ABLE WEALTH MANAGEMENT LLC

Able Wealth Management LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Able Wealth Management LLC. If you have any questions about the contents of this brochure, please contact us at (212) 634-7842 or by email at: info@ablewealth.co. 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 Able Wealth Management LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Able Wealth Management LLC’s CRD number is: 298085. 185 Route 70, Ste 105 Toms River, NJ 08755 (212) 634-7842 info@ablewealth.com www.ablewealth.com Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 01/14/2026 i  Item 2: Material Changes There were no material changes in this brochure from the last annual updating amendment of Able Wealth Management LLC on 02/18/2025. Material changes relate to Able Wealth Management LLC’s policies, practices or conflicts of interest. 2  Item 3: Table of Contents Item 4: Advisory Business .............................................................................................................................................. 4 Item 5: Fees and Compensation ....................................................................................................................................... 9 Item 6: Performance-Based Fees and Side-By-Side Management ................................................................................ 12 Item 7: Types of Clients ................................................................................................................................................ 12 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ........................................................................... 13 Item 9: Disciplinary Information ................................................................................................................................... 16 Item 10: Other Financial Industry Activities and Affiliations ........................................................................................ 17 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading..................................... 18 Item 12: Brokerage Practices .......................................................................................................................................... 19 Item 13: Review of Accounts ......................................................................................................................................... 22 Item 14: Client Referrals and Other Compensation ....................................................................................................... 23 Item 15: Custody ............................................................................................................................................................ 23 Item 16: Investment Discretion ...................................................................................................................................... 23 Item 17: Voting Client Securities (Proxy Voting) .......................................................................................................... 24 Item 18: Financial Information ....................................................................................................................................... 24 3  Item 4: Advisory Business Description of the Advisory Firm Able Wealth Management LLC (hereinafter “AWML”) is a Limited Liability Company organized in the State of New Jersey. The firm was formed in July 2018, and the principal owners are Seth Philip Hodes and Yoel Kaplowitz. Types of Advisory Services Portfolio Management Services AWML provides ongoing portfolio management services tailored to each client’s unique goals, objectives, time horizon, and risk tolerance. As part of our personalized approach, AWML develops an Investment Policy Statement (IPS) for each client, outlining their financial circumstances, such as tax considerations, risk tolerance levels, and any client-directed preferences. This document serves as the foundation for our portfolio management strategy, which includes, but is not limited to, the following services: ● Investment Strategy: Designing a comprehensive investment approach aligned with the client’s objectives and financial situation. ● Personal Investment Policy: Crafting an individualized policy that defines the guidelines and principles for managing the client’s portfolio. ● Asset Allocation: Developing a diversified allocation plan across various asset classes to optimize risk-adjusted returns based on the client’s objectives. ● Asset Selection: Selecting specific securities or investments consistent with the client’s policy and strategy. ● Risk Tolerance Assessment: Evaluating and incorporating the client’s risk tolerance into the portfolio design to balance growth potential with comfort level. ● Regular Portfolio Monitoring: Continuously reviewing portfolio performance and making adjustments as needed to remain aligned with the client’s financial goals. AWML reviews each client’s current investments in relation to their IPS, including risk tolerance and time horizon considerations. To enhance responsiveness, AWML requests discretionary authority from clients, allowing the firm to select securities and execute transactions without obtaining prior client approval for each individual transaction. This authority is established to facilitate timely decision-making and efficient portfolio management. AWML is committed to ensuring that investment decisions are made in accordance with fiduciary duties, prioritizing client interests above all else. In doing so, AWML avoids investment or trading practices that might systematically advantage or disadvantage specific client portfolios. To maintain a fair and equitable approach, AWML’s policy is to seek balanced allocation of investment opportunities and transactions among clients over time, thereby avoiding preferential treatment. AWML consistently strives to allocate investment opportunities it deems appropriate and prudent on a fair and equitable basis across all client accounts over time. 4  Financial Planning We offer comprehensive financial planning services tailored to meet the unique needs and objectives of each client. These services may be integrated into our overall wealth management approach or provided as a standalone offering. Our financial planning process typically includes: ● Initial Discovery Meeting: To gather relevant financial information and discuss your current situation, key concerns, and long-term objectives. ● Review and Analysis: We conduct a detailed review of your financial situation and develop a comprehensive, written financial plan that may include