Overview
- Headquarters
- Toms River, NJ
- Average Client Assets
- $2.0 million
- SEC CRD Number
- 298085
Fee Structure
Primary Fee Schedule (ADV PART 2A-ABLE WEALTH MANAGEMENT LLC)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 1.25% |
| $500,001 | $1,750,000 | 1.00% |
| $1,750,001 | $5,000,000 | 0.75% |
| $5,000,001 | and above | 0.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $11,250 | 1.12% |
| $5 million | $43,125 | 0.86% |
| $10 million | $68,125 | 0.68% |
| $50 million | $268,125 | 0.54% |
| $100 million | $518,125 | 0.52% |
Clients
- HNW Share of Firm Assets
- 65.89%
- Total Client Accounts
- 2,109
- Discretionary Accounts
- 2,109
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting
Regulatory Filings
Additional Brochure: ADV PART 2A-ABLE WEALTH MANAGEMENT LLC (2026-03-10)
View Document Text
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.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 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: 03/10/2026
Item 2: Material Changes
The material changes in this brochure since Able Wealth Management LLC’s (“AWML”) last annual updating amendment
dated February 18, 2025, are described below. Material changes include changes to AWML’s advisory services,
business practices, fee arrangements, and conflicts of interest.
● Expanded advisory services. AWML expanded its advisory services to include Portfolio Management for Business or
Institutional Clients and now offers Educational Seminars and Workshops to prospective and current clients. Please refer
to Item 4 for additional information.
● New subadvisor relationship – SyntheticFi LLC. AWML engaged SyntheticFi LLC as a subadvisor to provide securities-
backed borrowing strategies utilizing box spreads for clients who elect this service. Please refer to Items 4, 8, and 10 for
more information, including related risks and conflicts.
● New subadvisor relationship – Brooklyn Investment Group, LLC. AWML engaged Brooklyn Investment Group, LLC as a
subadvisor to provide direct indexing, custom indexing, and tax-advantaged long/short equity strategies. Brooklyn provides
discretionary portfolio management services utilizing proprietary technology and charges separate subadvisory fees based
on gross notional value. Please refer to Items 4, 5, and 10.
● New subadvisor relationship – Quantinno Capital Management LP (DEALS strategies). AWML engaged Quantinno Capital
Management LP as a subadvisor to provide tax-advantaged direct equity strategies (DEALS), including Core, Overlay, and
Exchange strategies utilizing systematic tax-loss harvesting and leverage. Quantinno charges a separate subadvisory fee
of 0.45% annually. Please refer to Items 4, 5, and 10.
● Potential recommendation of Quantinno private fund. AWML may recommend that suitable clients invest in the Quantinno
Fundamental Arbitrage Fund LP, a market-neutral hedge fund also managed by Quantinno Capital Management LP.
Please refer to Items 4, 5, and 10.
● Structured note due diligence support – Ancorato. AWML may utilize structured note selection and due diligence services
from Ancorato (operated by Legacy Solutions LLC) for clients investing in structured notes. Please refer to Item 4.
● Vestmark Advisory Solutions (VAS) platform relationship. AWML entered into an arrangement with Vestmark Advisory
Solutions, Inc. (“VAS”) to provide sub-advisory and technology services, including access to third-party model portfolios,
investment strategies, and discretionary trading services through the Vestmark Manager Marketplace. Please refer to
Items 4, 5, and 12.
● Proprietary fund structures with Glide / AQR. AWML established proprietary fund structures in partnership with Glide
Platform LLC. This includes (i) a proprietary feeder fund structure (the AWM Series) that invests in the AQR TA Delphi
Plus Fund, a tax-aware alternative investment strategy managed by AQR Capital Management II, LLC, and (ii) an
arrangement under which AWML serves as Series Advisor to the AQR Opportunity Fund, a designated series of Glide
Direct Series, LLC. In addition, AWML may recommend that suitable clients invest directly in the AQR TA Delphi Plus
Fund. Please refer to Items 4, 5, and 10 for information regarding these structures, fees, and related conflicts.
● Enhanced alternative investment disclosures. AWML enhanced its disclosures regarding alternative investments and fee
structures, including private credit, which are described in Item 8.
● Updated fee schedule and planning fees. AWML introduced a new service tier, “Level 2: Comprehensive Wealth
Management,” with a flat 1.00% advisory fee, and updated its financial planning fee ranges. Please refer to Item 5.
● BlackRock arrangements and related conflicts. AWML entered into arrangements with BlackRock, Inc., including (i)
eligibility to receive portfolio management software (Aladdin Wealth) contingent upon maintaining a threshold of client
assets in BlackRock funds, and (ii) a non-fiduciary model provider relationship with BlackRock Custom Model Solutions.
These arrangements create material conflicts of interest. Please refer to Items 10, 12, and 14.
● Use of Generative Artificial Intelligence. AWML enhanced its disclosures regarding the firm’s use of approved Generative
Artificial Intelligence tools for internal business functions, as well as related controls and review practices. Please refer to
Item 8.
