Overview
- Headquarters
- Sarasota, FL
- Total Firm Assets
- $111 million
- Average High-Net-Worth Client Portfolio Size
- $1.7 million
- Minimum Account Size
- $500,000
Fee Structure
Primary Fee Schedule (FORM ADV PART 2A/2B BROCHURE & BROCHURE SUPPLEMENT)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $250,000 | 2.00% |
| $250,001 | $500,000 | 1.50% |
| $500,001 | $1,000,000 | 1.25% |
| $1,000,001 | $4,000,000 | 1.00% |
| $4,000,001 | $7,000,000 | 0.75% |
| $7,000,001 | and above | 0.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $15,000 | 1.50% |
| $5 million | $52,500 | 1.05% |
| $10 million | $82,500 | 0.82% |
| $50 million | $282,500 | 0.56% |
| $100 million | $532,500 | 0.53% |
Clients
- High-Net-Worth Share of Firm Assets
- 47.59%
- Number of High-Net-Worth Clients
- 31
- Total Client Accounts
- 520
- Discretionary Accounts
- 520
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection, Educational Seminars
Regulatory Filings
- SEC CRD Number
- 284438
Primary Brochure: FORM ADV PART 2A/2B BROCHURE & BROCHURE SUPPLEMENT (2026-08-17)
View Document Text
Advanced Wealth Management, LLC
1990 Main Street
Suite 750
Sarasota, FL 34236
941-451-8512
service@awmfl.com
www.awmfl.com
Date of Disclosure Brochure: August 17, 2026
Advanced Wealth Management, LLC Form ADV Part 2A
Item 1 – Cover Page
This Form ADV Part 2 A Disclosure Brochure provides information about the qualifications and business
practices of Advanced Wealth Management, LLC. (also referred to as we, us and Advanced Wealth
Management or AWM throughout this disclosure brochure). If you have any questions about the contents
of this disclosure brochure, please contact Antonio P. Gomes, Advanced Wealth Management, LLC,
Managing Member, at 941-451-8512 or service@awmfl.com. The information
in this disclosure brochure has not been approved or verified by the United States Securities and Exchange
Commission or by any state securities authority.
Additional information about Advanced Wealth Management is also available on the Internet at
www.adviserinfo.sec.gov. You can view our firm's information on this website by searching for Advanced
Wealth Management, LLC. or our firm's CRD number 284438.
Registration as an investment adviser does not imply a certain level of skill or training.
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Item 2 - Material Changes
Advanced Wealth Management, LLC ("AWM" or the "Firm") is filing this interim amendment to update material
information in its Disclosure Brochure. Since the Firm's April 29, 2026 Disclosure Brochure, the following material
changes have occurred:
- Item 4 - Advisory Business (SEC Registration): AWM transitioned from registration as a Florida state-registered
investment adviser to registration with the United States Securities and Exchange Commission, effective July 1,
2026. The Firm remains subject to applicable state notice-filing and investment adviser representative requirements.
- Item 4 - Advisory Business (Regulatory Assets Under Management): As of August 14, 2026, AWM manages
$126,221,130 in regulatory assets under management, all on a discretionary basis. The Firm manages $0 on a
non-discretionary basis.
- Items 4, 10, 11, 15, and 18 - Regulatory References: The Brochure has been updated to reflect AWM's SEC registration
and to remove or revise references that applied specifically to the Firm while it was state-registered in Florida.
The Firm will provide clients with a summary of material changes as required by applicable law and will provide the
current Disclosure Brochure without charge upon request.
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Item 3 - Table of Contents
Item 1 – Cover Page .................................................................................................................. 1
Item 2 - Material Changes .......................................................................................................... 2
Item 3 - Table of Contents .......................................................................................................... 3
Item 4 - Advisory Business ......................................................................................................... 4
Item 5 - Fees and Compensation ..............................................................................................11
Item 6 - Performance-Based Fees and Side-By-Side Management ..........................................20
Item 7 - Types of Clients ...........................................................................................................20
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ......................................20
Item 9 - Disciplinary Information ................................................................................................26
Item 10 - Other Financial Industry Activities and Affiliations ......................................................26
Item 11 - Code of Ethics, Participation in Client Transactions and Personal Trading .................28
Item 12 - Brokerage Practices ...................................................................................................29
Item 13 - Review of Accounts ....................................................................................................33
Item 14 - Client Referrals and Other Compensation ..................................................................34
Item 15 - Custody ......................................................................................................................35
Item 16 - Investment Discretion .................................................................................................36
Item 17 - Voting Client Securities ..............................................................................................37
Item 18 - Financial Information ..................................................................................................37
Item 19 - Requirements for State-Registered Advisers ..............................................................37
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Item 4 - Advisory Business
Advanced Wealth Management, LLC ("AWM" or the "Firm") is registered as an investment adviser with the
United States Securities and Exchange Commission. The Firm maintains its principal office in Sarasota, Florida
and is organized as a limited liability company under the laws of the State of Florida. AWM is also subject to
applicable state notice-filing and investment adviser representative requirements in jurisdictions where such
requirements apply.
AWM also uses the trade name Boutique Family Office in certain marketing, educational, and client/prospect
communications. Boutique Family Office is a trade name of AWM and is not a separate registered investment
adviser.
AWM operates primarily through a virtual and remote-service model. The Firm maintains a business/mailing
address in Sarasota, Florida and may use office or meeting space on an as-needed basis for client meetings,
administrative purposes, or other business activities.
- Antonio P. Gomes is the Managing Member and 100% owner of Advanced Wealth Management.
Additional information regarding Antonio P. Gomes's education and business background is provided in his
Form ADV Part 2B Brochure Supplement.
- AWM was registered as an investment adviser with the Florida Office of Financial Regulation beginning in
August 2016 and transitioned to SEC registration effective July 1, 2026.
• AWM, in furtherance of providing investors with additional resources and information,
maintains the following websites and social media sites:
o https://www.awmfl.com/;
o https://www.boutiquefamilyofficecfo.com;
o https://www.bfocfo.com;
o https://www.instagram.com/awmfl/;
o https://www.facebook.com/advancedwealthmanagementllc;
o https://www.facebook.com/boutiquefamilyoffice;
o https://www.facebook.com/bfocfo;
o https://www.youtube.com/@awmfl; and
o https://www.linkedin.com/company/advanced-wealth-management/
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Introduction
The investment advisory services of Advanced Wealth Management are provided through
individuals who are registered or otherwise qualified as investment adviser representatives of the
Firm, as required by applicable law. Each investment adviser representative is required to meet
the licensing and qualification standards applicable under federal and state securities regulations.
AWM and its investment adviser representatives seek registration, notice filing, or other required
regulatory status in additional jurisdictions when required based on the Firm’s advisory
activities, clients, or prospective clients.
The Firm periodically hosts complimentary educational seminars and workshops for clients and
prospective clients. These events are educational in nature, are not used to recommend specific
securities or investment products, and no fees are charged for attendance. Attendance does not
obligate any attendee to engage the Firm for advisory services.
Description of Advisory Services
The following are descriptions of the primary advisory services of Advanced Wealth
Management.
Please understand that a written agreement, which details the exact terms of the service, must be
signed by you and Advanced Wealth Management before we can provide you the services
described below.
Asset Management Services
Advanced Wealth Management offers asset management services, which involves Advanced
Wealth Management providing you with continuous and ongoing supervision over your specified
accounts.
You must appoint our firm as your investment adviser of record on specified accounts
(collectively, the "Account"). The Account consists only of separate account(s) held by qualified
custodian(s) under your name. The qualified custodians maintain physical custody of all funds
and securities of the Account, and you retain all rights of ownership (e.g., right to withdraw
securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the
Account.
The Account is managed by us based on your financial situation, investment objectives and risk
tolerance. We actively monitor the Account and provide advice regarding buying, selling,
reinvesting or holding securities, cash or other investments of the Account.
We will need to obtain certain information from you to determine your financial situation and
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investment objectives. You will be responsible for notifying us of any updates regarding your
financial situation, risk tolerance or investment objective and whether you wish to impose or
modify existing investment restrictions; however, we will contact you at least annually to discuss
any changes or updates regarding your financial situation, risk tolerance or investment
objectives. We are always reasonably available to consult with you relative to the status of your
Account. You have the ability to impose reasonable restrictions on the management of your
accounts, including the ability to instruct us not to purchase certain securities.
It is important that you understand that we manage investments for other clients and provide
advice or take actions for them, or for our personal accounts, that may be different from the
advice we provide to you or the actions we take for you. We are not obligated to buy, sell or
recommend to you any security or other investment that we may buy, sell or recommend for any
other clients or for our own accounts.
Conflicts can arise in the allocation of investment opportunities among accounts that we manage.
We strive to allocate investment opportunities believed to be appropriate for your account(s) and
other accounts advised by our firm among such accounts equitably and consistent with the best
interests of all accounts involved. However, there can be no assurance that a particular
investment opportunity that comes to our attention will be allocated in any particular manner. If
we obtain material, non-public information about a security or its issuer that we are not permitted
to lawfully use or disclose, we have absolutely no obligation to disclose the information to any
client or use it for any client's benefit.