investment planning, retirement planning, tax strategies, risk management, and more, based on your goals. ● Plan Presentation: We present specific recommendations and strategies for implementation, aligned with your objectives. ● Ongoing Monitoring and Review: We offer periodic reviews and updates to ensure the plan remains aligned with your evolving goals and any changes in external factors. While the implementation of the financial plan remains your decision, you may choose to engage Able Wealth Management to manage your investments as part of the plan’s implementation. If you do so, Able Wealth Management will receive compensation under our portfolio management fee schedule, which creates a potential conflict of interest, as we have a financial incentive for clients to implement recommendations through our investment management services. To address this, we are committed to making recommendations solely in your best interest, and you are under no obligation to implement the financial plan through Able Wealth Management. You are encouraged to consider all available options and may implement our recommendations with another provider if preferred. Further details regarding this potential conflict of interest are included in this brochure. Pension Consulting Services AWML provides consulting services to pension and other employee benefit plans, including but not limited to 401(k) plans. Our pension consulting services are customized to address the unique needs and goals of each plan and may include: ● Establishing Investment Objectives and Restrictions: Collaborating with plan sponsors to define clear investment objectives and any specific restrictions tailored to the needs and goals of the plan and its participants. ● Asset Class and Investment Option Guidance: Offering strategic guidance on various asset classes and investment options suitable for the plan’s objectives, considering factors such as diversification, risk tolerance, and participant demographics. ● Money Manager Recommendations: Recommending qualified money managers to manage plan assets in alignment with established objectives, leveraging our due diligence process to identify those best suited to achieve the plan’s goals. 5  ● Performance Monitoring and Manager Oversight: Continuously monitoring the performance of money managers and investment options, providing recommendations for adjustments as needed to ensure the plan remains on track toward its objectives. ● Recommendation of Additional Service Providers: Suggesting essential service providers, such as custodians, administrators, and broker-dealers, to support efficient plan operations and enhance participant services. ● Third-Party Administrator (TPA) Recommendation: Recommending an experienced TPA to assist with plan administration, compliance testing, recordkeeping, and other regulatory requirements, ensuring the plan remains compliant with applicable laws and regulations. ● Development of a Comprehensive Pension Consulting Plan: Creating a detailed, written pension consulting plan that outlines strategies, policies, and procedures for achieving the plan’s objectives, considering the demographics, time horizon, and risk tolerance of plan participants. These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. “Held Away Asset” Portfolio Management Services – Pontera Platform We offer an additional investment management service for “Held Away accounts,” such as 401(k), 403(b), HSA, and 529 plan accounts. These accounts are not opened at Charles Schwab or Fidelity. We use a third-party platform, Pontera, to leverage an Order Management System to implement asset allocation and opportunistic rebalancing strategies on behalf of clients. We regularly review the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other accounts, though using different tools as necessary. A link will be provided to Clients allowing them to connect account(s) to the platform. Once a client’s account is connected to the platform, we will review the current account allocations. When deemed necessary, we will rebalance the account considering the Client’s investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. The Pontera’s platform allows us to avoid having custody of Clients’ funds since we do not have direct access to Client log-in credentials. We are not affiliated with Pontera and receive no compensation from Pontera for using their platform. Pontera charges AWML an annual fee of 0.25% of the assets on their platform. Where requested by the client, our Portfolio Management Services may include ongoing discretionary investment management and monitoring with respect to certain held-away accounts (e.g., employer sponsored retirement accounts) identified by the client. In order to manage certain types of held away accounts, we will utilize a third-party platform provided to us by Pontera Solutions (respectively, the “Pontera Platform” and “Pontera”). The Pontera Platform allows us to avoid having custody of client funds and securities since we do not have direct access to client log-in credentials to affect trades. Where these services are requested, a link will be provided to the client allowing them to connect to the held away account(s) they desire AWML to manage via the Pontera Platform. Once a client’s account(s) is connected to the Pontera Platform, AWML will review the current account allocations. We will monitor the account on an ongoing basis and when deemed necessary 6  and appropriate, rebalance the linked account(s) in consideration of the client’s unique investment goals, needs, and limitations. Sub-Advisory Platform Sponsors AWML has entered into agreements with Betterment LLC and Altruist LLC (collectively “Sponsors”) to utilize their advisory platform technology. These Sponsors have developed a Platform (as defined below) for use by independent investment advisors such as AWML. The Platform is a proprietary automated investment management platform for use by independent investment advisors to offer their clients a customized portfolio of exchange traded funds, publicly traded equities, fixed income securities, closed end funds and mutual funds (collectively “Investments”). In connection with the Platform, the Sponsors provide AWML with technology and related trading and account management services. Sub-Advisor(s) AWML has conducted due diligence on certain independent registered investment advisors and enters into written sub-advisory agreements to provide Investment Advisory Services to a selected portion of AWML’ Client portfolios, as appropriate. AWML may also enter into additional written sub-advisory agreements with other third-party registered