● Proxy voting clarification; supervised person disclosure; soft dollar clarification. AWML clarified that it does not vote
proxies, although certain third-party subadvisors may vote proxies for assets they manage, as described in Item 17. AWML
also disclosed that supervised person Simcha Goldberg is an independent licensed insurance agent, as described in Item
10. Finally, AWML clarified in Item 12 that it does not participate in “soft dollar” arrangements and described economic
benefits received from custodians and platform providers.
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
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.
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.
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.
Portfolio Management for Business or Institutional Clients
AWML provides portfolio management services to corporations, businesses, and other institutional clients to help
them manage their liquid assets, such as corporate cash reserves or other balance sheet assets. The services
provided are similar to our portfolio management services for individuals and are based on the client's stated
business objectives, cash flow needs, risk tolerance, and time horizon. An Investment Policy Statement (IPS) will
be developed to outline the specific goals and constraints for the assets.
Educational Seminars and Workshops
AWML may offer educational seminars or workshops to prospective clients, current clients, or community
members on various financial topics. These seminars are for general educational purposes only and do not
constitute personalized investment advice or a recommendation for any specific product or strategy. All seminar
materials are considered "Advertisements" under SEC Rule 206(4)-1. Attendees may be offered the opportunity to
schedule a follow-up consultation to discuss their personal financial situation and our advisory services. This
presents a conflict of interest, as the seminars are a marketing activity designed to solicit new advisory clients for
the firm.
AWML Series Advisor – AQR Opportunity Fund (Glide Direct Series, LLC)
AWML serves as the Series Advisor to the AQR Opportunity Fund, a designated series of Glide Direct Series, LLC
(the “AQR Opportunity Fund”). AWML may recommend investments in the AQR Opportunity Fund to those clients
for which an investment in the fund is suitable.
Held-Away Account Portfolio Management (Pontera Platform)
AWML also offers discretionary portfolio management services with respect to certain “held-away” accounts (for
example, certain employer-sponsored retirement plan accounts such as 401(k) and 403(b) accounts, and certain
HSA and 529 plan accounts) that are maintained away from our primary custodians, where requested by the
client. In order to provide these services, AWML utilizes a third-party platform provided by Pontera Solutions, Inc.
(“Pontera”), which allows clients to connect certain held-away accounts to the Pontera platform via a link provided
by AWML. Once a client’s held-away account(s) is connected, AWML will review the available investment options
and the account’s current allocation and, as deemed necessary and appropriate, implement and rebalance
allocations consistent with the client’s investment objectives and risk tolerance. AWML monitors held-away
account(s) managed through the Pontera platform on an ongoing basis and reviews such accounts at least
quarterly.
AWML is not affiliated with Pontera and does not receive compensation from Pontera in connection with AWML’s
use of the platform. Pontera charges AWML an annual fee currently equal to **0.25%** of the assets maintained
on the Pontera platform. The Pontera platform is designed to permit AWML to provide these services without
obtaining direct access to client login credentials.
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
Third-Party Model Portfolios (Non-Fiduciary)
AWML may utilize non-fiduciary, third-party model providers, such as BlackRock Custom Model Solutions (CMS),
to design and construct custom model portfolios. These providers act as technology and content vendors,
providing AWML with model allocations, trade rationales, and other reports.
Unlike a subadvisor, these model providers do not have investment discretion over any client account and are not
fiduciaries to AWML's clients. AWML's Investment Committee reviews these models, and our advisors retain full
fiduciary responsibility and discretion for determining if a model is suitable for a client and for implementing all
trade orders
Vestmark Advisory Solutions (VAS) Platform
We have entered into an agreement with Vestmark Advisory Solutions, Inc. ("VAS") to provide sub-advisory and
technology services to our firm. Through the Vestmark Manager Marketplace ("VMM"), VAS provides us with
access to third-party model portfolios, investment strategies, and discretionary trading services.
For accounts managed through this platform, VAS (or a third-party manager selected by us) acts as a sub-advisor
with discretionary authority to invest and reinvest assets, rebalance portfolios, and execute trades in accordance
with the strategy selected by Able Wealth Management. While VAS manages the day-to-day trading and
rebalancing of these designated assets, Able Wealth Management retains the primary client relationship and is
responsible for determining the suitability of the selected strategies for your financial situation.
SyntheticFi LLC - Securities-Backed Borrowing Subadvisor
AWML has engaged SyntheticFi LLC, an SEC-registered investment adviser, to provide subadvisory services for
clients who elect to utilize securities-backed borrowing strategies using option-based synthetic loan contracts (box
spreads).
SyntheticFi charges a separate subadvisory fee of 0.20% annually (maximum $2,400 per year) based on the
managed synthetic loan size, which is billed directly to participating client accounts monthly in arrears via email
invoice. This fee is in addition to AWML's standard advisory fee. Clients whose managed synthetic loan size is
less than $50,000 are not charged this fee.