Rollovers
As part of our investment advisory services, AWM may recommend that a client roll assets from
an employer-sponsored retirement plan to an individual retirement account (“IRA”) when we
determine that doing so is in the client’s best interest. Rollover recommendations are made in
accordance with AWM’s fiduciary obligations and applicable retirement account rules, including
ERISA where applicable.
If a client rolls assets to an IRA managed by AWM, the Firm will charge an advisory fee on
those assets as set forth in the applicable Advisory Agreement. This creates a conflict of interest
because AWM and its representatives have a financial incentive to recommend a rollover that
results in assets being managed by the Firm. Clients are under no obligation to complete a
rollover or to have rollover assets managed by AWM. Clients may also choose to leave assets in
an employer-sponsored plan, roll assets to another provider, or consult another financial
professional regarding available options.
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Financial Planning & Consulting Services
Advanced Wealth Management offers financial planning services, which involve preparing a
written financial plan covering specific, or multiple topics. We provide full written financial
plans, which typically address the following topics: Investment Planning, Retirement Planning,
Insurance and Protection Planning, Corporate and Personal Tax Planning and Management,
Portfolio Review, Estate and Charitable Planning, Education Planning and Funding,
Mortgage/Debt Analysis, Business and Personal Financial Planning (including Business
Consulting Services), and Asset Allocation. Our written plans include general recommendations
for actions to be taken, such as revising investment programs, creating or revising wills or trusts,
or establishing education or charitable programs. When providing financial planning and
consulting services, the role of your investment adviser representative is to find ways to help you
understand your overall financial situation and help you set financial objectives. Written
financial plans prepared by us do not include specific recommendations of individual securities.
When appropriate, AWM may assist clients with developing or reviewing an Investment Policy
Statement (“IPS”) to help document investment objectives, risk tolerance, allocation guidelines,
restrictions, or other relevant investment considerations. AWM may also review an IPS provided
by a client and determine whether the guidelines are consistent with the Firm’s advisory services
and the client’s objectives.
We also offer consultations in order to discuss financial planning issues when you do not need a
written financial plan. We offer a one-time consultation, which covers mutually agreed upon
areas of concern related to investments or financial planning. We also offer "as-needed"
consultations, which are limited to consultations in response to a particular investment or
financial planning issue raised or request made by you. Under an "as-needed" consultation, it
will be incumbent upon you to identify those issues for which you are seeking our advice or
consultation.
Our financial planning and consulting services do not involve implementing any transaction on
your behalf or the active and ongoing monitoring or management of your investments or
accounts. You have the sole responsibility for determining whether to implement our financial
planning and consulting recommendations. To the extent that you would like to implement any
of our investment recommendations through Advanced Wealth Management or retain Advanced
Wealth Management to actively monitor and manage your investments, you must execute a
separate written agreement with Advanced Wealth Management for our asset management
services.
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For clients who engage the Firm for asset management services under a fixed-fee arrangement,
comprehensive financial planning services are bundled into the overall advisory relationship at
no additional cost. In these instances, no separate financial planning agreement or additional
planning fee applies. This integrated service allows for a holistic approach, coordinating
investment management with a comprehensive review of the client’s broader financial goals and
objectives as part of the primary advisory engagement.
Limits Advice to Certain Types of Investments
Advanced Wealth Management provides investment advice on the following types of
investments:
• Mutual Funds
• Exchange Traded Funds (ETFs)
• Exchange Traded Notes (ETNs)
• Structured Investment Products
• Exchange-listed Securities
• Non-Exchange Traded Securities
• Master Limited Partnerships
• Securities Traded Over the Counter
• Foreign Issues (e.g. ADRs)
• Corporate Debt Securities
• Alternative Investments
• Commercial Paper
• Certificates of Deposit
• Variable Annuities
• Variable Life Insurance
• US Government Securities
• Equity Index Annuities
• Equity Index Universal Life
• Long Term Care Insurance
AWM primarily provides advice on the investment products and strategies listed above. When
appropriate, AWM may provide advice on other investment products or strategies that are
consistent with a client’s specific circumstances, needs, goals, objectives, risk tolerance, and
advisory agreement.
AWM does not generally attempt to time the market as a primary investment strategy. However,
AWM may increase cash holdings, adjust asset allocations, or use ETFs or other investment
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vehicles for risk-management, liquidity, or hedging purposes when the Firm determines that such
actions are appropriate based on a client’s objectives, risk tolerance, time horizon, liquidity
needs, and market conditions. We may modify our investment strategy to accommodate special
situations such as low basis stock, stock options, legacy holdings, inheritances, closely held
businesses, collectibles, or special tax situations.
(Please refer to Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss for more
information.)
Tailor Advisory Services to Individual Needs of Clients
Advanced Wealth Management's advisory services are always provided based on your individual
needs. This means, for example, that when we provide asset management services, you are given
the ability to impose reasonable restrictions on the accounts we manage for you, including
specific investment selections and sectors. We work with you on a one-on-one basis through
interviews and questionnaires to determine your investment objectives and suitability
information. Our financial planning and consulting services are always provided based on your
individual needs. When providing financial planning and consulting services, we work with you
on a one-on-one basis through interviews and questionnaires to determine your investment
objectives and suitability information.
We will not enter into an investment adviser relationship with a prospective client whose
investment objectives may be considered incompatible with our investment philosophy or
strategies or where the prospective client seeks to impose unduly restrictive investment
guidelines.
Selection of Other Advisors
Advanced Wealth Management recommends that certain clients use the services of a third-party
money manager (“TPMM”) to manage all, or a portion of, their investment portfolio when the
Firm determines that a TPMM is appropriate for the client’s needs, objectives, and
circumstances. After gathering information about our clients' financial situation and objectives,
the Firm recommends a specific TPMM or investment program when the Firm determines that
the TPMM or program is appropriate for the client. Factors that we take into consideration when
making our recommendation(s) include, but are not limited to, the following: the TPMM's
performance, methods of analysis, fees, our clients' financial needs, investment goals, risk
tolerance, and investment objectives. We will monitor the TPMM(s) performance to ensure its
management and investment style remains aligned with our clients' investment goals and
objectives. We will assume discretionary authority to hire and fire TPMM(s) and/or reallocate
our clients' assets to other TPMM(s) where we deem such action appropriate.
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AWM has professional relationships with multiple TPMMs inclusive of the following
organizations primarily to assist in portfolio management and trading activities on behalf of our
Firm's SMA client accounts:
• Advyzon Investment Management, LLC ("AIM"), an Illinois-based SEC-registered
investment adviser and turnkey asset management program service provider. AIM is able to
manage all or a portion of AWM's SMA client assets through its turnkey asset management
program (the "Program"). AIM, in furtherance of its Program, will evaluate the investor's
financial situation, investment objectives, financial goals, tolerance for risk, and investment
time horizon to assist in determining the appropriate Investment Strategy for the management
of your assets.
• Vise AI Advisors, LLC ("Vise AI") has been engaged on behalf of our separately managed
account ("SMA") clients as one of our TPMM's. Vise AI is a registered investment adviser
primarily based in San Francisco, California, and focused on creating equity portfolios for
registered investment advisers. Their mission is to help investment advisers grow their
client's wealth by providing access to diverse investment options. Vise AI offers
discretionary investment advisory services that are delivered through an automated and
interactive web- based investment management system to registered investment advisers
("RIAs"). The investment advice rendered is tailored to meet with the client investment needs
and objectives and is delivered exclusively based upon information we submit via a web-
based investment questionnaire. Those responses to the electronic investment questionnaire
are used by the web-based system to create an equity model portfolio based on the clients'
risk profile. After submission of the online investment questionnaire, the Vise AI technology
platform will provide automated portfolios that may include exchange traded funds ("ETFs"),
mutual funds, and/or individual debt or equity securities to Advanced Wealth Management. It
is then our responsibility to determine whether the model is appropriate for our client. Once
we select the portfolio model for our client, the platform system we utilize will automatically
process the transactions necessary to institute the originally constructed model and then
generate investment instructions necessary to maintain the asset allocations of the model. In
providing investment advisory services through the system, all information will be provided
through their web-based system. Vise AI does not verify any information they receive from
us or our agent(s) for accuracy, and they will rely on the information we provide. It is our
responsibility to promptly update our client's account application through the web-based
portal if there are ever any changes in our client's financial situation or investment objectives.
Vise AI routinely and actively monitors client investments and, based on the client’s risk
profile, recommends changes through the web-based system when appropriate.
• Finiat LLC ("Finiat") is an SEC-registered internet adviser based in Florida that provides
outsourced chief investment officer ("OCIO") services, Finiat's interactive website provides
portfolio models and investment instructions to institutional investors such as AWM to assist
with portfolio management and trading directives for underlying retail clients. Finiat charges
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OCIO service fees directly to AWM. AWM does not separately invoice clients for Finiat’s
OCIO fees; instead, those costs are incorporated into the management fees assessed by AWM
to applicable SMA clients.