investment advisors, from time to time, as it deems appropriate and in the best interests of our Clients. AWML will monitor the selected sub-advisor(s) and may, from time to time and in its sole discretion, hire and/or replace any sub-advisor as part of our engagement to manage the Client’s portfolio(s) consistent with the Client’s objectives. AWML will ensure that, as appropriate, the Client receives a copy of the disclosure document (Form ADV, Part 2, or other disclosure document in lieu of Part 2) of any sub- advisor selected to manage all, or a portion of, a Client’s account assets Services Limited to Specific Types of Investments AWML provides investment advice tailored to each client’s specific objectives, focusing on a diversified approach that aligns with individual financial goals. Exchange-Traded Funds (ETFs) are AWML’s primary investment vehicle for both equity and fixed-income exposure within client portfolios. ETFs provide broad market exposure, sector-specific targeting, and cost efficiency through low expense ratios. Additionally, they offer liquidity and flexibility, allowing AWML to make efficient portfolio adjustments as market conditions evolve. By using ETFs, AWML aligns clients’ asset allocations with their individual investment objectives, balancing growth and income across various sectors and asset classes. Beyond ETFs, AWML may recommend other types of investments on a limited, case-by-case basis, depending on each client’s needs and investment objectives. These additional investment options include: ● Mutual Funds and Closed-End Funds: Used to provide diversified exposure across multiple asset classes, sectors, or geographic regions, mutual and closed-end funds offer an efficient way to spread risk across a broad investment base. ● Interval Funds: Interval funds, which provide limited liquidity with periodic redemption opportunities, may be recommended selectively based on a client’s individual needs and long-term goals. ● Fixed-Income Securities: While AWML primarily uses ETFs for fixed-income exposure, individual government and corporate bonds may occasionally be used to support income generation and enhance portfolio stability. 7  ● Structured Notes: Structured notes may be recommended on a limited basis when they align with specific client risk- return objectives. These are considered selectively based on the client’s risk tolerance and prevailing market conditions. ● Insurance Products, including Annuities: AWML may recommend insurance products, such as annuities, in scenarios where they align with a client’s broader financial planning needs, such as retirement income or estate planning. Annuities can provide income, tax deferral, or capital preservation benefits. ● Equities (Individual Stocks): Individual stocks are generally rarely used by AWML within client portfolios. They may be included in specific situations where a client requests an individual stock or transfers it in and wishes to retain the position. When incorporated, individual stock positions are limited to support diversification and reduce portfolio volatility. ● Alternatives: AWML may recommend alternative investments, including strategies like long/short equity, market- neutral, and managed futures, to offer additional diversification and reduce portfolio volatility. Alternative investments are considered only when they are suitable for the client’s goals and risk tolerance and are used sparingly. ● Real Assets: Real assets, such as commodities, infrastructure, and other tangible assets, may be selectively recommended for clients seeking inflation protection or diversification. Real assets come with unique risks, such as illiquidity and price volatility, and are incorporated only when they align with the client’s objectives. ● Sub-Advisors: In cases requiring specialized expertise, AWML may engage sub-advisors selectively to manage specific investment strategies or asset classes. Sub-advisors are used to enhance portfolio management where specialized knowledge is needed to meet client objectives. While AWML’s recommendations typically prioritize ETFs as the core investment vehicle due to their efficiency, diversification, and flexibility, other securities or strategies may be considered as needed to meet unique client goals or adapt to evolving market conditions. This approach allows AWML to deliver customized, client-centered advice while maintaining a diversified investment strategy that aligns with each client’s financial objectives. Client-Tailored Services and Client-Imposed Restrictions AWML 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). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent AWML from properly servicing the client account, or if the restrictions would require AWML to deviate from its standard suite of services, AWML reserves the right to end the relationship. 8  Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. AWML does not participate in wrap fee programs. Assets Under Management AWML has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $579,538,342 $0 December 2025 In addition, AWML provides consulting to approximately $138,159,389 in 401(k) plan assets. These services are provided on an Assets Under Advisement (“AUA”) basis. Item 5: Fees and Compensation Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees $0 - $500,000 1.25% $500,001 - $1,750,000 1.00% $1,750,001 - $5,000,000 0.75% $5,000,001 + 0.50% AWML uses an average of the daily balance in the client's account throughout the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. These fees are negotiable, and the fee schedule is outlined below. The final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of AWML's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 30 days' written notice. When calculating Assets Under Management (AUM) for billing purposes, we aggregate all accounts held by each Household on certain platforms to determine the applicable fee tier. Specifically, accounts held with Schwab, Fidelity, and Pontera are aggregated across these platforms to calculate the total AUM for the Household. For accounts held on other platforms, such as Altruist and Betterment, or in annuity products, each platform’s AUM is calculated independently. In these cases, the AUM for each respective platform or annuity product is 9  not aggregated with other platforms for billing purposes. This approach ensures that fees are applied consistently based on each platform’s total assets. Sub-Advisory Fees AWML may refer Clients to other investment managers to act as sub-advisors in its sole discretion, subject to the investment guidelines provided by AWML. The independent manager(s) will