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Access Wealth
Form ADV Part 2A
Brochure
IARD/CRD No. 112973
SEC File No.: 801-60406
March 2026
120 Eagle Rock Avenue
East Hanover, NJ 07936
Phone: 973-740-2400
Fax: 973-461-4717
Web Site: www.access-wealth.com
March 2026
FORM ADV PART 2A BROCHURE
This brochure provides information about the qualifications and business practices of Access Wealth.
If you have any questions about the contents of this brochure, please contact us at 973-740-2400.
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.
information about Access Wealth
is also available on the SEC’s website at
Additional
www.adviserinfo.sec.gov. The searchable IARD/CRD number for Access Wealth is 112973.
Access Wealth is a registered investment adviser. Registration or any reference to the firm being or
the use of the terms “registered”, “registration,” or “registered investment adviser” does not imply
a certain level of skill or training.
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Access Wealth
Form ADV Part 2A
Brochure
IARD/CRD No. 112973
SEC File No.: 801-60406
March 2026
Item 2 - Material Changes
This section of the brochure highlights specific material changes made since the last update and offers
clients a concise summary of these modifications. The most recent update to our brochure was March
2025.
Furthermore, we have updated the Assets Under Management information in Item 4 to align with the
filing of our Annual Updating Amendment.
Clients are encouraged to request a copy of Form ADV Part 2A at any time, free of charge. Requests
can be made by sending a written notice to our Chief Compliance Officer at 120 Eagle Rock Avenue,
Suite 230, East Hanover, NJ 07936, or via email at thagberg@access-wealth.com.
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Access Wealth
Form ADV Part 2A
Brochure
IARD/CRD No. 112973
SEC File No.: 801-60406
March 2026
Contents
ITEM 2 ‐ MATERIAL CHANGES ................................................................................................................... 2
ITEM 4 ‐ ADVISORY BUSINESS ................................................................................................................... 4
ITEM 5 ‐ FEES AND COMPENSATION .......................................................................................................... 6
ITEM 6 ‐ PERFORMANCE‐BASED FEES AND SIDE‐BY‐SIDE MANAGEMENT ................................................. 9
ITEM 7 ‐ TYPES OF CLIENTS .................................................................................................................... 10
ITEM 8 ‐ METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ................................... 11
ITEM 9 ‐ DISCIPLINARY INFORMATION ................................................................................................... 15
ITEM 10 ‐ OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ............................................... 16
ITEM 11 ‐ CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS .......................... 18
AND PERSONAL TRADING ....................................................................................................................... 18
ITEM 12 ‐ BROKERAGE PRACTICES ........................................................................................................ 20
ITEM 13 ‐ REVIEW OF ACCOUNTS ........................................................................................................... 24
ITEM 14 ‐ CLIENT REFERRALS AND OTHER COMPENSATION .................................................................. 25
ITEM 15 – CUSTODY ............................................................................................................................... 26
ITEM 16 ‐ INVESTMENT DISCRETION ..................................................................................................... 28
ITEM 17 ‐ VOTING CLIENT SECURITIES .................................................................................................. 29
ITEM 18 ‐ FINANCIAL INFORMATION ...................................................................................................... 30
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Access Wealth
Form ADV Part 2A
Brochure
IARD/CRD No. 112973
SEC File No.: 801-60406
March 2026
Item 4 - Advisory Business
The United States Securities and Exchange Commission granted the investment adviser registration of
Access Wealth (“Access Wealth”) on July 1, 2001. The owners of the company are Darren Zagarola (CRD
Number 5121491), Howard Hook (CRD Number 4199828), and Howard Milove (CRD Number
3230483),Tracy A. Hagberg (CRD Number 1841992) is Chief Compliance Officer of the firm. Access
Wealth employs a holistic and comprehensive approach to investment advisory and financial planning
services. Our approach helps clients accumulate, protect and ultimately pass wealth from generation
to generation in an efficient manner.
Investment Advisory Services
Our investment advisory process begins with conversations to identify the client’s goals and objectives,
investment time horizon, and establish the client’s risk tolerance. Access Wealth then recommends
investment allocations that are suitable for the client and provide a balanced level of risk and reward.
Access Wealth continues to monitor portfolios and will rebalance as we feel appropriate given
economic considerations. We believe communication is a key component of the ongoing investment
advisory process so we will update clients on changes in the economy and encourage our client’s to
communicate to us any changes in their financial situation.
Our investment advisory services are provided on a discretionary basis, as specified in the client’s
agreement. When Access Wealth is engaged to provide asset management services on a discretionary
basis, Access Wealth will monitor client accounts to ensure that they are meeting asset allocation
requirements. On behalf of our clients, if any changes are needed to the investments, Access Wealth
will make those changes. These changes may involve selling a security or group of investments and
buying others or keeping the proceeds in cash. Clients may at any time place restrictions on the types
of investments Access Wealth may use on the client’s behalf, or on the allocations to each security
type. Clients will receive written or electronic confirmations from the account custodian after any
changes are made to the client account. Clients will also receive statements, at least quarterly, from
the account custodian.