Advisory fees charged by TPMMs are separate and apart from our advisory fees. Advisory fees
that you pay to the TPMM are established and payable in accordance with the brochure provided
by each TPMM to whom you are referred. The negotiability of TPMM fees depends on the
applicable TPMM’s fee schedule, program terms, and client arrangement. You should review the
recommended TPMM's brochure and take into consideration TPMM's fees along with our fees to
determine the total amount of fees associated with this program.
Participant Account Management
We use a third-party platform to facilitate management of held away assets such as defined
contribution plan participant accounts, with discretion. The platform allows us to avoid being
considered to have custody of Client funds since we do not have direct access to Client log-in
credentials to affect trades. We are not affiliated with the platform in any way and receive no
compensation from them for using their platform. A link will be provided to the Client allowing
them to connect an account(s) to the platform. Once Client account(s) is connected to the
platform, Advanced Wealth Management will review the current account allocations. Advanced
Wealth Management rebalances the account when appropriate based on the client’s investment
goals, risk tolerance, current economic conditions, and market trends. The goal is to improve
account performance over time, minimize loss during difficult markets, and manage internal fees
that harm account performance. Client account(s) will be reviewed at least quarterly and
allocation changes will be made when appropriate.
Client Assets Managed by Advanced Wealth Management
As of August 14, 2026, Advanced Wealth Management, LLC manages $126,221,130 in regulatory assets under
management on a discretionary basis. The Firm manages $0 on a non-discretionary basis.
Item 5 - Fees and Compensation
In addition to the information provided in Item 4 -Advisory Business, this section provides
additional details regarding our firm's services along with descriptions of each service's fees and
compensation arrangements. It should be noted that lower fees for comparable service may be
available from other sources. The exact fees and other terms will be outlined in the agreement
between you and Advanced Wealth Management.
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Attendance at the Firm’s educational seminars and workshops is offered on a complimentary
basis. No fees are charged for these events, and participation does not obligate attendees to
engage the Firm for advisory services.
Asset Management Services
Fees charged for our asset management services are based on a percentage of assets under
management, billed in advance (at the start of the billing period) on either a monthly or quarterly
basis, depending on the Client’s arrangement with Adviser, and calculated based on the fair
market value of your account as of the last business day of the previous billing period. Clients
may elect either monthly or quarterly billing in advance, subject to agreement with Adviser. Any
unearned portion of prepaid fees will be refunded to the Client on a pro rata basis upon
termination. AWM, under its advisory agreement, will memorialize the services and applicable
fees imposed to our investors which may include asset-based fees, a flat fee arrangement or
combination of the two; however, our Firm reserves the discretion to authorize the fee
arrangement at the time of onboarding. Fees are prorated (based on the number of days service is
provided during the initial billing period) for your account opened at any time other than the
beginning of the billing period. If asset management services are commenced in the middle of a
billing period, the prorated fee for the initial billing period is billed in advance for the remaining
days in the billing period.
The asset management services continue in effect until terminated by either party (i.e., Advanced
Wealth Management or you) by providing written notice of termination to the other party. Any
prepaid, unearned fees will be refunded to the Client within thirty (30) days of the termination
notice. Fee refunds will be determined on a pro rata basis using the number of days services were
provided during the final billing period. Clients may terminate the agreement within five (5)
business days of execution without penalty.
Advanced Wealth Management's investment advisory fee is based on the market value of assets
held in accounts under management ("AUM") and/or fixed with respect to the type of account or
advisory management provided. Fees charged for our asset management services are negotiable
based on the type of client, the complexity of the client's situation, the composition of the client's
account (i.e., equities versus mutual funds), the potential for additional account deposits, the
relationship of the client with the investment adviser representative, and the total amount of
assets under management for the client.
The annual fee for asset management services will range between 0.50% and 2.00%, according
to the following fee schedule:
Assets Under Management
$100,000 - $250,000
$250,001 - $500,000
Annual Fee
2.0%
1.5%
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$500,001 - $1,000,000
$1,000,001 - $4,000,000
$4,000,001 - $7,000,000
$7,000,001 plus
1.25%
1.00%
0.75%
0.5%
The lower fee tiers may apply to legacy accounts, exception accounts, related household
accounts, or other accounts accepted by the Firm in its discretion.
The asset management fee that will be deducted from your advisory account will be specified in
the Client Agreement.
In addition to asset-based fees, AWM offers a flat annual fee option starting at $5,000 when
appropriate for the client’s advisory arrangement. Flat fees generally will not exceed 2.00% of
AUM under normal circumstances. If a flat-fee arrangement equals or exceeds 3.00% of AUM,
AWM will provide any disclosure required by applicable state law, including Texas State
Securities Board Rule 116.13(a), before entering into the arrangement.
For clients who elect a flat/fixed fee arrangement for asset management services, comprehensive
financial planning services are bundled into the advisory fee at no additional cost; no separate
financial planning agreement or fee applies.
Fees are negotiable based on account size, overall relationship, and client circumstances.
Third-Party Money Management (TPMM) Fees
For clients utilizing the specialized services of a third-party money manager (“TPMM”) or
investment platform, TPMM or platform fees may apply in addition to AWM’s advisory fee.
These fees are established by the applicable TPMM or platform, are separate from AWM’s
advisory fee, and are billed in accordance with the applicable TPMM or platform’s fee schedule
and disclosure brochure.
Current TPMM and platform fees include:
• Vise AI Advisors, LLC: 0.28% of assets under management.
• Envestnet / Advyzon Investment Management (“AIM”) Program: 0.48% of assets under
management.
When a TPMM or platform is used, the total combined investment advisory fee — inclusive of
AWM’s advisory fee and the applicable TPMM or platform fee — will not exceed 2.48% of
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AUM per year. This combined fee cap applies only when a client’s account uses a TPMM or
platform for which an additional TPMM or platform fee is charged.
Custodian and Transaction Fees
In addition to AWM’s advisory fee, clients may incur certain fees and expenses charged directly
by custodians or broker-dealers. For example, custodians may charge for wire transfers,
overnight deliveries, or special services. While Charles Schwab & Co., Inc. (“Schwab”) —
AWM’s primary custodian — does not charge transaction fees for most U.S. equity and
exchange-traded fund trades, other fees, such as fees for certain mutual funds or specialty
services, apply when charged by Schwab, the custodian, broker-dealer, or fund company. These
charges are imposed by the custodian or fund company and are separate from the fees charged by
AWM. AWM does not receive any portion of these fees.
Minimum Account Size
AWM requires a minimum account size of $500,000 to open an advisory account. AWM may
waive or reduce this minimum in its discretion based on the client’s relationship to existing
clients, household or family relationship, personal circumstances, or other factors approved by
the Firm. AWM may combine account values for family members or other related relationships,
where applicable, to meet the stated minimum. AWM does not charge a separate maintenance
fee or other non-advisory account fee solely because an account falls below a stated minimum.
Advanced Wealth Management does not sponsor or otherwise participate in wrap fee programs.
Advanced Wealth Management believes that its annual fee is reasonable in relation to: (1)
services provided and (2) the fees charged by other investment advisers offering similar
services/programs. However, our annual investment advisory fee can be higher than the fees
charged by other investment advisers offering similar services or programs. In addition to our
compensation, clients incur charges imposed at the mutual fund level when they invest in mutual
funds or other investment company securities, including advisory fees and other fund expenses.
The investment advisory fees will be deducted from your account and paid directly to our firm
by the qualified custodian(s) of your account. You will authorize the qualified custodian(s) of
your account to deduct fees from your account and pay such fees directly to our firm. Our firm
will send you a billing statement prior to time that fee deduction instruction is sent to the
qualified custodian(s) of your account. The billing statement will detail the formula used to
calculate the fee, the assets under management on which the fee is based, and the time period
covered. You should review your account statements received from the qualified custodian(s)
and verify that appropriate investment advisory fees are being deducted. The qualified
custodian(s) will not verify the accuracy of the investment advisory fees deducted.
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Brokerage commissions and/or transaction ticket fees charged by the qualified custodian are
billed directly to you by the qualified custodian. Advanced Wealth Management does not receive
any portion of such commissions or fees from you or the qualified custodian. In addition, you
may incur certain charges imposed by third parties other than Advanced Wealth Management in
connection with investments made through your account including, but not limited to, mutual
fund sales loads, 12(b)-1 fees and surrender charges, variable annuity fees and surrender charges,
IRA and qualified retirement plan fees, and charges imposed by the qualified custodian(s) of
your account. Management fees charged by Advanced Wealth Management are separate and
distinct from the fees and expenses charged by investment company securities that may be
recommended to you. A description of these fees and expenses is available in each investment
company security's prospectus.