AWML retains full responsibility for determining the initial and ongoing suitability of this strategy for each client and
for all client communications. SyntheticFi facilitates the execution and trading of the synthetic loan contracts based
on parameters selected by AWML. Clients utilizing this service will receive SyntheticFi's Form ADV Part 2A, Form
CRS, and other required disclosure documents at the time of engagement.
Brooklyn Investment Group, LLC - Direct Indexing and Tax-Loss Harvesting Subadvisor
AWML has engaged Brooklyn Investment Group, LLC ("Brooklyn" or "BKLN"), an SEC-registered investment
adviser to provide subadvisory services for clients who elect to utilize direct indexing, custom indexing, and tax-
advantaged long/short equity strategies.
Brooklyn provides discretionary investment advisory services utilizing proprietary technology including artificial
intelligence-powered portfolio construction, algorithmic rebalancing, and systematic tax-loss harvesting
capabilities. Brooklyn is authorized to apply account management processes utilizing large language models and
machine learning-based decision making to client accounts.
Brooklyn charges a separate subadvisory fee based on the gross notional value of assets managed, which is
billed monthly in arrears and debited directly from client accounts. This fee is in addition to AWML's standard
advisory fee. Fee schedules vary by strategy:
● Tax-Advantaged Equity Only: 0.17% (17 basis points) annually. An additional 0.03% (3 basis points) applies if premium
indices are used.
● Tax-Advantaged Balanced Strategy: 0.20% (20 basis points) annually.
● Tax-Advantaged Long/Short Equity Strategy: 0.17% applied to gross notional value (e.g., a 130% long / 30% short strategy
would result in a fee of 0.272% or 27.2 basis points annually).
AWML retains full responsibility for determining the initial and ongoing suitability of Brooklyn's strategies for each
client. Brooklyn provides discretionary portfolio management, trade execution, and proxy voting services based on
Investment Guidelines provided by AWML. Clients utilizing this service will receive Brooklyn's Form ADV Part 2A
and other required disclosure documents at the time of engagement.
Quantinno Capital Management LP - DEALS Tax-Advantaged Direct Equity Strategies
AWML has engaged Quantinno Capital Management LP ("Quantinno"), an SEC-registered investment adviser, to
provide discretionary subadvisory services for clients who elect to utilize Quantinno's DEALS (Direct Equity and
Loss Strategies) tax-advantaged investment strategies.
Quantinno offers three primary DEALS strategies:
● DEALS Core: Seeks broad equity market exposure while generating significant tax benefits through systematic tax-loss
harvesting. Typically employs leverage (e.g., 130% long / 30% short positions) using hundreds of individual stocks. For
accounts funded with securities, Quantinno seeks to reduce initial tracking error relative to the benchmark.
● DEALS Overlay: Seeks positive total return with significant tax benefits using client-contributed collateral. Typically targets
30% long / 30% short exposure using hundreds of individual stocks.
● DEALS Exchange: Seeks tax-efficient transition of concentrated equity positions into a diversified portfolio over time.
Typically employs leverage (e.g., 130% long / 30% short positions) using hundreds of individual stocks.
Quantinno charges a separate subadvisory fee of 0.45% annually based on the market value of assets managed,
which is billed quarterly in advance and debited directly from client accounts. This fee is in addition to AWML's
standard advisory fee.
Quantinno has full discretionary authority over the designated assets, including the authority to buy, sell, or
otherwise effect transactions; select brokers or dealers; and manage cash balances within the account. AWML
retains full responsibility for determining the initial and ongoing suitability of Quantinno's DEALS strategies for
each client.
Quantinno does not vote proxies. Clients retain full responsibility for voting proxies and will receive proxy materials
directly from the custodian.
Important Risk Disclosures: Quantinno's DEALS strategies involve specific and potentially heightened risks,
including market risk, idiosyncratic risk (company-specific factors), short-sale risk (potential for unlimited losses if
shorted stocks appreciate significantly), borrow risk (risk of needing to cover short positions at unfavorable prices),
leverage risk (magnified gains and losses), and borrow rate risk (increased costs to borrow securities for shorting).
Tax benefits generated through loss harvesting may represent tax deferral rather than permanent tax savings.
Clients should consult their tax advisor regarding these strategies.
Clients utilizing this service will receive Quantinno's Form ADV Part 2A, Form CRS, and other required disclosure
documents at the time of engagement.
Quantinno Capital Management LP - Market-Neutral Alternative Investment Subadvisor
AWML may recommend that suitable clients invest in the Quantinno Fundamental Arbitrage Fund LP, a private
pooled investment vehicle managed by Quantinno Capital Management LP ("Quantinno"), an SEC-registered
investment adviser. Quantinno employs a systematic market-neutral equity strategy using over-the-counter equity
swaps with targeted gross exposure of 400-600%.
The Fund charges a management fee of 1.5% annually and a performance-based incentive fee of 20% of net
profits (subject to a high-water mark), in addition to AWML's standard advisory fee. The Fund offers monthly
liquidity with 30 days' notice and has a minimum investment of $1,000,000 (which may be waived at the fund
manager's discretion).