Financial Planning
We offer our clients a comprehensive range of financial planning services that are tailored to their
specific needs and goals and believe it is an ongoing process as life evolves and unfolds. Through a
thorough analysis of their financial resources, we provide our clients with personalized financial
programs that cover their present and future assets and liabilities, including retirement planning,
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Form ADV Part 2A
Brochure
IARD/CRD No. 112973
SEC File No.: 801-60406
March 2026
charitable giving strategies, estate planning, tax planning, insurance planning, family wealth planning,
education savings planning, and cash management strategies.
Our financial planning services go beyond providing general recommendations for our clients. We
provide specific actions that clients can take to achieve their financial objectives, such as acquiring
insurance coverage, setting up an individual retirement account, or drawing up estate planning
documents. If needed, we can recommend the services of other professionals to implement our
recommendations. However, our clients are not obligated to use any recommended professionals, and
they retain absolute discretion over all such decisions.
We also offer ongoing financial counseling, account reviews, securities research, and other advisory
services related to investments. We strongly encourage our clients to renew their financial planning
services annually to review and update our previous recommendations and services, ensuring that their
financial plans remain aligned with their evolving needs and goals. Financial Planning services are
offered under a separate agreement from investment advisory services.
Account Aggregation Services
We offer Account Aggregation services to our clients, allowing them to track their investments through
Access Wealth. To utilize this service, clients must provide their investment statements or consent to
have their transactions downloaded directly to our systems. Access Wealth will maintain the
investment data and produce Portfolio Management reports on a monthly or quarterly basis. Please
note that this service is solely for tracking and reporting purposes and does not include financial
planning or management of assets.
Assets Under Management
As of December 31, 2025, the firm had regulated assets under management in the amount of
$539,117,584 across 1009 accounts of which 100% is managed on a discretionary basis.
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Access Wealth
Form ADV Part 2A
Brochure
IARD/CRD No. 112973
SEC File No.: 801-60406
March 2026
Item 5 - Fees and Compensation
A. Fees Charged
Investment Advisory Services
All investment advisory clients will be required to execute an Investment Advisory Agreement that will
describe the type of asset management services to be provided and the fees, among other items.
Clients are advised that they may pay fees that are higher or lower than fees they may pay another
advisor for the same services, and may in fact pay lower fees for comparable services from other
sources. Clients are under no obligation at any time to engage or to continue to engage Access Wealth
for investment services.
Access Wealth’s annual investment advisory fee shall vary (up to 1.50% of the total assets placed under
Access Wealth’s management) and shall be based upon various objective and subjective factors,
including, but not limited to, the amount of the assets placed under Access Wealth’s direct
management, the complexity of the engagement, and the level and scope of the overall investment
advisory services to be rendered. The investment advisory fee is negotiable in the sole discretion of
Access Wealth.
Financial Planning Services
For financial planning services, Access Wealth charges a fixed fee. These fees are negotiable and
typically range from $1,500 to $5,000 depending on the complexity of the client's situation. Upon
engaging Access Wealth, 50% of the fee is due, and the remaining balance is due upon presentation of
the written financial plan.
We will offer a full refund on the financial planning fee if the client notifies us, in writing, within 10 days
of receiving the financial plan that they are not satisfied with it. We will also refund any fees paid if the
client terminates our relationship before the financial plan is delivered.
Investment Advisory and Financial Planning Combined Services
In addition, we offer a combined flat fee for financial planning services and investment advisory
services. These fees are negotiable and typically range from $8,000 to $18,000 per year. payable on a
quarterly basis. The client can choose to have the fees deducted from their investment advisory
accounts under Access Wealth's management or be billed separately.
Both the client and Access Wealth have the right to terminate the advisory agreement at any time with
written notice. If the agreement or our services are terminated, we will promptly refund any unearned
portion of the fee to the client.
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Access Wealth
Form ADV Part 2A
Brochure
IARD/CRD No. 112973
SEC File No.: 801-60406
March 2026
Account Aggregation Services
Access Wealth offers account aggregation services at a fixed rate fee ranging from $1,000 to $5,000
per year. This fee is negotiable in the sole discretion of Access Wealth.
B. Fee Payment
Investment Advisory Services
The investment advisory fee is paid quarterly, in advance, and the value used for the fee calculation is
the net value as of the last market day of the previous quarter, including any cash in the client’s
account. For example, if your annual fee is 1.00%, each quarter we will multiply the value of your
account by 1.00%, then divide by four to calculate our fee. To the extent there is cash in your account,
it will be included in the value for the purpose of calculating fees only if the cash is part of an investment
strategy. Once the calculation is made, we will instruct your account custodian to deduct the fee from
your account and remit it to Access Wealth. Clients may also pay the investment advisory fee directly
by submitting a check payable to Access Wealth.