Assets Included in Fee Calculation
AWM, as an accommodation, accepts portfolio holdings that were acquired by clients before
onboarding with the Firm (“Legacy Assets”). Legacy Assets are identified to clients in writing
and are included in the Firm’s fee calculation unless otherwise agreed in writing. The Firm
includes cash in a client’s account when determining the valuation for billing purposes unless
otherwise agreed in writing. Held-away accounts, including employer-sponsored retirement plan
accounts, self-directed brokerage accounts, health savings brokerage accounts, or other accounts
not held at the Firm’s primary custodian, may be included in the client’s household AUM for
billing purposes when AWM provides advisory or management services for those assets, unless
otherwise agreed in writing. Any exclusions from the fee calculation, including exclusions for
certain client holdings, held-away assets, accommodation accounts, alternative investments, or
cash positions, will be discussed with the client and documented in the applicable Client
Agreement or other written fee disclosure.
Financial Planning & Consulting Services
Fees charged for our financial planning and consulting services are negotiable based upon the
type of client, the services requested, the complexity of the client's situation, the composition of
the client's account, other advisory services provided and the relationship of the client and the
investment adviser representative. The following are the fee arrangements available for financial
planning and consulting services offered by Advanced Wealth Management.
Fees for Financial Planning Services
Advanced Wealth Management provides financial planning services under an hourly fee
arrangement. An hourly fee of $500 per hour is charged by Advanced Wealth Management for
financial planning services under this arrangement. Before commencing financial planning
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services, Advanced Wealth Management provides an estimate of the approximate hours needed
to complete the requested financial planning services. If Advanced Wealth Management
anticipates exceeding the estimated amount of hours required, Advanced Wealth Management
will contact you to receive authorization to provide additional services. You will pay in advance
a mutually agreed upon retainer that will be available for Advanced Wealth Management to bill
hourly fees against for our financial planning services; however, under no circumstances will
Advanced Wealth Management require you to pay fees more than $500 more than six months in
advance. The standard billing dates and events of Advanced Wealth Management are the
following: (1) the first business day of each month; (2) the date when incurred hourly fees and
expenses will cause the retainer balance to be depleted to zero; (3) the date or thereafter that
Advanced Wealth Management substantially provides the agreed upon services; and (4) the date
the engagement is terminated by either you or Advanced Wealth Management. Upon
presentment of the invoice to you, Advanced Wealth Management will deduct the hourly fees
due Advanced Wealth Management against your current retainer balance, and you are required to
pay immediately Advanced Wealth Management any outstanding balance of hourly fees due.
Advanced Wealth Management also provides financial planning services under a fixed fee
arrangement. A mutually agreed upon fixed fee is charged for financial planning services under
this arrangement. There is a range in the amount of the fixed fee charged by Advanced Wealth
Management for financial planning services. The minimum fixed fee is generally $500, and the
maximum fixed fee is generally no more than $5,000. The amount of the fixed fee for your
engagement is specified in your financial planning agreement with Advanced Wealth
Management. At our sole discretion, you may be required to pay in advance of the fixed fee at
the time you execute an agreement with Advanced Wealth Management; however, at no time
will Advanced Wealth Management require payment of more than $500 in fees more than six
months in advance. Upon completion and delivery of the financial plan, the fixed fee is
considered earned by Advanced Wealth Management. In the event of early termination, the
earned portion of a prepaid fixed fee is calculated by determining the actual hours worked
multiplied by the $500 hourly rate, as detailed in the Refund Policy below. Any unpaid earned
balance is immediately due.
The financial planning services terminate upon delivery of the written financial plan or upon
either party providing the other party with written notice of termination.
Termination and Refund Policy for Financial Planning Services
Clients may terminate the financial planning agreement within five (5) business days of
execution without penalty. For any fees paid in advance, the earned portion is determined by
multiplying actual hours worked by the Firm’s $500 hourly rate, billed in 15-minute increments.
Any remaining unearned balance is refunded to the Client within thirty (30) days of the
termination notice.
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Fees for Consulting Services
Advanced Wealth Management provides consulting services under an hourly fee arrangement.
An hourly fee of $500 per hour is charged by Advanced Wealth Management for consulting
services. Before providing consulting services, Advanced Wealth Management will provide an
estimate of the approximate hours needed to complete the consulting services. If Advanced
Wealth Management anticipates exceeding the estimated number of hours required, Advanced
Wealth Management will contact you to receive authorization to provide additional services.
You may be requested to pay in advance a mutually agreed upon retainer that will be available
for Advanced Wealth Management to bill hourly fees against for our consulting services;
however, under no circumstances will Advanced Wealth Management require you to pay fees
more than $500 more than six months in advance. The standard billing dates and events of
Advanced Wealth Management are the following: (1) the first business day of each month; (2)
the date when incurred hourly fees will cause the retainer balance to be depleted to zero; (3) the
date or thereafter that Advanced Wealth Management substantially provides the agreed upon
services; and (4) the date the engagement is terminated by either you or Advanced Wealth
Management. Upon presentment of the invoice to you, Advanced Wealth Management will
deduct the hourly fees due Advanced Wealth Management against your current retainer balance,
and you will immediately pay Advanced Wealth Management any outstanding balance of hourly
fees due.
Advanced Wealth Management also provides consulting services under a fixed fee arrangement.
This may include one-time project-based consultations or ongoing consulting services that renew
annually. A mutually agreed upon fixed fee is charged for consulting services under this
arrangement. There is a range in the amount of the fixed fee charged by Advanced Wealth
Management for consulting services. The minimum annual fixed fee for consulting services will
be $500, and the maximum annual fixed fee will be generally no more than $5,000. The amount
of the fixed fee for your engagement is specified in your consulting agreement with Advanced
Wealth Management. At our sole discretion, you may be required to pay in advance of the fixed
fee at the time you execute an agreement with Advanced Wealth Management. At no time will
Advanced Wealth Management require payment of more than $500 in fees more than six months
in advance. The fixed fee will be considered earned by Advanced Wealth Management upon the
completion of the consulting services or substantial completion of the annual service period.
Should the engagement be terminated before completion, the earned portion of any prepaid fixed
fee will be calculated using the 'Actual Hours x $500' methodology described in the Termination
and Refund Policy below.
The one-time consulting services will terminate upon completion of the consultation or either
party providing the other party with written notice. The "as-needed" consulting services will
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terminate upon either you or Advanced Wealth Management providing written notice of
termination to the other party.
Termination and Refund Policy for Consulting Services
Clients may terminate consulting services within five (5) business days of entering into an
agreement without penalty or fees due. For consulting services that automatically renew on an
annual basis, the engagement remains continuous until terminated by either party providing
thirty (30) days’ written notice. If you terminate after five (5) business days, you are responsible
for payment of work performed prior to notice. For hourly arrangements, you pay the incurred
hourly fees. For fixed-fee arrangements, you pay an early termination fee based on actual hours
worked multiplied by the $500 hourly rate, billed in 15-minute increments. Any remaining
balance of prepaid fees will be refunded to you within thirty (30) days of the termination notice.
Other Fee Terms for Financial Planning & Consulting Services
You may pay the investment advisory fees owed for the financial planning services by
submitting payment directly (for example, by check) or having the fee deducted from an existing
investment account.
If you elect to pay by automatic deduction from an existing investment account, you will provide
written authorization to Advanced Wealth Management for such charge.
You should notify Advanced Wealth Management within ten (10) days of receipt of an invoice if
you have questions about or dispute any billing entry.
To the extent Advanced Wealth Management engages an outside professional, such as an
attorney, independent investment adviser, or accountant, to assist the Firm in providing financial
planning or consulting services, Advanced Wealth Management will be responsible for the fees
of that outside professional unless otherwise agreed to in writing by the Client. To the extent that
the Client personally engages an outside professional, the Client will be responsible for the fees
charged by that outside professional, and those fees will be separate from and in addition to the
fees charged by Advanced Wealth Management. In no event will Advanced Wealth Management
engage an outside professional on behalf of the Client without the Client’s express approval.
Insurance and Annuity Compensation
In addition to advisory fees, AWM and/or certain investment adviser representatives may receive
compensation when insurance or annuity products are recommended and implemented, including
life insurance, disability insurance, long-term care insurance, fixed annuities, indexed annuities,
variable annuities, 1035 exchanges, annuity replacements, and restructuring of existing insurance
or annuity contracts. Depending on the product and arrangement, compensation may be received
through insurance commissions paid by insurance companies or through advisory fees on fee-
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based annuity products.
Insurance commissions, annuity compensation, surrender charges, mortality and expense
charges, rider charges, administrative fees, and other insurance-company fees are separate from
and in addition to advisory fees charged by AWM, unless otherwise disclosed in writing. The
receipt of insurance commissions or advisory fees creates a conflict of interest because AWM
and/or its representatives have a financial incentive to recommend insurance or annuity products
or transactions that generate compensation.
Clients are under no obligation to implement any insurance or annuity recommendation through
AWM or its representatives and may purchase insurance or annuity products through any
insurance agent, insurance agency, or insurance company of their choosing.