arrange for the execution of securities transactions for the accounts through brokers or dealers that they believe will provide best execution. All or a portion of the account transactions may be placed away from the AWML’s Custodian if the independent manager(s) believe this will result in best execution. The independent manager(s) advisory fee is payable, in addition to AWML fee, and is debited separately by the custodian or is debited by AWML and paid to the sub-advisor. All fee arrangements are fully disclosed to the client. Pension Consulting Services Fees The rate for pension consulting services is between 0.05% and 1.00% of the plan assets for which AWML is providing such consulting services. These fees are negotiable, and the fee schedule is outlined below. AWML uses an average of the daily balance in the client's account throughout the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the pension consulting fee is based. Total Assets Under Advisement Pension Consulting Fees $0 - $3,000,000 1.00% $3,000,000 - $8,000,000 0.75% $8,000,001 - $10,000,000 0.50% $10,000,001 - $15,000,000 0.25% $15,000,001 - $20,000,000 0.20% $20,000,001 - $60,000,000 0.15% $60,000,001 - $90,000,000 0.10% $90,000,001+ 0.05% Financial Planning Fees ● Fixed Fees: The negotiated fixed rate for creating client financial plans is between $500 and $20,000. ● Hourly Fees: The negotiated hourly fee for these services is between $100 and $500. Clients may terminate the agreement without penalty for a full refund of AWML’s fees within five business days of signing the Financial Planning Agreement. After that, clients may terminate the Financial Planning Agreement generally upon written notice. 10  Payment of Fees Payment of Portfolio Management Fees: Asset-based portfolio management fees are withdrawn directly from the client's accounts with the client's written authorization on a quarterly basis. Fees are paid in arrears. Payment of Pension Consulting Services Fees: Pension consulting fees are withdrawn directly from Plan Assets with the Plan’s Trustees’ written authorization. Fees are paid quarterly in arrears or paid via check depending on the Plan Trustees’ preference. Payment of Financial Planning Fees: Financial planning fees are payable via check or ACH transfer, according to the client’s preference. Fixed financial planning fees may be structured in several ways. Typically, 20% of the fee is due in advance, but not exceeding six months in advance, with the remaining balance due upon presentation of the completed financial plan. Clients may also elect to pay fixed fees on a monthly or quarterly schedule, as mutually agreed upon prior to signing the financial planning agreement. Hourly financial planning fees are paid in arrears, upon completion of the services rendered. The firm may, at its discretion, waive financial planning fees for clients who have at least $250,000 in assets under management (AUM) with the firm. Client Responsibility For Third-Party Fees Clients are responsible for any third-party fees incurred in connection with their investments, such as custodian fees, brokerage fees, mutual fund expenses, and transaction fees. These fees are separate and distinct from those charged by AWML for its advisory services. For additional information regarding broker-dealer and custodian fees, please refer to Item 12 of this brochure. Prepayment of Fees AWML may collect certain fees in advance and others in arrears, as specified in the relevant sections above. For fees paid in advance but not yet earned, refunds will be issued on a prorated basis, reflecting the portion of work completed at the time of termination. Refunds will be processed within fourteen days and returned to the client via check or deposited directly into the client’s account. Fixed fees collected in advance are prorated based on the amount of work completed by the termination date. Outside Compensation For the Sale of Securities to Clients AWML and its supervised persons do not accept any compensation, including asset-based sales charges or service fees, in connection with the sale of investment products such as mutual funds or other securities. This policy ensures that our advisory services remain free from conflicts of interest and are solely focused on serving 11  our clients’ best interests. Item 6: Performance-Based Fees and Side-By-Side Management AWML does not charge performance-based fees, nor does it charge fees based on a share of the capital gains or capital appreciation of client assets. All client fees are structured as asset-based or fixed fees, which are fully disclosed in the client’s advisory agreement. This structure supports our commitment to unbiased, client- centered advice and avoids any potential conflicts of interest associated with performance-based compensation. Item 7: Types of Clients AWML provides advisory services to a broad range of clients, including: ● Individuals and High-Net-Worth Individuals ● Pension and Profit-Sharing Plans ● Charitable Organizations AWML does not impose a minimum account size for its services, making our advisory offerings accessible to clients with diverse financial needs and goals. 12  Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss Methods of Analysis AWML uses several methods of analysis to guide its investment decisions, including Fundamental Analysis, Modern Portfolio Theory (MPT), and Factor Investing. These approaches are designed to align with clients’ financial goals and risk tolerance but carry inherent limitations and risks. Fundamental Analysis: Fundamental Analysis evaluates a company’s financial health, including financial statements, revenue trends, competitive positioning, and management quality, to determine intrinsic value. This method seeks to identify undervalued or overvalued securities. However, risks include the potential that the market may not recognize the intrinsic value, or that unforeseen external factors may negatively impact performance. Modern Portfolio Theory (MPT): MPT focuses on optimizing a portfolio’s expected return for a given risk level through asset class diversification. This approach relies on historical correlations, assuming they will hold over time. However, during market stress, correlations may increase, reducing the intended diversification benefits. Factor Investing: Factor investing targets specific characteristics, or “factors,” such as value, size, momentum, quality, and volatility, which have historically driven returns. While factors can offer risk-adjusted return potential, shifts in market behavior or prolonged underperformance of specific factors can impact outcomes and introduce additional