AWML acts as the primary investment adviser to the client and is responsible for determining the suitability of an
investment in the Quantinno Fund based on the client's investment objectives, risk tolerance, liquidity needs, and
overall portfolio construction. Quantinno has full discretionary authority over the Fund's portfolio management.
Clients will receive the Fund's offering memorandum, subscription documents, and Quantinno's Form ADV Part
2A prior to investment.
Structured Note Selection Services
For clients investing in structured notes, AWML may utilize selection and due diligence services from Ancorato
(operated by Legacy Solutions LLC, "Ancorato"), an SEC-registered investment adviser. Ancorato provides
recommendations on structured note strategies, issuer analysis, payout structure evaluation, and ongoing
monitoring of structured note investments.
AWML retains full discretionary authority over all investment decisions and compensates Ancorato directly from
AWML's advisory fee. Clients do not pay separate fees to Ancorato for these services. AWML is responsible for
determining the suitability of structured note investments for each client and for all client communications.
AWML Proprietary Feeder Fund - AQR TA Delphi Plus Investment
AWML has established a proprietary feeder fund structure (the "AWM Series" or "Feeder Fund") in partnership
with Glide Platform LLC ("Glide"), a Delaware-based private fund administration platform. The Feeder Fund is
structured as a segregated series within a Series LLC administered by Glide.
AWML acts as the Series Advisor to the Feeder Fund and makes all investment decisions on behalf of the Feeder
Fund. The Feeder Fund's sole investment objective is to pool client capital and invest 100% of its assets in the
AQR TA Delphi Plus Fund (the "Underlying Fund"), a private investment fund managed by AQR Capital
Management II, LLC ("AQR"), an SEC-registered investment adviser. AQR is not affiliated with AWML or Glide.
The AQR TA Delphi Plus Fund employs a tax-aware alternative investment strategy combining Defensive Long-
Short Equity (approximately 70% of risk) with Trend Following strategies (approximately 30% of risk). The fund is
designed for qualified purchasers seeking diversified, tax-efficient returns with low correlation to traditional equity
markets.
Structure and Roles:
●
AWML's Role: Acts as Series Advisor to the Feeder Fund with full discretionary authority over the decision to invest in
and maintain the investment in the Underlying Fund. Responsible for initial and ongoing due diligence of AQR and the
Underlying Fund. Determines suitability of the Feeder Fund investment for each client. Monitors performance and
conducts ongoing suitability reviews.
● Glide's Role: Acts as Administrator and Operator of the Series LLC. Handles subscriptions, redemptions, investor
communications, NAV calculations, capital calls/distributions, coordinates with fund auditor, prepares annual audited
financial statements, and issues Schedule K-1 tax forms.
●
AQR's Role: Acts as investment manager of the Underlying Fund with full discretionary authority over all investment
decisions, trade execution, and portfolio management operations of the Underlying Fund.
Fees and Expenses (Layered Structure): Investments in the Feeder Fund are subject to multiple layers of fees:
● Glide Administration Fee: Approximately 0.35% - 0.60% annually
●
●
AQR Management Fee: 2.00% annually (charged by the Underlying Fund)
AQR Performance Fee: 17.5% - 20% of net profits over a Treasury Bill hurdle rate, subject to high-water mark
(charged by the Underlying Fund)
●
AWML Advisory Fee: AWML's standard advisory fee continues to apply to assets invested in the Feeder Fund
Clients should be aware that the total annual base fees for this investment structure range from approximately
3.35% to 3.85% annually (excluding performance fees), which is significantly higher than traditional mutual funds
or ETFs.
Investor Qualification and Liquidity: Investment in the Feeder Fund requires qualification as a Qualified Purchaser
(generally $5,000,000+ in investments for individuals) under Section 3(c)(7) of the Investment Company Act. The
investment is subject to a 1-year lock-up period with no redemptions permitted during the first 12 months. After the
lock-up expires, redemptions are available quarterly with 75 days' prior written notice. The Feeder Fund
Administrator and/or Underlying Fund Manager reserve the right to suspend, limit, or gate redemptions under
extraordinary circumstances.
Clients will receive the Feeder Fund's offering documents (Series Advisory Agreement, Portfolio Supplement,
Subscription Agreement), the AQR TA Delphi Plus Fund's offering memorandum, and AQR's Form ADV Part 2A
prior to investment. Clients will receive annual audited financial statements and Schedule K-1 tax forms (typically
by March 15, subject to extension).
AQR TA Delphi Plus Fund - Direct Investment Option
In addition to the feeder fund structure described above, AWML may also recommend that suitable clients invest
directly into the AQR TA Delphi Plus Fund. For direct investments, the client enters into a direct subscription
agreement with AQR and becomes a limited liability company member of the Fund.
AWML's Role: AWML is responsible for (i) conducting initial and ongoing due diligence of the Fund and AQR; (ii)
determining that a direct investment in the Fund is suitable for the client's overall investment strategy; (iii) including
the Fund's value in AWML's periodic client reports; and (iv) providing ongoing advisory services. AWML does not
have discretionary authority over the Fund's investment decisions—AQR retains full discretionary authority over all
portfolio management, trade execution, and operations.
