian. Clients should direct all
proxy questions to the issuer of the security.
Item 18: Financial Information
A. Balance Sheet
AWM does not require nor solicit prepayment of more than $1,200 in fees per client,
six months or more in advance and therefore does not need to include a balance sheet
with this brochure.
B. Financial Conditions Reasonably Likely to Impair Ability to Meet
Contractual Commitments to Clients
Neither AWM nor its management have any financial conditions that are likely
to reasonably impair our ability to meet contractual commitments to clients.
C. Bankruptcy Petitions in Previous Ten Years
AWM has never been the subject of a bankruptcy petition in the last ten years.
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