portfolio risk. Investment Strategies AWML employs a range of investment strategies to suit clients’ needs, including Long-Term Trading and Asset Allocation strategies, each tailored to balance risk and reward. Each strategy type may involve specific risks and is subject to market conditions. Long-Term Trading: This strategy seeks to capture returns over an extended period, reducing exposure to short- term volatility. However, it introduces risks such as inflation, interest rate changes, and market downturns, as well as issuer-specific and liquidity risks. Long-term trading also exposes clients to broader economic cycles, regulatory changes, and technological disruptions. Asset Allocation: AWML uses asset allocation to balance risk and reward by adjusting the portfolio mix of asset classes like equities, fixed income, and cash equivalents. The goal is to diversify based on the client’s risk tolerance, financial goals, and investment horizon. AWML may blend one or more allocation strategies—such as Strategic, Dynamic, Tactical, and Core-Satellite Asset Allocation—to tailor portfolios, though reliance on historical correlations introduces some limitations. Custom Allocation: AWML offers customized asset allocation strategies designed to align with each client’s financial objectives, risk tolerance, liquidity needs, and tax considerations. In addition, AWML can incorporate client preferences, such as socially responsible investing (SRI) or environmental, social, and governance (ESG) 13  considerations. Allocations are reviewed periodically and adjusted as market conditions and client circumstances change. Asset Allocation Strategies: AWML customizes asset allocation strategies to match client goals and market conditions: ● Strategic Asset Allocation: A long-term approach with target allocations rebalanced periodically to maintain consistency. It avoids short-term timing but may lack responsiveness to changing economic conditions. ● Dynamic Asset Allocation: This approach adjusts portfolio weights based on current economic factors, such as inflation or interest rate changes, offering flexibility but possibly increasing costs and turnover. ● Tactical Asset Allocation: A more active strategy aimed at short-term gains by capitalizing on market trends. Tactical allocation involves higher short-term risks and may not align with all clients’ long-term objectives. ● Core-Satellite Asset Allocation: Combining a stable, diversified core with a more actively managed satellite portion, this strategy balances steady growth with flexibility, though it introduces additional transaction costs and risks. Use of Sub-Advisors: In certain cases, AWML may engage sub-advisors for complex strategies, particularly involving derivatives, private equity, or other specialized investments. Sub-advisors are selected based on their expertise in these areas and are monitored to ensure alignment with client goals. When using sub-advisors, clients may incur additional fees, which are fully disclosed prior to implementation. In cases involving margin accounts, the associated risks of margin calls and leverage will also be discussed. Rebalancing: To maintain target allocations, AWML periodically rebalances client portfolios. This process involves selling assets that have appreciated above their target levels and purchasing underweighted assets. Rebalancing ensures that portfolios remain aligned with clients’ risk-return profiles, but it may result in transaction costs and potential tax consequences. Liquidity Considerations: AWML assesses the liquidity needs of each client to ensure that portfolios can meet cash flow requirements. Investments in less liquid assets, such as certain real assets or alternative investments, are carefully considered based on the client’s overall liquidity needs and financial objectives, as liquidity constraints can become pronounced during market stress. Tax Efficiency: Where appropriate, AWML uses tax-efficient strategies, such as tax-loss harvesting and tax- advantaged vehicles (e.g., municipal bonds, retirement accounts), to maximize after-tax returns for clients. Tax efficiency is an essential consideration, especially for high-net-worth clients, and AWML regularly reviews portfolios to optimize for tax implications.. Material Risks Involved Risks of Loss Investing in securities involves a risk of loss that clients should be prepared to bear. AWML portfolios are designed to align with client objectives and risk tolerance, yet even diversified portfolios are subject to market, economic, and asset-specific risks that can impact performance. While diversification aims to manage risk, 14  there is no guarantee against potential losses. Past performance is not indicative of future results, and clients should consider their ability to bear risk over time. Risks of Specific Securities Utilized Clients should understand that investing in securities involves a material risk of loss. The securities listed below (with the exception of Treasury Inflation-Protected/Inflation-Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency, and each carries unique risks. Mutual Funds: Investing in mutual funds carries the risk of capital loss, meaning you may lose money. All mutual funds incur costs that reduce investment returns, and the funds may invest in a variety of asset types, including bond (fixed income) and stock (equity) funds. Risks associated with mutual funds include market risk, management risk, and liquidity risk, depending on the underlying investments. Interval Funds: Interval funds are closed-end funds not listed on an exchange, providing access to strategies often limited to institutional investors. These funds may invest in less liquid asset classes and are designed for long-term investors who do not need immediate access to their capital. Liquidity is limited as interval funds only offer repurchase of shares periodically (usually quarterly), as detailed in the fund’s prospectus. Due to their illiquid nature and complex strategies, interval funds carry heightened liquidity and market risk compared to mutual funds. Equity: Equity investments involve purchasing shares of stock, where the value of the investment can fluctuate based on company-specific factors, industry conditions, and broader economic trends. The primary risks include market risk, where prices can decline due to various factors, and company-specific risk, which can arise from poor management, competitive challenges, or regulatory changes. Dividends and capital gains are not guaranteed, and the value of equity securities may decrease. Fixed Income: Fixed income investments, such as corporate and government