If you retain Advanced Wealth Management to implement the recommendations provided under
this service, Advanced Wealth Management will not generally recommend load or no-load
mutual funds that charge you 12(b)-1 fees except where no other share class in the fund selection
exists or there is not a suitable alternative. Should a 12b-1 fee be applicable to the fund offering,
Advanced Wealth Management will not receive any portion of these fees charged to advisory
accounts.
Fees paid to Advanced Wealth Management for financial planning and consulting services are
separate and distinct from brokerage commissions, transaction charges, asset management fees,
insurance-company fees, annuity charges, and other costs that may be incurred if a client
implements recommendations through AWM or another provider.
It should be noted that lower fees for comparable services may be available from other sources.
Other Fees and Charges
In addition to compensation paid to Advanced Wealth Management, Clients incur charges
imposed at the mutual fund or investment company level when applicable, including advisory
fees and other fund expenses. A description of these fees and expenses is available in each
investment company security’s prospectus. Clients also incur brokerage commissions,
transaction ticket fees, custodial fees, and other charges imposed by the qualified custodian,
broker-dealer, fund company, insurance company, or other third parties, when applicable. These
charges include, but are not limited to, mutual fund sales loads, 12b-1 fees, surrender charges,
variable annuity fees and surrender charges, IRA and qualified retirement plan fees, and charges
imposed by the qualified custodian(s) of the Account.
Except as otherwise disclosed in this Brochure with respect to insurance or annuity
compensation, Advanced Wealth Management does not receive any portion of fees charged by
qualified custodians, broker-dealers, fund companies, or other third-party service providers.
Management fees charged by Advanced Wealth Management are separate and distinct from the
fees and expenses charged by investment company securities recommended to Clients.
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Item 6 - Performance-Based Fees and Side-By-Side Management
Performance-based fees are fees based on a share of capital gains or capital appreciation of the
assets held in a client's account. Advanced Wealth Management does not charge or accept
performance-based fees.
Item 7 - Types of Clients
Advanced Wealth Management provides investment advice to the following types of clients:
• Individuals
• High net worth individuals
• Charitable Organizations
• Foundations
• Pension Plans
• Institutional Investors
Clients are required to execute a written agreement with Advanced Wealth Management
specifying the advisory services to be provided in order to establish a client relationship with the
Firm.
Minimum Investment Amounts Required
Advanced Wealth Management requires a minimum of $500,000 to open an advisory account.
To meet this minimum, clients can aggregate household accounts.
The minimum fee charged for financial planning services provided on an hourly basis is $500.
The minimum fixed fee charged for financial planning services on a fixed fee basis is $500.
The minimum hourly fee charged for consulting services is $500. The minimum fixed fee
charged for consulting services is $500.
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Advanced Wealth Management uses one or more of the following methods of analysis when
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formulating investment advice, reviewing client portfolios, and making allocation or investment
recommendations:
Fundamental Analysis - AWM may review financial, economic, issuer-specific, industry,
valuation, income, balance sheet, credit, and other relevant information when evaluating
investments. Fundamental analysis involves the risk that the information reviewed may be
incomplete, inaccurate, outdated, or interpreted incorrectly, and that an investment may perform
differently than expected.
Technical and Market Analysis - AWM may review market data, price trends, trading volume,
volatility, interest rate trends, sector movement, and other market indicators when evaluating
whether to buy, sell, hold, or rebalance investments. AWM does not rely on technical analysis as
a guarantee of future results. Technical and market indicators may be unreliable, may change
quickly, and may result in incorrect timing or allocation decisions.
Cyclical and Macroeconomic Analysis - AWM may consider economic cycles, interest rate
conditions, inflation, employment trends, consumer activity, market valuations, geopolitical
conditions, and other macroeconomic factors when evaluating portfolio positioning. Economic
and market cycles are difficult to predict, and allocation decisions based on macroeconomic
views may be early, late, or incorrect.
Third-Party Research and Platform Analysis - AWM may use research, data, model portfolios,
portfolio analytics, investment platform information, custodian resources, fund materials,
prospectuses, offering documents, SEC filings, rating services, and other third-party information.
AWM reviews this information as part of its advisory process, but third-party information may
be incomplete, inaccurate, delayed, or subject to the judgment and limitations of the provider.
There are risks involved in using any method of analysis, and no analysis method can guarantee
investment results or prevent losses.
Investment Strategies
Advanced Wealth Management uses the following investment strategies when managing client
assets and/or providing investment advice:
Long-term purchases - AWM generally emphasizes long-term investment holdings when
consistent with a client’s objectives, risk tolerance, time horizon, and overall financial
circumstances.
Short-term purchases - AWM may purchase or sell investments within a shorter time period
when the Firm determines that market conditions, client objectives, risk considerations, tax
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factors, liquidity needs, or other circumstances make such activity appropriate.
Short-term or tactical trading - Although AWM does not engage in day trading or frequent
trading as a primary investment strategy, the Firm may, on an infrequent basis, buy or sell
investments over shorter time periods when it determines that doing so is appropriate for a
client’s account.
Tactical asset allocation - AWM may make limited adjustments to a client’s asset allocation
based on market conditions, economic outlook, valuation considerations, risk management,
liquidity needs, or other client-specific circumstances. Tactical allocation does not mean AWM
attempts to predict short-term market movements with certainty. Rather, it allows the Firm to
make measured allocation changes when AWM determines that such changes are appropriate for
the client’s objectives, risk tolerance, and overall financial circumstances.
Strategic asset allocation - AWM generally uses strategic asset allocation as a long-term
portfolio framework. This involves establishing target allocations among asset classes based on
the client’s investment objectives, risk tolerance, time horizon, income needs, liquidity needs, tax
considerations, and other relevant circumstances. Portfolios may be reviewed and rebalanced
periodically or as circumstances warrant to help maintain alignment with the client’s objectives.
Strategic allocation targets may change over time as the client’s goals, needs, risk profile, or
financial circumstances change.
Material Risks of Investment Strategies
Each investment strategy utilized by Advanced Wealth Management involves material risks.
Clients should carefully consider the following risks associated with our primary strategies:
● Long-Term Purchases: Securities purchased with the intent to hold for more than one year
are subject to market risk, company-specific risk, and inflation risk. Extended holding
periods do not protect against market downturns and can expose investors to losses in
purchasing power over time.
● Short-Term Purchases: Securities purchased with the intent to sell within one year are
subject to volatility and market timing risk. Shorter holding periods can increase transaction
costs and can result in reduced after-tax returns.
● Short-Term or Tactical Trading: Short-term or tactical trading can increase transaction
costs, create tax consequences, and result in losses if market conditions change unexpectedly.
Because these trades may be based on market, economic, or security-specific judgments,
there is a risk that those judgments may be incorrect or that the trade may underperform a
longer-term investment approach.
● Tactical or Strategic Allocation: Tactical and strategic allocation strategies involve the risk
that the selected mix of asset classes, sectors, or investments may underperform other
available allocations or fail to achieve the client’s objectives. Tactical adjustments may be
based on market, economic, valuation, or risk-management judgments that prove incorrect.
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Strategic allocations may also become less appropriate over time if a client’s goals, risk
tolerance, income needs, liquidity needs, tax circumstances, or time horizon changes.
Rebalancing or allocation changes may result in transaction costs, tax consequences, or
market timing risk. Asset classes intended to diversify a portfolio may also move together
during periods of market stress.
Clients should recognize that investing in securities involves the risk of loss of principal, and
there can be no assurance that any strategy will be successful.
Primarily Recommend One Type of Security
We do not primarily recommend one type of security to clients. Instead, we recommend any
product that may be suitable for each client relative to that client's specific circumstances and
needs.
Risk of Loss
Past performance is not indicative of future results. Therefore, you should never assume that
future performance of any specific investment or investment strategy will be profitable. Investing
in securities (including stocks, mutual funds, and bonds, etc.) involves risk of loss. The degree of
risk varies depending on the type of investment. You should be prepared to bear investment loss
including loss of original principal.
Because of the inherent risk of loss associated with investing, our firm is unable to represent,
guarantee, or even imply that our services and methods of analysis can or will predict future
results, successfully identify market tops or bottoms, or insulate you from losses due to market
corrections or declines. There are certain additional risks associated with investing in securities
through our investment management program, as described below:
• Market Risk - Either the stock market as a whole, or the value of an individual company,
goes down resulting in a decrease in the value of client investments. This is also referred to
as systemic risk.
• Equity (stock) market risk - Common stocks are susceptible to general stock market
fluctuations and to volatile increases and decreases in value as market confidence in and
perceptions of their issuers change. If you held common stock, or common stock equivalents,
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of any given issuer, you would generally be exposed to greater risk than if you held preferred
stocks and debt obligations of the issuer.
• Company Risk - When investing in stock positions, there is always a certain level of
company or industry specific risk that is inherent in each investment. This is also referred to
as unsystematic risk and can be reduced through appropriate diversification. There is a risk
that the company will perform poorly or that its value will be reduced based on factors
specific to the company or its industry. For example, if a company's employees go on strike
or the company receives unfavorable media attention for its actions, the value of the
company can be reduced.