Clients whose fees are directly debited will provide written authorization to debit advisory fees from
their accounts held by a qualified custodian chosen by the client. Access Wealth is to invoice the
qualified custodian for fees. Each quarter, the client will receive a statement from their account
custodian showing all transactions in their account, including the fee. Access Wealth encourages clients
to carefully review the statements and confirmations sent to them by their custodian, and to compare
the information on reports prepared by Access Wealth against the information in the statements
provided directly from the custodian. Please alert Access Wealth of any discrepancies.
Financial Planning Services
Upon engaging Access Wealth for financial planning services, 50% of the fee is due at the time of
engagement, and the remaining balance is due upon presentation of the written financial plan. The
fee can be paid by check or debited from the investment assets managed by Access Wealth.
We will offer a full refund on the financial planning fee if the client notifies us, in writing, within 10 days
of receiving the financial plan that they are not satisfied with it. We will also refund any fees paid if the
client terminates our relationship before the financial plan is delivered.
Investment Advisory and Financial Planning Combined Services
When Access Wealth is engaged by the client for both investment advisory and financial planning
services, a fixed fee is charged and payable on a quarterly basis. The client can choose to have the fee
deducted from their investment advisory accounts under Access Wealth's management or be billed
separately.
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Form ADV Part 2A
Brochure
IARD/CRD No. 112973
SEC File No.: 801-60406
March 2026
Both the client and Access Wealth have the right to terminate the advisory agreement at any time with
written notice. If the agreement or our services are terminated, we will promptly refund any unearned
portion of the fee to the client.
C. Other Fees
There are a number of other fees that can be associated with holding and investing in securities.
Expenses of a mutual fund or ETF will not be included in management fees, as they are deducted from
the value of the shares by the manager. When selecting mutual funds that have multiple share classes
for recommendation to clients, Access Wealth will take into account the internal fees and expenses
associated with each share class, and it is Access Wealth’s policy to choose the lowest-cost share class
available, absent circumstances that dictate otherwise. For complete discussion of expenses related
to each mutual fund or ETF, you should read a copy of the prospectus issued by that fund. Access
Wealth can provide or direct you to a copy of the prospectus for any fund that we recommend to you.
Please make sure to read Item 12 of this informational brochure, where we discuss broker-dealer and
custodial issues.
Pro-rata Fees
D.
If a client becomes a client during a quarter, they will pay a management fee for the number of days
left in that quarter. If clients terminate the relationship during a quarter, they will be entitled to a
refund of any management fees for the remainder of the quarter they may have prepaid. Once the
notice of termination is received, Access Wealth will assess pro-rated fees for the number of days
between the end of the prior billing period and the date of termination to be paid in whatever way a
client direct (check, wire). Access Wealth will cease to perform services, including processing trades
and distributions, upon termination. Assets not transferred from terminated accounts within 30
(thirty) days of termination may be “de-linked”, meaning they will no longer be visible to Access Wealth
and will become a retail account with the custodian.
E. Compensation for Sales of Securities
Access Wealth does not engage in the buying or selling of securities for the purpose of earning
commissions, and we do not receive any compensation related to securities transactions in any client
account, beyond the investment fees as described previously.
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Form ADV Part 2A
Brochure
IARD/CRD No. 112973
SEC File No.: 801-60406
March 2026
Item 6 - Performance-Based Fees and Side-by-Side Management
Our firm does not charge performance-based fees, which are fees based on a share of capital gains or
capital appreciation of the assets of a client. We believe that charging such fees creates a conflict of
interest between our clients and us.
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Access Wealth
Form ADV Part 2A
Brochure
IARD/CRD No. 112973
SEC File No.: 801-60406
March 2026
Item 7 - Types of Clients
Access Wealth provides investment advisory services to a diverse range of clients, including individuals,
high net worth individuals, pension and profit-sharing plans, trusts, estates, charitable organizations,
corporations, and other business entities. We do not have a minimum portfolio size requirement, but
all clients are required to enter into a formal services agreement that outlines the scope of services to
be provided.
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Access Wealth
Form ADV Part 2A
Brochure
IARD/CRD No. 112973
SEC File No.: 801-60406
March 2026
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
Strategies and Methods of Analysis
Modern Portfolio Theory (“MPT”) is a time-tested economic concept that emphasizes the importance
of asset allocation, diversification, and rebalancing as part of a sound investment strategy. According
to MPT, a portfolio's risk and return characteristics are determined by its composition and the
correlation of its components. An optimal asset allocation for each level of risk is designed to achieve
the best balance of risk and return, rather than the highest returns or the lowest risk. The Efficient
Frontier represents the meeting point of each level of risk and reward, where optimal portfolios reside.