bonds, provide returns on a fixed schedule, but they carry risks such as interest rate risk, inflation risk, credit risk, and default risk. Rising interest rates general ly result in falling bond prices, especially for longer-term securities. Inflation risk erodes the purchasing power of bond interest payments, while credit and default risks arise if the issuer or counterparty is unable to meet its obligations. Fixed income securities also carry liquidity risk, especially in the case of structured products such as mortgage-backed securities. Foreign fixed income investments add currency risk and geopolitical risk to the general risks of bond investments. Exchange-Traded Funds (ETFs): ETFs are traded like stocks on exchanges and carry similar risks to both stocks and mutual funds. Investors in ETFs face market risk, where the value of the ETF may decline in line with the underlying assets. There is also liquidity risk, particularly in more complex or less widely traded ETFs. Additional concerns include the potential for conflicts of interest, increased product complexity, and inadequate regulatory compliance. In cases of extreme market conditions, ETFs may experience significant price discrepancies from their net asset value (NAV). Real Estate Funds (including REITs): Real estate funds and REITs carry risks specific to the real estate sector, which can experience fluctuations due to economic cycles, local market conditions, interest rates, and regulatory changes. The value of real estate investments may be affected by competition, capital expenditures, changing tax rates, or environmental legislation. Liquidity risks are also prevalent in this sector, as real estate markets can become illiquid during downturns. Annuities: Annuities are designed for long-term retirement income but can incur early withdrawal penalties, taxes, and surrender charges. Variable annuities, which invest in sub-accounts like mutual funds, carry market and investment risk. Fees associated with annuities may be high, and any guarantees are subject to the financial strength of the issuing insurance company. 15  Private Equity: Private equity funds invest in private companies and carry illiquidity risk, limited transparency, and potential capital calls, where additional funding may be required on short notice. Private equity investments are typically long-term and carry the potential for significant capital loss. Private Placements: Private placements are less regulated, illiquid investments with limited transparency, and resale restrictions. These factors, coupled with the possibility of substantial discounts if sold, make private placements a high- risk investment that may result in complete capital loss. Venture Capital Funds: Venture capital funds focus on early-stage companies, which are highly speculative and illiquid, with uncertain exit strategies. These investments carry a high risk of failure and can result in the total loss of invested capital. Derivative Instruments (Options and Futures): Options and futures involve leverage, where small price movements can lead to significant gains or losses. Derivatives require margin accounts and may lead to additional capital requirements if positions decline in value. Liquidity constraints and price volatility add further risk, and strategies like covered calls or protective puts may not always perform as anticipated. Structured Notes: Structured notes, linked to assets such as equities, commodities, or interest rates, are complex instruments that carry credit risk (issuer default), market risk, and liquidity risk. Their value is influenced by the performance of the underlying asset, and they may not be easily tradable. Alternative Strategy Funds (ETFs and Mutual Funds): These funds employ strategies like long/short equity, market neutral, and managed futures to enhance diversification. However, they involve unique risks, including strategy execution risk, liquidity risk, and complex implementation. For example, long/short funds may incur losses if market predictions are inaccurate, and managed futures can underperform in volatile markets. Real Assets: Investments in commodities, real estate, infrastructure, and natural resources provide diversification and inflation protection but carry risks such as price volatility, liquidity risk, and regulatory risks. Commodities are subject to market fluctuations and geopolitical factors, while real estate investments can be affected by local market conditions, interest rates, and zoning laws. Infrastructure and heavy equipment financing carry credit risk and default risk associated with borrowers or lessees. Each of these securities carries a unique set of risks. Clients should carefully consider their risk tolerance, liquidity needs, and investment time horizon when investing in any of these securities, as even a diversified portfolio cannot fully eliminate the risk of loss. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information Criminal or Civil Actions There are no criminal or civil actions to report. 16  Administrative Proceedings There are no administrative proceedings to report. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations Registration as a Broker/Dealer or Broker/Dealer Representative Neither AWML nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither AWML 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. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Yoel Kaplowitz is an independent licensed insurance agent and from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. AWML always acts in the client's best interest, including selling commissionable products to advisory clients. Clients are in no way required to utilize the services of any representative of AWML in connection with such individual's activities outside of AWML. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections AWML may direct clients to third-party investment advisers. AWML will be compensated via a fee share from the advisers to which it directs those clients. The fees shared will not exceed any limit imposed by any regulatory agency. This creates a conflict of interest in that AWML is incentivized to direct clients to third- party investment advisers that provide AWML with a larger fee split. AWML will always act in the best interests of the client, including when determining which third‑party investment adviser to recommend to 17  clients. AWML will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where AWML is recommending the adviser to clients. AWML is not affiliated with Pontera in any way and receives no compensation from Pontera in connection with our use of the Pontera Platform. Clients are advised that our management of accounts via the Pontera Platform is subject to the limitations and restrictions imposed by the underlying sponsor, issuer, and/or custodian of the client’s held-away assets. For example, our instructions to rebalance holdings within your held-away account through the Pontera Platform may not be implemented by the account sponsor, issuer, or custodian for up to one (1) business day or more following entry. We may also not be able to view real-time account value and holdings data over the Pontera Platform. Clients understand that our investment of the assets held within such accounts is limited to allocation of the client’s assets among the various investment options made available by the account sponsor, issuer, or custodian. Upon entering into an agreement for advisory services with us, clients authorize us to use unrelated third party service providers (including Pontera) to service their account, including billing and the deduction of fees from client accounts. Clients agree to allow us to share non-public, personal information with these unrelated third- party service providers for the purpose of administering and managing the clients’ accounts. We require unrelated third-party service providers to execute a confidentiality agreement and not share client information with any unauthorized person or entity. The use of unrelated third-party service providers will not cause the client to incur any additional fees. We pay unrelated third-party service providers (including Pontera) for services out of the total advisory fee charged to the client. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics AWML 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. AWML's Code of Ethics is free upon request to any client or prospective client. Recommendations Involving Material Financial Interests AWML does not recommend that clients buy or sell any security in which a related person to AWML or AWML has a material financial interest. 18  Investing Personal Money in the Same Securities as Clients From time to time, representatives of AWML may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of AWML to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting from the recommendations they provide to clients. Such transactions may create a conflict of interest. AWML will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of AWML may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of AWML to buy or sell securities before or after recommending securities to clients resulting in representatives profiting from the recommendations they provide to clients. Such transactions may create a conflict of interest; however, AWML will never engage in trading that operates to the client’s disadvantage if representatives of AWML buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on AWML’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. This means that AWML seeks a custodian/broker-dealer that will hold client assets and execute transactions on terms that are, overall, most advantageous when compared with other available providers and their services. AWML considers a range of factors, including but not limited to: ● Capability to execute, clear, and settle trades (buy and sell securities for your account) itself or to facilitate such services. ● Proficiency in facilitating timely transfers and payments to and from accounts. ● Availability of investment research and tools that assist us in making investment decisions. ● Competitiveness of the price of those services and willingness to negotiate the prices. [Clients will not necessarily pay the lowest commission or commission equivalent.] ● Quality of services. ● Reputation, financial strength, and stability. ● Prior service to us and our other clients. 19  MTG, LLC dba Betterment Securities (“Betterment Securities”), a SEC registered broker-dealer FINRA/SIPC member, will be the qualified custodian for client accounts using Betterment LLC and/or Betterment Institutional. AWML is independently owned and operated and is not affiliated with Betterment Securities. Clients will open an account with Betterment Securities by entering into an account agreement directly with them. While we do not open the account for you, we may assist you in doing so. Altruist Financial LLC (“Altruist Financial”), a SEC registered broker-dealer FINRA/SIPC, will be the qualified custodian for client accounts using Altruist’s platform. AWML is independently owned and operated and is not affiliated with Altruist Financial. Clients will open an account with Altruist Financial by entering into an account agreement directly with them. While we do not open the account for you, we may assist you in doing so. AWML generally recommends its clients to use Charles Schwab & Co Inc,. Member FINRA/SIPC Research and Other Soft Dollar Benefits While AWML has no formal soft dollars program in which soft dollars are used to pay for third party services, AWML may receive research, products, or other services from its broker/dealer in connection with client securities transactions (“soft dollar benefits”) consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended, and may consider these benefits in recommending brokers. There can be no assurance that any particular client will benefit from any particular soft dollar research or other benefits. AWML benefits by not having to produce or pay for the research, products, or services, and AWML will have an incentive to recommend a broker dealer based on receiving research or services. Clients should be aware that AWML’s acceptance of soft dollar benefits may result in higher commissions charged to the client. Brokerage and Custody Costs - For client accounts that Betterment Securities maintains, Betterment Securities generally does not charge separately for custody services. It is instead compensated as part of the Betterment Institutional platform fee, which is a percentage of the dollar amount of assets in the account in lieu of commissions. AWML has determined that having Betterment Securities execute trades is consistent with its duty to seek “best execution” of trades (see above). Services Available Via Betterment Institutional - Betterment Securities serves as broker‑dealer to Betterment Institutional, an investment and advice platform serving independent investment advisory firms. Betterment Institutional also offers available various support services, which may not be available to its retail customers. Some of those services help AWML manage or administer client accounts, while others help us manage and grow our business. Betterment Institutional’s support services are generally available on an unsolicited basis (AWML does not have to request these services) and at no additional charge to AWML. The following is a more detailed description of Betterment Institutional’s support services: Services That Benefit The Client. Betterment Institutional includes access to a range of investment products, execution of securities transactions, and custody of client assets through Betterment Securities. Betterment Securities’ services described in this paragraph generally benefit clients and their accounts. 