• Fixed Income Risk - When investing in bonds, there is the risk that the issuer will default on
the bond and be unable to make payments. Further, individuals who depend on set amounts
of periodically paid income face the risk that inflation will erode their spending power.
Fixed-income investors receive set, regular payments that face the same inflation risk.
• Options Risk - From time to time, AWM may provide advice regarding client-held options,
stock options, or option-related positions when relevant to a client’s overall financial
circumstances. Options can be volatile and may involve greater risk than investments in the
underlying securities. Options may expire worthless, decline rapidly in value, or create tax,
liquidity, and suitability considerations. AWM does not generally use options trading as a
primary investment strategy.
• ETF and Mutual Fund Risk - When investing in an ETF or mutual fund, you will bear
additional expenses based on your pro rata share of the ETF's or mutual fund's operating
expenses, including the potential duplication of management fees. The risk of owning an
ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF
or mutual fund holds. You will also incur brokerage costs when purchasing ETFs.
• ETNs Risk - An ETN, or an exchange-traded note, is a debt security that acts much like a
loan or a bond. Issuers like banks or other financial institutions sell the "note," which tracks
the performance of an underlying commodity or index/benchmark. ETNs do not yield
dividends or interest in the way that ETFs do. ETNs, in general, are subject to the following
risks: (i) Risk of default. An ETN is tied to a financial institution such as a bank. It's possible
for that bank to issue an ETN but fail to pay back the principal after the holding period. If so,
they'll go into default, leaving you with a loss.
• MLPs Risk - Master limited partnerships (or "MLPs") pose risks subject to the sensitivity to
changes in interest rates, volatility risk, governance features that can favor management over
other investors, concentrated exposure to a single industry or commodity resulting in
potential loss of principal invested.
• Alternative Investments Risk - The performance of alternative investments (e.g.,
commodities, futures, hedge funds; funds of hedge funds, private equity or other types of
limited partnerships) can be volatile. Alternative investments involve various risk factors and
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liquidity constraints, a complete discussion of which is set forth in the offering documents of
each specific alternative investment. Due to the speculative nature of alternative investments
a client must satisfy certain income or net worth standards prior to investing.
• Structured Products Risk - Structured products can be complex and may involve issuer
credit risk, market risk, liquidity risk, limited secondary markets, caps on returns, downside
exposure, early redemption features, call features, and tax considerations. The return of a
structured product depends on the terms of the product and the financial condition of the
issuer. Structured products may not be appropriate for all clients.
• Insurance and Annuity Product Risk - Insurance and annuity products can involve fees,
surrender charges, liquidity restrictions, tax considerations, rider charges, mortality and
expense charges, administrative fees, crediting limitations, caps, participation rates, market
value adjustments, and insurance-company claims-paying ability risk. Guarantees are subject
to the financial strength and claims-paying ability of the issuing insurance company. Some
annuity or insurance products may be difficult or costly to surrender, exchange, or replace,
and may not be appropriate for all clients.
• Cash/Cash Equivalents Risk - When a portfolio has significant investments in cash or cash
equivalents, there is a risk that the value of the cash account, including interest, will not keep
pace with inflation, reducing purchasing power over time.
• Foreign (Non-U.S.) Risk - A portfolio's investments in securities of non-U.S. or foreign
issuers can involve more risk than investments in securities of U.S. issuers. These securities
can fluctuate more widely in price and can be less liquid due to adverse market, economic,
political, regulatory, or other factors.
• Management Risk - Your investment with our firm varies with the success and failure of
our investment strategies, research, analysis and determination of portfolio securities. If our
investment strategies do not produce the expected returns, the value of a client’s investments
will decrease.
- Key Person Risk - AWM is a small organization, and Antonio P. Gomes serves as the
Firm's principal owner, Managing Member, and primary investment
and supervisory professional. The loss, incapacity, reduced availability, or departure of Mr.
Gomes or other key personnel could adversely affect the Firm's ability to provide services,
implement investment strategies, supervise personnel, or operate the business without
interruption. To address this risk, the Firm maintains business continuity and succession
planning procedures. However, clients should understand that a small firm may experience
operational or service disruptions if key personnel become unavailable or if a transition to
successor personnel or a successor organization becomes necessary.
• Geopolitical Conflicts Risk - International conflicts have led to, and are expected to
continue to cause, disruption, instability, and volatility in global markets and industries that
can negatively impact client investments. For example, sanctions, export controls, military
25
actions, and other governmental responses to conflicts can affect global economic and
commercial activity, market conditions, currencies, industries, businesses, and individual
issuers. The duration and severity of these effects are difficult to predict and can adversely
affect client portfolios and underlying investments. Additional governmental actions,
including sanctions-related, military, legal, or regulatory actions, can further disrupt or alter
financial, legal, and regulatory systems in ways that are adverse to client investments and
AWM’s ability to pursue client investment objectives.
• Pandemic Risk - Pandemic risk has caused, and can again cause, disruptions in economies
and individual companies and volatility in financial markets throughout the world, including
those in which AWM prospective investors or existing customers (collectively, "Clients")
invest. The impact of the pandemic and resulting economic disruptions can negatively impact
the Clients and the performance of their portfolios due to, among other things, (i) interruption
of business operations resulting from travel restrictions, reduced consumer spending, and
quarantines of employees, customers and suppliers in areas affected by the outbreak, (ii)
closures of manufacturing facilities, warehouses and logistics supply chains, and (iii)
uncertainty about the duration of the virus' impact on global financial markets. Governments
and central banks throughout the world have responded to the pandemic and resulting
economic disruptions with a variety of fiscal and monetary policy changes, including direct
capital infusions into companies and other issuers, new monetary policy tools and lower
interest rates, but the ultimate impact of these efforts is uncertain. It is not possible to
determine the duration or severity of the disruption in financial markets or the long-term
economic impact of a pandemic, or other future epidemics or pandemics, which can
adversely affect the Clients' performance and investment strategies and significantly reduce
available investment opportunities.
• Legal or Legislative Risk - Legislative changes or court rulings can impact the value of
investments or the securities' claim on the issuer's assets and finances.
Item 9 - Disciplinary Information
Advanced Wealth Management does not have any disciplinary information concerning the Firm
or its key persons, including its Executive Officers, to disclose in this Item. For more information
about the Firm or its investment adviser representatives, investors may visit the IAPD website by
clicking this link www.adviserinfo.sec.gov.
Item 10 - Other Financial Industry Activities and Affiliations
Advanced Wealth Management is not and does not have a related person that is a broker/dealer,
municipal securities dealer, government securities dealer or broker, an investment company or
26
other pooled investment vehicle (including a mutual fund, closed-end investment company, unit
investment trust, private investment company or "hedge fund," and offshore fund), another
investment adviser or financial planner, a futures commission merchant, commodity pool
operator, or commodity trading advisor, a banking or thrift institution, an accountant or
accounting firm, a lawyer or law firm, an insurance company or agency, a pension consultant, a
real estate broker or dealer, and a sponsor or syndicator of limited partnerships.
AWM is an independent investment adviser registered with the United States Securities and Exchange
Commission. AWM provides investment advisory, financial planning, and consulting services as described in
this Brochure. Certain supervised persons of AWM are also licensed insurance agents and may recommend
insurance or annuity products when appropriate for a client's needs and circumstances. These insurance and
annuity activities create conflicts of interest as described below.
Insurance Agent
Certain investment adviser representatives of AWM are independently licensed insurance agents.
When acting in this separate insurance capacity, they may recommend insurance or annuity
products, including life insurance, disability insurance, long-term care insurance, fixed annuities,
indexed annuities, variable annuities, 1035 exchanges, annuity replacements, or restructuring of
existing insurance or annuity contracts, when they determine such products or transactions are
appropriate for a client’s needs and circumstances.
Depending on the product and arrangement, AWM and/or its licensed insurance representatives
may receive compensation through insurance commissions paid by insurance companies or
through advisory fees on fee-based annuity products. The receipt of insurance commissions or
advisory fees creates a conflict of interest because the Firm and/or its representatives have a
financial incentive to recommend insurance or annuity products or transactions that generate
compensation.
AWM addresses this conflict by disclosing the conflict to clients, evaluating whether the
recommendation is in the client’s best interest, and allowing clients to decide whether to
implement any insurance or annuity recommendation. Clients are under no obligation to
purchase insurance or annuity products through AWM or its representatives and may purchase
such products through any insurance agent, insurance agency, or insurance company of their
choosing.
Retirement Planning & Training Services
Advanced Wealth Management and/or certain supervised persons may provide practice-
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management education, event management, retirement planning education, training, or related
consulting services to other financial professionals, including advisers who are considering or
pursuing independence. These services may be referred to as “All Star Advisors.” All Star
Advisors is not currently a separate legal entity, DBA, or registered investment adviser. These
services are separate from AWM’s investment advisory services described in this Brochure and
are not provided as individualized investment advice to AWM clients unless separately agreed in
writing. To the extent these activities create a conflict of interest, AWM addresses the conflict
through disclosure, supervision, and review of outside business activities.