At Access Wealth, we implement the principles of Modern Portfolio Theory to construct models with
varying levels of risk (standard deviation) that are appropriate for each client's investment horizon, risk
tolerance, age, and financial situation. In some cases, we may create a client-specific model to meet
special situations.
Our Investment Committee evaluates each investment manager selection for every asset class. To be
considered, investment managers must have at least a five-year history in their asset class, with a
standard deviation (risk) within an acceptable range, historical returns within an acceptable range, and
fees within acceptable parameters for their asset class. The investment management firm must also
maintain the investment style for which it has been chosen to represent within the portfolio.
While individual money managers may charge a fee to be paid by the client, Access Wealth and its
associated persons do not receive any portion of that fee.
Risk of Loss
There are always risks to investing. Clients should be aware that all investments carry various types of risk
including the potential loss of principal that clients should be prepared to bear. It is impossible to name all
possible types of risks. Among the risks are the following:
Political Risks. Most investments have a global component, even domestic stocks. Political events
anywhere in the world may have unforeseen consequences to markets around the world.
General Market Risks. Markets can, as a whole, go up or down on various news releases or for no
understandable reason at all. This sometimes means that the price of specific securities could go up or
down without real reason and may take some time to recover any lost value. Adding additional
securities does not help to minimize this risk since all securities may be affected by market fluctuations.
Currency Risk. When investing in another country using another currency, the changes in the value of
the currency can change the value of your security value in your portfolio.
Regulatory Risk. Changes in laws and regulations from any government can change the value of a given
company and its accompanying securities. Certain industries are more susceptible to government
regulation. Changes in zoning, tax structure or laws impact the return on these investments.
Tax Risks Related to Short Term Trading: Clients should note that Access Wealth may engage in short-
term trading transactions. These transactions may result in short term gains or losses for federal and
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Form ADV Part 2A
Brochure
IARD/CRD No. 112973
SEC File No.: 801-60406
March 2026
state tax purposes, which may be taxed at a higher rate than long term strategies. Access Wealth
endeavors to invest client assets in a tax efficient manner, but all clients are advised to consult with their
tax professionals regarding the transactions in client accounts.
Purchasing Power Risk. Purchasing power risk is the risk that your investment’s value will decline as the
price of goods rises (inflation). The investment’s value itself does not decline, but its relative value does,
which is the same thing. Inflation can happen for a variety of complex reasons, including a growing
economy and a rising money supply.
Business Risk. This can be thought of as certainty or uncertainty of income. Management comes under
business risk. Cyclical companies (like automobile companies) have more business risk because of the
less steady income stream. On the other hand, fast food chains tend to have steadier income streams
and therefore, less business risk.
Financial Risk. The amount of debt or leverage determines the financial risk of a company.
Default Risk. This risk pertains to the ability of a company to service their debt. Ratings provided by
several rating services help to identify those companies with more risk. Obligations of the U.S.
government are said to be free of default risk.
Margin Risk. “Margin” is a tool used to maximize returns on a given investment by using securities in a
client account as collateral for a loan from the custodian to the client. The proceeds of that loan are
then used to buy more securities. Margin carries a higher degree of risk than investing without margin.
Short Sales. “Short sales” are a way to implement a trade in a security Access Wealth feels is overvalued.
In a “long” trade, the investor is hoping the security increases in price. Thus, in a long trade, the amount
of the investor’s loss (without margin) is the amount paid for the security. In a short sale, the investor
is hoping the security decreases in price. However, unlike a long trade where the price of the security
can only go from the purchase price to zero, in a short sale, the prince of the security can go infinitely
upwards. Thus, in a short sale, the potential for loss is unlimited and unknown, where the potential for
loss in a long trade is limited and knowable. Access Wealth utilizes short sales only when the client’s risk
tolerances permit.
Risks specific to private placements, sub-advisors and other managers. If we invest some of your assets
with another advisor, including a private placement, there are additional risks. These include risks that
the other manager is not as qualified as we believe them to be, that the investments they use are not as
liquid as we would normally use in your portfolio, or that their risk management guidelines are more
liberal than we would normally employ.
Information Risk. All investment professionals rely on research in order to make conclusions about
investment options. This research is always a mix of both internal (proprietary) and external (provided
by third parties) data and analyses. Even an adviser who says they rely solely on proprietary research
must still collect data from third parties. This data, or outside research is chosen for its perceived
reliability, but there is no guarantee that the data or research will be completely accurate. Failure in
data accuracy or research will translate to a compromised ability by the adviser to reach satisfactory
investment conclusions.