20  Services That May Not Directly Benefit Clients. Betterment Institutional also makes available to AWML other products and services that benefit AWML but may not directly benefit the client or client accounts. These products and services assist AWML in managing and administering client accounts, such as software and technology that may: ● Assist with back-office functions, recordkeeping, and client reporting of our accounts. ● Provide access to client account data (such as duplicate trade confirmations and account statements). ● Provide pricing and other market data. ● Assist with back-office functions, recordkeeping, and client reporting. Services That Generally Benefit Only Us. By using Betterment Institutional, we will be offered other services intended to help us manage and further develop our business enterprise. These services include: ● Educational conferences and events. ● Consulting on technology, compliance, legal, and business needs. ● Publications and conferences on practice management and business succession. Our Interest In Betterment Securities Services. The availability of these services from Betterment Institutional benefits AWML because we do not have to produce or purchase them. In addition, AWML does not have to pay an additional fee for Betterment Securities’ services, although these services may be contingent upon AWML committing a certain amount of assets to Betterment Securities for custody. AWML has an incentive to have clients maintain their accounts with Betterment Securities based on AWML’s interest in receiving Betterment Institutional and Betterment Securities’ services that benefit our business rather than based on clients’ interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. However, the availability to us of Betterment Institutional’ s and Betterment Securities’ products and services is not based on AWML giving particular investment advice, such as buying particular securities for its clients. Moreover, AWML believes that the use of Betterment Securities as custodian and broker-dealer is in the clients’ best interests and consistent with AWML’s fiduciary duty. AWML’s selection of Betterment Securities is primarily supported by the scope, quality, and price of services (described above) rather than Betterment Institutional and Betterment Securities’ services that benefit AWML directly. Brokerage for Client Referrals AWML receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. Clients Directing Which Broker/Dealer/Custodian to Use AWML will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. 21  Aggregating (Block) Trading for Multiple Client Accounts If AWML buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, AWML would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. AWML would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). Item 13: Review of Accounts Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for AWML's advisory services provided on an ongoing basis are reviewed at least Quarterly by Seth P Hodes, Co-Owner, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at AWML are assigned to this reviewer. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Seth P Hodes, Co-Owner. Financial planning clients are provided with a one-time financial plan concerning their financial situation. After the presentation of the plan, there are no further reports. Clients may request additional plans or reports for a fee. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in a client’s financial situations (such as retirement, termination of employment, physical move, or inheritance). With respect to financial plans, AWML’s services will generally conclude upon delivery of the financial plan. Content and Frequency of Regular Reports Provided to Clients Each client of AWML's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. Each financial planning client will receive the financial plan upon completion. 22  Item 14: Client Referrals and Other Compensation Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) AWML will receive a non-economic benefit from Betterment Institutional and Betterment Securities in the form of the support products and services it makes available to AWML (and other independent investment advisors whose clients maintain their accounts at Betterment Securities). These products and services, how they benefit AWML, and the related conflicts of interest are described above - see Item 12. The availability of Betterment Institutional and Betterment Securities’ products and services to AWML is not based on AWML giving particular investment advice, such as buying particular securities for its clients. Compensation to Non–Advisory Personnel for Client Referrals AWML does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, AWML 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 and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Under government regulations, we are deemed to have custody of your assets if, for example, you authorize us to instruct Betterment Securities to deduct our advisory fees directly from your account. Betterment Securities maintains actual custody of your assets. Your statements will be available for you to review on the activity section of your Betterment for Advisors account portal. You will also receive account statements directly from Betterment Securities at least quarterly at www.bettermentsecurities.com. You should carefully review those statements promptly. Item 16: Investment Discretion AWML provides discretionary and non-discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, AWML generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. 23  Item 17: Voting Client Securities (Proxy Voting) AWML 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 Balance Sheet AWML neither requires nor solicits prepayment of more than $500 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither AWML nor its management has any financial condition that is likely to reasonably impair AWML’s ability to meet contractual commitments to clients. Bankruptcy Petitions in the Previous Ten Years AWML has not been the subject of a bankruptcy petition in the last ten years. 24