Fees and Expenses (Two-Layer Structure): Direct investments in the AQR TA Delphi Plus Fund are subject to a
two-layer fee structure:
1. AWML Advisory Fee: The market value of the client's investment in the Fund is included in Assets Under Management for
calculating AWML's advisory fee under the client's Advisory Agreement
2. AQR Fund-Level Fees: Vary by share class and are deducted from the Fund's assets:
○ Class A: Management fee of 1.75% annually + performance fee of 20% of net profits over Treasury Bill hurdle
(subject to high-water mark). Monthly liquidity with 30 days' notice.
○ Class B: Management fee of 2.00% annually + performance fee of 17.5% of net profits over Treasury Bill hurdle
(subject to high-water mark). Quarterly liquidity with 30 days' notice, subject to 1-year lock-up.
Investor Qualification and Liquidity: Direct investment in the Fund requires qualification as a Qualified Purchaser
(generally $5,000,000+ in investments for individuals). Class A shares have no initial lock-up period and permit
monthly redemptions with 30 days' prior written notice. Class B shares are subject to a 1-year lock-up period and
permit quarterly redemptions with 30 days' prior written notice after the lock-up expires. The Fund Manager
reserves the right to suspend, limit, or gate redemptions under extraordinary circumstances.
Clients will receive the Fund's Private Placement Memorandum, Limited Liability Company Agreement,
Subscription Agreement, and AQR's Form ADV Part 2A prior to investment. Clients will receive annual audited
financial statements and Schedule K-1 tax forms for tax reporting purposes.
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.
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.
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%
Comprehensive Wealth Management Fees
Clients may also select our "Level 2: Comprehensive Wealth Management" service. The advisory fee for this
service is a flat 1.00% on all assets under management. This service is designed for clients seeking holistic
coordination across multiple areas of their financial life, such as advanced estate planning, complex tax planning,
and business succession planning. Clients should be aware that depending on their total Assets Under
Management, the flat 1.00% fee for Comprehensive Wealth Management may result in a higher total advisory fee
than the tiered schedule for Investment Portfolio Management Services. Our advisors will conduct a suitability
analysis and document the rationale for the selected service level.
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 not
aggregated with other platforms for billing purposes. This approach ensures that fees are applied consistently
based on each platform’s total assets.
AQR Opportunity Fund, a designated series of Glide Direct Series, LLC Fees
AWML serves as the Series Advisor to the AQR Opportunity Fund, a designated series of Glide Direct Series,
LLC. The management fee for investing in this fund is 1% of the assets under management within the fund. For
assets invested in the AQR Opportunity Fund, the 1% management fee is inclusive of AWML’s advisory services.
The standard tiered advisory fee schedule listed above will not be applied to assets maintained within this specific
fund.
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.
Vestmark Platform and Sub-Advisory Fees
Unlike other sub-advisory arrangements described above where a separate fee may be charged to your account,
Able Wealth Management absorbs the sub-advisory and platform fees associated with Vestmark Advisory
Solutions. We pay VAS directly from our own advisory fees. Therefore, clients whose assets are managed through
the Vestmark platform do not incur an additional investment management fee for these services beyond Able
Wealth Management’s standard advisory fee listed above.
Note on Transaction Costs: While we pay the management fees for VAS, your account may still be responsible for
standard transaction costs, custodial fees, or commissions associated with trade execution, including those
resulting from "step-out" trades where VAS may execute transactions through a broker-dealer other than your
primary custodian to seek best execution.
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 $2,500 and $100,000.
● Hourly Fees: The negotiated hourly fee for these services is between $250 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.
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 AQR Opportunity Fund Fees:
Management fees for investments in the AQR Opportunity fund 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
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 investment advisory services to a broad range of clients, including:
● Individuals, including 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.
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.
Use of Generative Artificial Intelligence
AWML may use approved Generative Artificial Intelligence (AI) platforms to assist with internal business functions.
These tools may be used to help summarize economic reports, analyze public data, or draft initial drafts of internal
memos or client communications.
The firm and its supervised persons remain fully liable for all outputs. AI is not used to generate or deliver final,
automated investment advice. In accordance with our "Human-in-the-Loop" policy, all AI-generated output is
treated as a first draft and must be meticulously reviewed, fact-checked, and approved for accuracy and
completeness by a qualified supervised person before being saved as a firm record or communicated to a client.
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) 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.
Risks of Securities-Backed Borrowing and Box Spreads (Utilizing SyntheticFi LLC as Subadvisor)
For clients who elect to utilize securities-backed borrowing services provided by our subadvisor SyntheticFi LLC,
this program involves complex derivative instruments (box spreads) and exposes you to significant risks,
including:
● Margin & Collateral Risk: The strategy requires a margin account. Your portfolio assets serve as collateral. A decline in
your collateral's value could trigger a margin call, which may force the liquidation of your securities at an unfavorable time
and potentially cause losses and adverse tax consequences.