Small Companies. Some investment opportunities in the marketplace involve smaller issuers. These
companies may be starting up or are historically small. While these companies sometimes have
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Form ADV Part 2A
Brochure
IARD/CRD No. 112973
SEC File No.: 801-60406
March 2026
potential for outsized returns, they also have the potential for losses because the reasons the company
is small are also risks to the company’s future. For example, a company’s management may lack
experience, or the company’s capital for growth may be restricted. These small companies also tend to
trade less frequently that larger companies, which can add to the risks associated with their securities
because the ability to sell them at an appropriate price may be limited compared to the markets as a
whole. Not only do these companies have investment risk, if a client is invested in such small companies
and requests immediate or short-term liquidity, these securities may require a significant discount to
value in order to be sold in a shorter time frame.
Concentration Risk. While Access Wealth selects individual securities, including mutual funds, for client
portfolios based on an individualized assessment of each security, this evaluation comes without an
overlay of general economic or sector specific issue analysis. This means that a client’s equity portfolio
may be concentrated in a specific sector, geography, or sub-sector (among other types of potential
concentrations), so that if an unexpected event occurs that affects that specific sector or geography, for
example, the client’s equity portfolio may be affected negatively, including significant losses.
Transition risk. As assets are transitioned from a client’s prior advisers to Access Wealth there may be
securities and other investments that do not fit within the asset allocation strategy selected for the
client. Accordingly, these investments will need to be sold in order to reposition the portfolio into the
asset allocation strategy selected by Access Wealth. However, this transition process may take some
time to accomplish. Some investments may not be unwound for a lengthy period of time for a variety
of reasons that may include unwarranted low share prices, restrictions on trading, contractual
restrictions on liquidity, or market-related liquidity concerns. In some cases, there may be securities or
investments that are never able to be sold. The inability to transition a client's holdings into
recommendations of Access Wealth may adversely affect the client's account values, as Access Wealth’s
recommendations may not be able to be fully implemented.
Restriction Risk. Clients may at all times place reasonable restrictions on the management of their
accounts. However, placing these restrictions may make managing the accounts more difficult, thus
lowering the potential for returns.
Risks Related to Investment Term & Liquidity. Securities do not follow a straight line up in value. All
securities will have periods of time when the current price of the security is not an accurate measure of
its value. If you require us to liquidate your portfolio during one of these periods, you will not realize as
much value as you would have had the investment had the opportunity to regain its value. Further,
some investments are made with the intention of the investment appreciating over an extended period
of time. Liquidating these investments prior to their intended time horizon may result in losses.
Excess Cash Balance Risk: Client accounts may have cash balances in excess of $250,000, which is the
insurance limit of the Federal Deposit Insurance Corporation. For cash balances in excess of that
amount, there is an enhanced risk that operation related counterparty risk related to the account
custodian could cause losses in the account. We mitigate this risk by carrying cash balances in amounts
either subject to protection or as limited as you, the client, directs. You may elect to participate in a
“cash sweep” program through your account custodian which automatically moves excess cash from
your investment account into a cash account and then invests that cash into cash-based investments,
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Form ADV Part 2A
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IARD/CRD No. 112973
SEC File No.: 801-60406
March 2026
such as money market funds. We do not receive compensation of any kinds for facilitating your
participation in such cash sweep accounts.
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Brochure
IARD/CRD No. 112973
SEC File No.: 801-60406
March 2026
Item 9 - Disciplinary Information
We are obligated to inform clients or prospective clients of any material legal or disciplinary events
that may impact their assessment of our advisory business or the integrity of our management. Access
Wealth has nothing to report.
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Brochure
IARD/CRD No. 112973
SEC File No.: 801-60406
March 2026
Item 10 - Other Financial Industry Activities and Affiliations
We are required to disclose any relationship or arrangement that is material to our advisory business
with certain related people.
A. Broker-dealer
Some of our supervised persons are registered representatives of Purshe Kaplan Sterling Investments,
Inc. (“PKS”), a registered broker-dealer (CRD No. 6627), and a member of FINRA and SIPC. As registered
representatives of PKS, these individuals may engage in securities transactions that are not related to
their work with Access Wealth. They may receive commission-based compensation, including 12b-1
fees for the sale of investment company products, for such transactions, which is separate from the
advisory fees paid to Access Wealth. This may create a conflict of interest, as they may be incentivized
to prioritize generating commissions rather than acting solely in the best interest of the client.
However, clients are not obligated to follow the recommendations of the supervised people, and
neither the Advisor nor supervised persons will earn ongoing investment advisory fees in connection
with any products or services implemented in their separate capacity as a registered representative.
Please refer to Item 10 – Other Financial Industry Activities and Affiliations for more information.
B. Broker-dealer
Principals of Access Wealth, nor any related persons are registered, or have an application pending to
register, as a futures commission merchant, commodity pool operator, a commodity trading advisor,
or an associated person of the foregoing entities.
C. Relationship with Related Persons
Consultants
Tax Preparation
Certain associated persons of Access Wealth are Certified Public Accountants (“CPAs”). Howard Hook
prepares tax returns for individuals who are not clients of Access Wealth. His tax business is not
promoted through Access Wealth.
