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)

MinMaxMarginal 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 AssetsAnnual FeesAverage 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)

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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). 2 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 3 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 4 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. 5 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. 6 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 7 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. 8 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. 9 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. 10 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. 11 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. 14 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. 16 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. 17

Frequently Asked Questions