● Strategy & Execution Risk: This is a sophisticated options strategy. Poor market liquidity, improper execution of the
strategy's four "legs," or an unexpected early assignment of an options contract could cause the strategy to fail or result in
significant, unintended costs.
● Complex Tax Implications: The cost of borrowing is not treated as traditional loan interest. It is generally treated as a
Section 1256 capital loss (60% long-term / 40% short-term). This treatment is complex and may not be suitable for your tax
situation. We do not provide tax advice; you must consult your tax advisor to fully understand the tax consequences.
Alternative Investments and Fee Structures (Including Private Credit)
AWML may recommend alternative investments, including private credit funds, hedge funds, and other pooled
investment vehicles, to clients for whom such investments are suitable. Clients should be aware that these
investments typically involve significantly higher fees and more complex fee structures than traditional mutual
funds or ETFs. Unlike traditional funds where fees are assessed on net assets, management fees for certain
alternative investments are often calculated on gross assets, which includes assets purchased with borrowed
funds (leverage). This calculation method results in an effective fee rate on the client's invested equity that is
higher than the stated management fee percentage. Furthermore, many alternative funds charge performance-
based incentive fees that may lack "high-water mark" protections, allowing managers to earn performance fees on
recent gains even if the fund has not fully recovered from prior losses.
These complex fee structures create a specific conflict of interest, particularly regarding leverage. Because
management fees are calculated on gross assets, fund managers may be economically incentivized to employ
maximum leverage to increase the asset base upon which their fee is calculated, which simultaneously increases
the volatility and risk of the client’s investment. AWML addresses this conflict by conducting enhanced due
diligence on alternative investment managers, analyzing total expense ratios, and monitoring performance to
assess whether the manager's gross returns continue to justify the higher fee structures and elevated risk profile.
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, 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 carry 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 generally 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.
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.
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
Supervised persons of AWML, including Yoel Kaplowitz and Simcha Goldberg, are independent licensed
insurance agents 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.
AQR Opportunity Fund (Glide Direct Series, LLC) – Series Advisor Conflict
AWML serves as Series Advisor to the AQR Opportunity Fund, a designated series of Glide Direct Sales, LLC.
AWML will recommend investments in this fund to those eligible clients for which investment in the fund is
appropriate. This presents a conflict of interest in that AWML, or its related person may receive more
compensation from investment in the fund than from other investments. To mitigate this conflict and avoid 'double-
billing,' AWML does not charge its standard Level 1 or Level 2 investment advisory fees on any client assets
invested in the AQR Opportunity Fund. Instead, the firm receives only the 1.00% management fee associated with
the fund for those specific assets. Nevertheless, AWML acts in the best interest of the client consistent with its
fiduciary duties and clients are not required to invest in the fund if they do not wish to do so.
Arrangement with BlackRock, Inc.
AWML is eligible to receive access to Aladdin Wealth portfolio management software from BlackRock, Inc. at no
cost. The provision of this software is contingent upon AWML investing a certain threshold of client assets in
BlackRock mutual funds and exchange-traded funds (ETFs).
When utilized, the firm receives a significant economic benefit from this arrangement in the form of cost savings,
as it would otherwise be required to purchase comparable software from its own resources. This cost savings
directly benefits AWML's profitability and continues only so long as client assets remain invested in BlackRock
funds. This conflict creates a risk that investment selection may be influenced by the firm's economic benefit rather
than exclusively by the client's best interest. The firm addresses this conflict through documented investment
selection procedures requiring fiduciary analysis of all fund recommendations and Investment Committee
oversight. Clients are not obligated to invest in BlackRock funds.
Subadvisory Relationships
AWML has entered into subadvisory arrangements with the following SEC-registered investment advisers:
● SyntheticFi LLC (CRD #334027): Provides discretionary subadvisory services for securities-backed borrowing strategies using box
spreads. SyntheticFi charges clients a separate subadvisory fee.
● Brooklyn Investment Group, LLC (CRD #316475): Provides discretionary subadvisory services for direct indexing, custom
indexing, and tax-advantaged long/short equity strategies. Brooklyn charges clients a separate subadvisory fee based on gross
notional value of assets managed.
● Quantinno Capital Management LP: Provides two distinct services: (1) Discretionary subadvisory services for DEALS tax-
advantaged direct equity strategies (Core, Overlay, and Exchange) employing systematic tax-loss harvesting and leverage
(typically 130% long / 30% short). Quantinno charges a separate subadvisory fee of 0.45% annually. (2) Manages the Quantinno
Fundamental Arbitrage Fund LP, a private pooled investment vehicle employing a market-neutral equity strategy using OTC
swaps with 400-600% gross exposure. AWML may recommend this fund to suitable clients. The fund charges management fees
of 1.5% annually and performance fees of 20% of net profits (subject to high-water mark), in addition to AWML's advisory fee.
● Ancorato (Legacy Solutions LLC, CRD #323360): Provides structured note selection, due diligence, and monitoring services.
AWML compensates Ancorato directly from AWML's advisory fee; clients do not pay separate fees to Ancorato.