Item 11 - Code of Ethics, Participation in Client Transactions and Personal
Trading
Code of Ethics Summary
An investment adviser is considered a fiduciary and has a fiduciary duty to all clients. Advanced
Wealth Management has established a Code of Ethics to comply with the requirements of the
securities laws and regulations that reflect its fiduciary obligations and those of its supervised
persons. The Code of Ethics also requires compliance with federal securities laws. Advanced
Wealth Management's Code of Ethics covers all individuals that are classified as "supervised
persons". All employees, officers, directors and investment adviser representatives are classified
as supervised persons. Advanced Wealth Management requires its supervised persons to
consistently act in your best interest in all advisory activities. Advanced Wealth Management
imposes certain requirements on its affiliates and supervised persons to ensure that they meet the
firm's fiduciary responsibilities to you. The standard of conduct required is higher than the
standard ordinarily required and encountered in commercial business.
This section is intended to provide a summary description of the Code of Ethics of Advanced
Wealth Management. If you wish to review the Code of Ethics in its entirety, you should send us
a written request and upon receipt of your request, we will promptly provide a copy of the Code
of Ethics to you.
Affiliate and Employee Personal Securities Transactions Disclosure
Advanced Wealth Management or associated persons of the firm are permitted to buy or sell, for
their personal accounts, investment products that are identical to those recommended to clients.
This creates a conflict of interest. It is the express policy of Advanced Wealth Management that
all persons associated in any manner with our firm must place clients' interests ahead of their
own when implementing personal investments. Advanced Wealth Management and its
associated persons will not buy or sell securities for their personal account(s) where their
decision is derived, in whole or in part, by information obtained because of employment or
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association with our firm unless the information is also available to the investing public upon
reasonable inquiry.
Advanced Wealth Management maintains written policies and procedures reasonably designed to
comply with applicable securities laws and regulations. To prevent conflicts of interest, we have
developed written supervisory procedures that include personal investment and trading policies
for our representatives, employees and their immediate family members (collectively, associated
persons):
• Associated persons cannot prefer their own interests to that of the client.
• Associated persons cannot purchase or sell any security for their personal accounts prior to
implementing transactions for client accounts.
• Associated persons cannot buy or sell securities for their personal accounts when those
decisions are based on information obtained because of their employment, unless that
information is also available to the investing public upon reasonable inquiry.
• Associated persons are prohibited from purchasing or selling securities of companies in
which any client is deemed an "insider".
- Associated persons are discouraged from conducting frequent personal trading.
- Associated persons are prohibited from serving as board members of publicly traded companies unless an
exception has been granted in writing by Advanced Wealth Management's Chief Compliance Officer or
designee.
Any associated person not observing our policies is subject to sanctions up to and including
termination.
Item 12 - Brokerage Practices
Advanced Wealth Management generally recommends that clients establish accounts with
Charles Schwab & Co., Inc. (“Schwab”), the Firm’s primary custodian, to maintain custody of
client assets and effect securities transactions. Clients are not required to use Schwab and may
request to use another qualified custodian, subject to the Firm’s ability to service the account
effectively. AWM is independently owned and operated and is not affiliated with Schwab.
AWM recommends custodians based on several factors, including the quality and cost of
services, trading and custody capabilities, technology, reporting, service levels, financial
strength, reputation, and ability to support the Firm’s advisory services. As noted in Item 5,
Schwab charges certain account-level fees when applicable, but does not generally charge
transaction fees for most U.S. equity and exchange-traded fund trades.
Clients are under no obligation to act on the financial planning recommendations of Advanced
Wealth Management. If the firm assists in the implementation of any recommendations, we are
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responsible for ensuring that the client receives the best execution possible. Best execution does
not necessarily mean that clients receive the lowest possible commission costs but that the
qualitative execution is best. In other words, all conditions considered, the transaction execution
is in your best interest. When considering best execution, we look at a number of factors besides
prices and rates including, but not limited to:
• Execution capabilities (e.g., market expertise, ease/reliability/timeliness of execution,
responsiveness, integration with our existing systems, ease of monitoring investments)
• Products and services offered (e.g., investment programs, back-office services, technology,
regulatory compliance assistance, research, and analytic services)
• Financial strength, stability, and responsibility
• Reputation and integrity
• Ability to maintain confidentiality
We exercise reasonable due diligence to make certain that best execution is obtained for all
clients when implementing any transaction by considering the back-office services, technology
and pricing of services offered.
Brokerage Recommendations
Advanced Wealth Management recommends that clients establish brokerage accounts with the
Schwab Institutional division of Charles Schwab & Co., Inc. ("Schwab") ("custodial broker
dealer") a SEC-registered broker-dealer, Member FINRA/SIPC, to maintain custody of clients'
assets and to effect trades for their accounts.
Although Advanced Wealth Management recommends the clients establish accounts at Schwab,
clients retain the right to custody assets with any qualified custodial broker dealer. Advanced
Wealth Management is independently owned and operated and not affiliated with any broker-
dealer. Advanced Wealth Management recommends additional unaffiliated broker-dealers to
effect fixed income transactions when appropriate.
The custodial broker dealers provide Advanced Wealth Management with access to its
institutional trading and custody services, which are typically not available to retail investors.
Schwab provides AWM with access to institutional custody, trading, reporting, and technology
services that are generally not available to retail investors. These services are not contingent
upon Advanced Wealth Management committing to custodial broker-dealers any specific amount
of business (assets in custody or trading commissions). The custodial broker dealers' brokerage
services include the execution of securities transactions, custody, research, and access to mutual
funds and other investments that are otherwise generally available only to institutional investors
or would require significantly higher minimum initial investment.
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For Advanced Wealth Management's clients' accounts maintained in its custody, custodial broker
dealers generally do not charge separately for custody services but is compensated by account
holders through commissions or other transaction-related or asset-based fees for securities trades
that are executed through the broker dealer or that settle into their accounts. Custodial broker
dealers also offer Advanced Wealth Management other products and services that benefit
Advanced Wealth Management, but may not directly benefit clients' accounts. Many of these
products and services may be used to service all or some substantial number of Advanced
Wealth Management's accounts, including accounts not maintained at that broker dealer.
Custodial broker dealers' products and services that assist Advanced Wealth Management in
managing and administering clients' accounts include software and other technology that (i)
provides access to client account data (such as trade confirmations and account statements); (ii)
facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii)
provide research, pricing and other market data; (iv) facilitate payment of Advanced Wealth
Management's fees from some of its accounts; and (v) assist with back-office functions,
recordkeeping and client reporting.
Custodial broker dealers also offer other services intended to help Advanced Wealth
Management manage and further develop its business enterprise. These services may include: (i)
compliance, legal and business consulting; (ii) publications and conferences on practice
management and business succession; and (iii) access to employee benefits providers, human
capital consultants and insurance providers. The broker dealer may discount or waive fees it
would otherwise charge for some of these services or pay all or part of the fees of a third-party
providing these services to Advanced Wealth Management. The custodial broker dealer may also
provide other benefits such as educational events or occasional business entertainment of
Advanced Wealth Management personnel. While as a fiduciary, Advanced Wealth Management
endeavors to act in its clients' best interests, Advanced Wealth Management's recommendation
that clients maintain their assets in accounts at a particular broker dealer may take into account
availability of some of the foregoing products and services and other arrangements not solely on
the nature of cost or quality of custody and brokerage services provided which may create a
potential conflict of interest.
Directed Brokerage
Clients are allowed to select the broker-dealer that will be used for their accounts. Clients
directing the use of a particular broker/dealer or other custodian must understand that we may
not be able to obtain the best prices and execution for the transaction. Under a client-directed
brokerage arrangement, clients may receive less favorable prices than would otherwise be the
case if the client had not designated a particular broker/dealer or custodian. Directed brokerage
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account trades are generally placed by Advanced Wealth Management after effecting trades for
other clients of Advanced Wealth Management. In the event that a client directs Advanced
Wealth Management to use a particular broker or dealer, Advanced Wealth Management may
not be authorized to negotiate commissions and may be unable to obtain volume discounts or
best execution. In addition, under these circumstances a disparity in commission charges may
exist between the commissions charged to clients who direct Advanced Wealth Management to
use a particular broker or dealer versus clients who do not direct the use of a particular broker or
dealer.
Soft Dollar Benefits
An investment adviser receives soft dollar benefits from a broker-dealer when the adviser
receives research or other products and services in exchange for client securities transactions or
maintaining an account balance with the broker-dealer.
Advanced Wealth Management does not have any soft dollar arrangements under which client
brokerage commissions are used to obtain research or other services. As described above, AWM
may receive institutional custody, technology, practice management, or related support from
Schwab or other custodians, which creates a conflict of interest because those benefits may
influence the Firm’s custodian recommendation.