D. Recommendations of Other Advisers
Darren Zagarola, Howard Milove and Howard Hook are the owners of DHH Advisors, LLC, (“DHH”) an
SEC registered investment adviser that provides comprehensive financial planning and investment
advisory services. Access Wealth and DHH are parties to an agreement whereby DHH has hired Access
Wealth to provide back office and administrative services and support for a fee.
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SEC File No.: 801-60406
March 2026
Access Wealth has an inherent conflict of interest related to the relationship with EKS Associates
(“EKS”). Certain principal owners of Access Wealth are also principal owners of EKS. This creates a
conflict of interest, as there may be a financial incentive for Access Wealth to refer clients to EKS, as
they would have personal financial gain. Additionally, there is a conflict where being an employee of
EKS may potentially take away from an employee’s ability to conduct business for Access Wealth.
Access Wealth attempts to mitigate these conflicts by requiring employees to acknowledge the firm’s
Code of Ethics and reminding them of their individual fiduciary duty to the clients of Access Wealth,
which requires that employees put the interests of their clients above their own.
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Brochure
IARD/CRD No. 112973
SEC File No.: 801-60406
March 2026
Item 11 - Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
A. Code of Ethics
As a fiduciary, Access Wealth and its associates have a duty of utmost good faith to act solely in the
best interests of each client. Our clients entrust us with their funds and personal information, which
places a high standard on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of
Ethics and represents the expected basis of all our dealings.
Our Code of Ethics is designed to ensure that we act with the highest standards of ethical behavior and
professionalism. It is not intended to identify all possible conflicts of interest, and associated persons
may still be liable for personal trading or other conduct that violates their fiduciary duty to advisory
clients. A summary of the Code of Ethics’ Principles is outlined below:
• Integrity – We shall offer and provide professional services ethically, honestly, and fairly.
• Objectivity – We shall be objective in providing professional services to clients.
• Competence – We shall provide services to clients competently and maintain the necessary
knowledge and skill to continue to do so in those areas in which we are engaged.
• Fairness – We shall perform professional services in a manner that is fair and reasonable to clients
and shall disclose conflicts of interest in providing such services.
• Confidentiality – We shall not disclose confidential client information without the specific consent of
the client, except in response to proper legal process, or as required by law.
We periodically review and update our Code of Ethics to ensure that it remains current and relevant,
and we require all firm access persons to attest to their understanding of and adherence to the Code
of Ethics at least annually. We are happy to provide a copy of our Code of Ethics to any client or
prospective client upon request.
B. Financial Interest Conflict
Access Wealth does not recommend to clients that they invest in any security in which Access Wealth,
or any principal thereof has any financial interest.
C. Participation or Interest in Client Transactions
We and our related persons may buy or sell securities that are the same, similar, or different from those
we recommend to clients. Recommendations may vary between clients due to differing objectives and
risk tolerances. However, we ensure that neither we nor any related party receives preferential
treatment over our clients.
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D. Personal Trading
To avoid conflicts of interest, we may restrict or prohibit associates from trading certain securities. Any
exceptions must be approved by our Chief Compliance Officer beforehand, and we keep records of all
personal securities transactions as required by regulations.
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SEC File No.: 801-60406
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Item 12 - Brokerage Practices
Suggestion of Broker
Charles Schwab
Access Wealth does not maintain custody of your assets that we manage. Your assets must be
maintained in an account at a “qualified custodian”, generally a broker-dealer or bank. We recommend
that our clients use Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer, member SIPC,
as the qualified custodian.
We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your
assets in a brokerage account and buy and sell securities when we instruct them to. While we
recommend that you use Schwab as custodian/broker, you will decide whether to do so and will open
your account with Schwab by entering into an account agreement directly with them. Conflicts of
interest associated with this arrangement are described below as well as in Item 14 (Client Referrals
and Other Compensation). You should consider these conflicts of interest when selecting your
custodian.
We do not open an account for you, although we may assist you in doing so. If you do not wish to place
your assets with Schwab, then we cannot manage your account.
How We Select Brokers/Custodians
We seek to select a custodian/broker that will hold your assets and execute transactions. When
considering whether the terms that Schwab provides are, overall, most advantageous to you when
compared with other available providers and their services, we consider a wide range of factors
including:
1. Combination of transaction execution services and asset custody services (generally without a
separate fee for custody).
2. Capability to execute, clear and settle trades (buy and sell securities for your account).
3. Capability to facilitate transfers and payments to and from accounts (wire transfers, check
requests, etc.)
4. Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds,
etc.)
5. Availability of investment research and tools that assist us in making investment decisions.
6. Quality of services.
7. Competitiveness of the price of those services (commission rates, margin interest rates, other
fees, etc.) and willingness to negotiate the prices.
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8. Reputation, financial strength, security and stability.