● AQR Capital Management II, LLC: Manages the AQR TA Delphi Plus Fund, a tax-aware alternative investment employing long-
short equity and trend-following strategies. AWML may recommend this fund to suitable clients through two structures: (1)
AWML's proprietary feeder fund (AWM Series) administered by Glide Platform LLC, where AWML acts as Series Advisor; or (2)
direct client investment into the AQR Fund. AQR has full discretionary authority over the Fund's portfolio management. The Fund
charges management fees of 1.75-2.00% annually (depending on share class) and performance fees of 17.5-20% of net profits
over a Treasury Bill hurdle rate, subject to high-water mark. These fees are in addition to AWML's advisory fee.
These arrangements allow AWML to provide specialized investment strategies and services beyond the firm's
core competencies. AWML retains full responsibility for determining the suitability of each subadvisor's services
for each client. Clients utilizing subadvisory services will receive the subadvisor's Form ADV Part 2A and other
required disclosure documents.
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 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.
Pontera Platform (Held-Away Account Management) – No Compensation,
Limitations and Data Sharing
AWML is not affiliated with Pontera Solutions, Inc. (“Pontera”) and receives no compensation from Pontera in
connection with our use of the Pontera platform. Clients should understand that our ability to manage held-away
accounts through the Pontera platform is subject to limitations imposed by the underlying plan sponsor, issuer,
and/or custodian, including (i) delays in the implementation of transactions (which may be one (1) business day or
more following entry), (ii) the availability of account information through the platform (which may not be real-time),
and (iii) limitations on our investment discretion to the investment options made available within the applicable
plan or account.
In connection with providing these services, clients authorize us to share non-public personal information with
Pontera and other unaffiliated service providers as necessary to administer and manage their accounts. We
require such service providers to maintain the confidentiality of client information and to restrict disclosure to
authorized parties.
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 recommends that clients buy or sell any security in which a related person to AWML or AWML
has a material financial interest.
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
AWML recommends custodians and broker-dealers consistent with its duty to seek best execution, meaning the
most favorable terms reasonably available under the circumstances. In evaluating providers, AWML considers
overall services and not solely the lowest commissions or transaction charges. Factors may include execution
quality, clearing and settlement capabilities, trading functionality, operational support, reporting, pricing,
reputation, financial stability, and prior experience. AWML is independently owned and not affiliated with
custodians or broker-dealers it may recommend. Clients typically open accounts directly with the selected
custodian/broker-dealer, and AWML may assist with the onboarding process.
Custodians/Broker-Dealers Commonly Used
AWML may recommend or work with: Fidelity Brokerage Services LLC (“Fidelity”), Charles Schwab & Co., Inc.
(“Schwab”), Altruist Financial LLC (“Altruist”), and for certain legacy accounts being transitioned off-platform, MTG,
LLC d/b/a Betterment Securities (“Betterment Securities”).
Soft Dollar Practices; Economic Benefits; Conflicts
AWML does not have any formal or informal “soft dollar” arrangements and does not “pay up” for research or
services using client commission dollars.
AWML may receive economic benefits from custodians and platform providers (for example, technology, software,
and support services). These benefits are generally related to the amount of client assets maintained with a
provider and create a conflict of interest because they provide an incentive to recommend or maintain
relationships based on benefits to AWML rather than solely on clients’ interests.
Betterment (Legacy Accounts Being Phased Out)
AWML maintains a limited number of legacy client accounts at Betterment that are being transitioned to other
custodians over time. Betterment Securities is generally compensated through the Betterment platform fee rather
than separate custody charges. Betterment may also make available certain support services, which creates a
conflict of interest. AWML seeks to mitigate this conflict through best execution oversight and by transitioning
these legacy accounts where appropriate.
Services Available from BlackRock Custom Model Solutions (CMS)
AWML utilizes BlackRock CMS for model portfolio services and related support at no cost. This arrangement is
subject to an asset threshold across models and may involve allocations to BlackRock-affiliated funds, creating a
conflict of interest. AWML retains full fiduciary responsibility for suitability and implementation decisions.
Step-Out Trading (Sub-Advisors)
For accounts managed by certain third-party sub-advisors, the sub-advisor may execute trades away from the
client’s primary custodian to seek best execution (“step-out trades”). Clients may incur additional transaction costs,
trade-away fees, or commissions not included in AWML’s advisory fee.
Brokerage for Client Referrals
AWML does not receive referrals from broker-dealers, custodians, or third parties in exchange for using or
recommending them.
Clients Directing Which Broker/Dealer/Custodian to Use
AWML generally requires clients to use custodians that support AWML’s ability to provide services (including
trading, reporting, and administration). If a client directs brokerage or custody, AWML may have limited ability to
negotiate costs or achieve best execution, and the client may incur higher costs or other limitations.
Aggregating (Block Trading)
AWML may aggregate trades for multiple clients when it believes doing so is fair and may improve execution or
efficiency. Allocations are intended to be equitable over time, are periodically reviewed, and may not be available
for accounts with specific trading restrictions or directed brokerage.