Handling Trade Errors
Advanced Wealth Management has implemented procedures designed to prevent trade errors;
however, trade errors in client accounts can occur. Consistent with its fiduciary duty, it is the
policy of Advanced Wealth Management to correct trade errors in a manner that is in the best
interest of the client. In cases where the client causes the trade error, the client is responsible for
any loss resulting from the correction. Depending on the specific circumstances of the trade
error, the client may not receive any gains generated as a result of the error correction. In all
situations where the client does not cause the trade error, the client is made whole and any loss
resulting from the trade error is absorbed by Advanced Wealth Management if the error is caused
by Advanced Wealth Management. If the error is caused by the broker-dealer, the broker-dealer
is responsible for handling the trade error. If an investment gain results from the correcting trade,
the gain remains in the client's account unless the same error involved other client account(s) that
should also receive the gains. It is not permissible for all clients to retain the gain. Advanced
Wealth Management confers with a client, when appropriate, to determine whether the client
should forego the gain, such as for tax reasons.
Advanced Wealth Management will never benefit or profit from trade errors.
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Block Trading Policy
Investment advisers can purchase or sell the same securities for several clients at approximately
the same time when they believe such action is advantageous to clients. This process is referred
to as aggregating orders, batch trading, or block trading. Advanced Wealth Management is
authorized, but not obligated, to aggregate, batch, or combine purchases, sales, and other
transactions made for an Account with transactions in the same or similar securities or
instruments for other clients of Advanced Wealth Management, where authorized in writing by
the applicable clients. Advanced Wealth Management uses block trading infrequently and only
when the Firm determines that doing so is appropriate and consistent with the interests of the
participating clients.
When Advanced Wealth Management aggregates trades, participating client accounts generally
receive the average price for the aggregated transaction and share transaction costs, if any, on a
pro rata or otherwise fair and equitable basis. Advanced Wealth Management will not favor one
participating client account over another when allocating aggregated trades. If an aggregated
order is partially filled, the Firm will allocate the securities purchased or sold among
participating client accounts in a fair and equitable manner, consistent with the Firm’s written
trading and allocation procedures.
Because Advanced Wealth Management develops individualized investment strategies for
clients, and client holdings vary, the Firm generally implements client orders on an individual
basis. Clients are not hindered because block trading is used infrequently and only for accounts
where such trading has been authorized and determined to be appropriate.
Agency Cross Transactions
Our associated persons are prohibited from engaging in agency cross transactions. This means
we cannot act as broker for both the sale and purchase of a single security between two different
clients and cannot receive compensation in the form of an agency cross commission or principal
mark-up for such trades.
Item 13 - Review of Accounts
Account Reviews and Reviewers
Managed accounts are monitored on a periodic basis and reviewed quarterly by one of Advanced
Wealth Management's Financial Professionals, including Antonio P. Gomes or Charles G.
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Bryant. In addition to quarterly reviews, account reviews are conducted at the client’s request or
when the Firm determines that market conditions, changes in the client’s financial circumstances,
investment objectives, or other relevant factors warrant additional review. Account reviews
include a review of the client’s investment strategy, objectives, and whether changes are
appropriate based on the client’s circumstances. Reviews are conducted by our Firm's Financial
Professionals to determine whether client portfolios remained aligned with the client’s stated
investment goals and objectives and whether reallocation or rebalancing is appropriate.
Financial planning services terminate upon presentation of the written plan. Financial planning
and consulting services do not include ongoing monitoring of client investments or accounts
unless otherwise agreed in writing.
Statements and Reports
For our asset management services, clients receive transaction confirmation notices and regular
quarterly account statements directly from the qualified custodian. Advanced Wealth
Management provides position or performance reports quarterly or upon request when
applicable.
Financial planning clients do not receive any report other than the written plan originally
contracted for and provided by Advanced Wealth Management.
Clients are encouraged to compare any reports or statements provided by the Firm against the
account statements delivered from the qualified custodian. When clients have questions about an
account statement, they should contact our firm and the qualified custodian preparing the
statement.
Item 14 - Client Referrals and Other Compensation
Advanced Wealth Management does not currently maintain arrangements with unaffiliated
promoters, solicitors, referral sources, or other persons or entities to refer clients to the Firm for
investment advisory services in exchange for compensation.
If AWM enters into any compensated referral, promoter, solicitor, endorsement, or testimonial
arrangement in the future, the Firm will do so only in accordance with applicable federal and
state securities laws. This may include, as applicable, entering into a written agreement,
providing required disclosures to clients and prospective clients, reviewing the arrangement for
conflicts of interest, and maintaining required books and records.
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AWM does not currently receive compensation from unaffiliated third parties for referring
clients to other investment advisers, financial professionals, broker-dealers, custodians, insurance
companies, or other product or service providers, except as otherwise disclosed in this Brochure.
Item 15 - Custody
Custody, as it applies to investment advisers, is generally defined by regulators as having access
to or control over client funds or securities. In other words, custody is not limited to physically
holding client funds and securities. If an investment adviser has the ability to access or control
client funds or securities, the investment adviser is deemed to have custody and must ensure
proper procedures are implemented.
Advanced Wealth Management has limited authority to deduct advisory fees directly from client
accounts in accordance with client agreements and custodian authorizations. AWM may also
facilitate client-authorized standing letters of authorization ("SLOAs") through qualified
custodians. The Firm maintains policies and procedures designed to comply with Rule 206(4)-2
under the Investment Advisers Act of 1940 and applicable SEC guidance, including
requirements and available exceptions applicable to fee deductions and client-authorized
transfers. Client assets are maintained with qualified custodians.
For accounts in which Advanced Wealth Management is deemed to have custody the Firm has
established procedures to ensure all client funds and securities are held at a qualified custodian in
a separate account for each client under that client's name. Clients or an independent
representative of the client direct, in writing, the establishment of accounts and are made aware
of the qualified custodian's name, address, and the manner in which the funds or securities are
maintained. Finally, account statements are delivered directly from the qualified custodian to
each client, or the client's independent representative, at least quarterly. Clients should carefully
review those statements and are urged to compare the statements against reports received from
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Advanced Wealth Management. When clients have questions about their account statements,
they should contact Advanced Wealth Management or the qualified custodian preparing the
statement.
When fees are deducted from an account, Advanced Wealth Management is responsible for
calculating the fee and delivering instructions to the custodian. At the same time Advanced
Wealth Management instructs the custodian to deduct fees from the client’s account; Advanced
Wealth Management sends the client an invoice itemizing the fee. Itemization will include the
formula used to calculate the fee, the amount of assets under management the fee is based on,
and the time period covered by the fee.
Item 16 - Investment Discretion
When providing asset management services, Advanced Wealth Management maintains a limited
power of attorney including trading authorization over a client’s Account and provides
management services on a discretionary basis when authorized by the client. When discretionary
authority is granted, AWM has the authority to determine the type of securities and the amount
of securities to be bought or sold for the client’s portfolio without obtaining the client’s consent
for each transaction.
If a client grants trading authorization on a non-discretionary basis, AWM is required to contact
the client prior to implementing changes in the account. Therefore, you will be contacted and
required to accept or reject our investment recommendations including:
• The security being recommended;
• The number of shares or units; and
• Whether to buy or sell.
Once the above factors are agreed upon, we will be responsible for making decisions regarding
the timing of buying or selling an investment and the price at which the investment is bought or
sold. If an account is managed on a non-discretionary basis, delays in reaching the client or
receiving the client’s response can adversely impact the timing of trade implementation and can
prevent AWM from achieving the optimal trading price. Clients have the ability to place
reasonable restrictions on the types of investments that may be purchased in their Account.
Clients also may place reasonable limitations on the discretionary authority granted to Advanced
Wealth Management, provided the limitations are specifically set forth in, or included as an
attachment to the client agreement.
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Item 17 - Voting Client Securities
Proxy Voting
Advanced Wealth Management does not vote proxies on behalf of Clients. The Firm has
determined that taking on responsibility for voting client securities does not add enough value to
the services provided to Clients to justify the additional compliance and regulatory costs
associated with voting client securities. Therefore, Clients are responsible for voting all proxies
for securities held in their Accounts.
Clients receive proxies directly from the qualified custodian or transfer agent;
Advanced Wealth Management does not provide proxies to clients. Clients are
encouraged to review the information provided with the proxy-voting
documents and make voting decisions based on that information.
Item 18 - Financial Information
Advanced Wealth Management does not require or solicit prepayment of more than $1,200 in
fees per client, six months or more in advance. Therefore, the Firm is not required to include a
balance sheet for the most recent fiscal year. Advanced Wealth Management is not subject to any
financial condition that is reasonably likely to impair its ability to meet contractual commitments
to clients. Advanced Wealth Management has not been the subject of a bankruptcy petition at
any time.
Item 19 - Requirements for State-Registered Advisers
- Advanced Wealth Management is owned and controlled by Antonio P. Gomes.
- More information regarding Antonio P. Gomes's education and business background is included in
Item 2 of the applicable Form ADV Part 2B Brochure Supplement.
- There are no reportable legal or disciplinary events.
- Our Firm representatives are not compensated for advisory services with performance-based fees
managing client accounts.
- Neither the Firm nor its management persons have any relationship or arrangement with any issuer
of securities that is not disclosed in Item 10 above.