9. Prior service to us and our clients.
10. Availability of other products and services that benefit us, as discussed below (see “Products
and Services Available to us from Schwab).
Your Brokerage and Trading Costs
For our client accounts that Schwab maintains, Schwab generally does not charge you separately for
custody services but is compensated by charging you commissions or other fees on trades that it
executes or that settle into your Schwab account. Certain trades (for example, many mutual funds, and
U.S. exchange-listed equities and ETFs) may not incur Schwab commissions or transaction fees. Schwab
is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash
Features Program.
In addition to commissions, Schwab charges you a flat dollar amount as a “prime broker” or “trade
away” fee for each trade that we have executed by a different broker-dealer but where the securities
sold are deposited (settled) into your Schwab account. These fees are in addition to the commissions
or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your
trading costs, we have Schwab execute most trades for your account.
We are not required to select the broker or dealer that charges the lowest transaction cost, even if that
broker provides execution quality comparable to other brokers or dealers. Although we are not
required to execute all trades through Schwab, we have determined that having Schwab execute most
trades is consistent with our duty to seek “best execution” of your trades. Best execution means the
most favorable terms for a transaction based on all relevant factors, including those listed above (see
“How We Select Brokers/Custodians”). By using another broker or dealer you may pay lower
transaction costs.
Products and Services Available to us from Schwab
Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like
ours. They provide us and our clients with access to their institutional brokerage services (trading,
custody, reporting and related services), many of which are not typically available to Schwab retail
customers. However, certain retail investors may be able to get institutional brokerage services from
Schwab without going through our firm. Schwab also makes available various support services. Some
of those services help us manage or administer our clients’ accounts, while others help us manage and
grow our business. Schwab’s support services are generally available at no charge to us. Following is a
more detailed description of Schwab’s support services:
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Services that benefit you. Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions and custody of client assets. The investment
products available through Schwab include some to which we might not otherwise have access or that
would require a significantly higher minimum initial investment by our clients. Schwab’s services
described in this paragraph generally benefit you and your account.
Services that do not directly benefit you. Schwab also makes available to us other products and
services that benefit us but do not directly benefit you or your account. These products and services
assist us in managing and administering our clients’ accounts and operating our firm. They include
investment research, both Schwab’s own and that of third parties. We use this research to service all
or a substantial number of our clients’ accounts, including accounts not maintained at Schwab. In
addition to investment research, Schwab also makes available software and other technology that:
1. Provide access to client account data (such as duplicate trade confirmations and account
statements.
2. Facilitate trade execution and allocate aggregated trade orders for multiple client accounts.
3. Provide pricing and other market data.
4. Facilitate payment of our fees from our clients’ accounts.
5. Assist with back-office functions, record keeping and client reporting.
Services that generally benefit only us. Schwab also offers other services intended to help us manage
and further develop our business enterprise. These services include:
1. Educational conferences and events.
2. Consulting on technology and business needs.
3. Publications and conferences on practice management and business succession.
4. Access to employee benefits providers, human capital consultants and insurance providers.
5. Marketing consulting and support.
Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to
provide the services to us. Schwab also discounts or waives fees for some of these services or pays all
or a part of a third party’s fees. Schwab also provides us with other benefits, such as occasional business
entertainment for our personnel. If you did not maintain your account with Schwab, we would be
required to pay for these services from our own resources.
Our Interest in Schwab’s Services
The availability of these services from Schwab benefits us because we do not have to produce or
purchase them. We do not have to pay for Schwab’s services. The fact that we receive these benefits
from Schwab is an incentive for us to recommend the use of Schwab rather than making such decision
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based exclusively on your interest in receiving the best value in custody services and the most favorable
execution of your transactions. This is a conflict of interest. We believe, however, that taken in the
aggregate, our selection of Schwab as custodian and broker is in the best interest of our clients. Our
selection is supported by the scope, quality and price of Schwab’s services and not Schwab’s services
that benefit only us.
When feasible Access will aggregate client trades, and prices shall be allocated evenly among
participating client accounts.
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Brochure
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SEC File No.: 801-60406
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Item 13 - Review of Accounts
Investment Advisory Services
While accounts are monitored on an ongoing basis, we perform specific quarterly account reviews for
clients who receive our Investment Advisory Services. However, if market conditions or other factors
require it, we may conduct reviews more frequently. In addition, changes in tax laws, new investment
information, or changes in a client's personal circumstances may trigger a review. We encourage all
our investment advisory clients to discuss their needs, goals, and objectives with us and to keep their
investment advisory representative informed of any changes.
As part of our service, all investment advisory clients receive written quarterly portfolio reports, which
are reviewed by their Investment Advisory Representative.
Financial Planning Services
As part of our Financial Planning service, we offer an annual review of our clients' financial situation,
which includes updating their budget and cash flow schedules and providing a written report with our
recommendations. This review is conducted when the client renews their FPA on an annual basis. The
client's Investment Advisory Representative (IAR) will review these schedules and the written report
with the client.