Item 13: Review of Accounts
Frequency and Nature of Periodic Reviews and Who Makes Those Reviews
Ongoing investment advisory accounts. Client accounts receiving ongoing investment advisory services are
reviewed at least quarterly, and more frequently as AWML determines appropriate. Reviews generally consider
the client’s investment objectives, risk tolerance, time horizon, liquidity needs, constraints, and alignment with the
client’s investment policy (as applicable). Reviews are conducted by Seth P. Hodes, Chief Compliance Officer
(“CCO”), and/or other supervised persons under the CCO’s oversight.
Financial planning engagements (non-ongoing). Financial planning engagements are typically reviewed in
connection with plan preparation and delivery. Because financial planning services are generally provided on a
non-recurring basis (unless otherwise agreed), AWML’s review process for planning clients typically concludes
upon delivery of the financial plan and any agreed-upon follow-up meeting(s). Clients may engage AWML for
additional planning services in the future under a new or amended agreement and for an additional fee, as
applicable.
Factors That Will Trigger a Non-Periodic Review of Client Accounts
In addition to periodic reviews, AWML may review accounts (or the appropriateness of a financial plan) in
response to events such as: Significant market, economic, or geopolitical developments; Material changes in a
client’s financial circumstances or objectives (for example, retirement, inheritance, divorce, business sale, job
change, relocation, or major changes in cash flow); Significant deposits, withdrawals, or changes in account
composition; Changes in applicable laws, regulations, product features, or account restrictions that may impact the
client.
For financial planning clients, AWML’s services generally conclude upon delivery of the financial plan unless the
client requests and engages AWML for additional services.
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.
Item 14: Client Referrals and Other Compensation
Economic Benefits Provided by Third Parties for Advice Rendered to Clients
AWML may receive economic benefits from custodians, platform providers, and other third parties in connection
with services provided to AWML and/or AWML’s clients, such as technology, software, reporting, practice
management resources, training, or other support services. These benefits may create a conflict of interest by
providing an incentive for AWML to recommend or maintain relationships with certain providers based on benefits
to AWML rather than solely on clients’ interests.
To the extent AWML receives such benefits from a custodian or platform provider, related conflicts and the firm’s
practices are described in Item 12 (Brokerage Practices) and/or elsewhere in this brochure, as applicable.
Betterment (legacy accounts being phased out).
AWML maintains a limited number of legacy accounts on the Betterment Institutional platform that are being
transitioned off platform over time. Betterment may make available certain support services to participating
advisory firms. These benefits are not contingent on AWML providing particular investment advice (such as
recommending specific securities). Related conflicts are described in Item 12.
Potential economic benefits from BlackRock (Aladdin Wealth).
As disclosed in Item 10, AWML may be eligible to receive access to portfolio management software (Aladdin
Wealth) at no cost, contingent on maintaining certain client asset thresholds in BlackRock products. When utilized,
this provides an economic benefit to AWML and creates a conflict of interest. AWML mitigates this conflict through
documented investment selection procedures and Investment Committee oversight.
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
AWML is generally deemed to have limited custody of client assets when the client authorizes AWML to deduct
advisory fees directly from the client’s custodial account. In those circumstances, AWML obtains written
authorization from the client and provides fee-related information as required under applicable regulations.
Clients receive account statements directly from their qualified custodian (for example, Fidelity, Schwab, Altruist,
and/or Betterment Securities for legacy accounts), and clients should carefully review those statements and any
billing information for accuracy. The qualified custodian maintains actual custody of client assets.
Item 16: Investment Discretion
AWML provides both discretionary and non-discretionary investment advisory services, depending on the client’s
agreement and selected services. Where a client grants AWML discretionary authority, AWML may buy and sell
securities and otherwise manage the account without obtaining the client’s prior approval for each transaction,
consistent with the client’s investment objectives and any written guidelines or restrictions. In non-discretionary
arrangements, AWML provides recommendations and the client generally makes the final decision before trades
are executed. The scope of AWML’s authority is set forth in the client’s advisory agreement and/or applicable
account documentation.
Item 17: Voting Client Securities (Proxy Voting)
AWML does not ask for, nor accept, authority to vote client securities (proxies) for assets managed directly by
AWML or for assets managed by certain third-party subadvisors whose policy is not to vote proxies. For these
assets, clients retain responsibility for voting proxies and will generally receive proxy materials directly from the
issuer and/or the custodian.
Exception for Certain Third-Party Subadvisors
If client assets are managed by an independent third-party subadvisor selected or recommended by AWML, and
that subadvisor’s stated policy is to vote proxies, that subadvisor may vote proxies for the assets it manages in
accordance with its proxy voting policies. In such cases, the client may not receive proxy materials for those
assets. Information regarding a subadvisor’s proxy voting policies is provided in the subadvisor’s disclosure
documents.
Currently, Brooklyn Investment Group votes proxies for assets under its discretionary management. SyntheticFi
and Quantinno do not vote proxies for assets they manage.
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
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.