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Brochure
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Item 14 - Client Referrals and Other Compensation
A. Economic Benefit Provided by Third Parties for Advice Rendered to Client
Access Wealth receives an economic benefit from Schwab in the form of the support products and
services it makes available to us and other independent investment advisors whose clients maintain
their accounts at Schwab. We benefit from the products and services provided because the cost of
these services would otherwise be borne directly by us, and this creates a conflict. You should consider
these conflicts of interest when selecting a custodian. These products and services, how they benefit
us, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices).
B. Compensation to Non-Advisory Personnel for Client Referrals
In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm provides cash or
non-cash compensation directly or indirectly to unaffiliated persons for testimonials or endorsements
(which include client referrals). Such compensation arrangements will not result in higher costs to the
referred client. In this regard, our firm maintains a written agreement with each unaffiliated person
that is compensated for testimonials or endorsements in an aggregate amount of $1,000 or more (or
the equivalent value in non-cash compensation) over a trailing 12-month period in compliance with
Rule 206 (4)-1 of the Investment Advisers Act of 1940 and applicable state and federal laws. The
following information will be disclosed clearly and prominently to referred prospective clients at the
time of each testimonial or endorsement:
Whether or not the unaffiliated person is a current client of our firm,
A description of the cash or non-cash compensation provided directly or indirectly by our firm
to the unaffiliated person in exchange for the referral, if applicable, and
A brief statement of any material conflicts of interest on the part of the unaffiliated person
giving the referral resulting from our firm’s relationship with such unaffiliated person.
In cases where state law requires licensure of solicitors, our firm ensures that no solicitation fees are
paid unless the solicitor is registered as an investment adviser representative of our firm. If our firm is
paying solicitation fees to another registered investment adviser, the licensure of individuals is the
other firm’s responsibility.
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Item 15 – Custody
Deduction of Advisory Fees
While Access Wealth does not maintain physical custody of client assets (which are maintained by a
qualified custodian, as discussed above), we are deemed to have custody of certain client assets if given
the authority to withdraw assets from client accounts, as further described below under “Third Party
Money Movement.” All of our clients receive account statements directly from their qualified
custodian(s) at least quarterly upon opening of an account. We urge our clients to carefully review
these statements. Additionally, if our firm decides to send its own account statements to clients, such
statements will include a legend that recommends the client compare the account statements received
from the qualified custodian with those received from our firm. Clients are encouraged to raise any
questions with us about the custody, safety or security of their assets and our custodial
recommendations.
Third Party Money Movement
On February 21, 2017, the SEC issued a no-action letter (“Letter”) with respect to Rule 206(4)-2
(“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided
guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client
funds to a third party under a standing letter of authorization (“SLOA”) is deemed to have custody. As
such, our firm has adopted the following safeguards in conjunction with our custodian:
The client provides an instruction to the qualified custodian, in writing, that includes the client’s
signature, the third party’s name, and either the third party’s address or the third party’s
account number at a custodian to which the transfer should be directed.
The client authorizes the investment adviser, in writing, either on the qualified custodian’s form
or separately, to direct transfers to the third party either on a specified schedule or from time to
time.
The client’s qualified custodian performs appropriate verification of the instruction, such as a
signature review or other method to verify the client’s authorization, and provides a transfer of
funds notice to the client promptly after each transfer.
The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
The investment adviser has no authority or ability to designate or change the identity of the
third party, the address, or any other information about the third party contained in the client’s
instruction.
The investment adviser maintains records showing that the third party is not a related party of
the investment adviser or located at the same address as the investment adviser.
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Brochure
IARD/CRD No. 112973
SEC File No.: 801-60406
March 2026
The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
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Brochure
IARD/CRD No. 112973
SEC File No.: 801-60406
March 2026
Item 16 - Investment Discretion
Access Wealth will manage your accounts on a discretionary basis. This means that we have the
authority to trade securities in your account without obtaining your prior consent for each trade.
However, we will still follow the investment objectives and guidelines set forth in your agreement and
take into account any restrictions or preferences you have communicated to us. We do not have
discretion over the withdrawal or transfer of funds from your account.
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March 2026
Item 17 - Voting Client Securities
Access Wealth does not vote proxies on behalf of clients as part of our firm policy. Clients are
responsible for voting their own proxies, and proxies and solicitations are sent to clients directly by the
custodian or issuing company. If a client requests assistance with voting proxies, we will provide
recommendations to them. However, if a conflict of interest exists, we will disclose it to the client.
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SEC File No.: 801-60406
March 2026
Item 18 - Financial Information
Access Wealth does not foresee any financial condition that would impair our ability to meet
contractual commitments to clients.
Additionally, we do not require or solicit payment of fees more than $1,200 per client more than six
months in advance of services rendered.
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