Overview
- Headquarters
- Canton, OH
- Total Firm Assets
- $218 million
- Average High-Net-Worth Client Portfolio Size
- $1.4 million
Fee Structure
Primary Fee Schedule (FORM ADV PART 2A - AFFINITY WEALTH, LLC)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 1.50% |
| $500,001 | $2,000,000 | 1.00% |
| $2,000,001 | $5,000,000 | 0.85% |
| $5,000,001 | $8,000,000 | 0.70% |
| $8,000,001 | and above | 0.60% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $12,500 | 1.25% |
| $5 million | $48,000 | 0.96% |
| $10 million | $81,000 | 0.81% |
| $50 million | $321,000 | 0.64% |
| $100 million | $621,000 | 0.62% |
Clients
- High-Net-Worth Share of Firm Assets
- 59.94%
- Number of High-Net-Worth Clients
- 90
- Total Client Accounts
- 1,129
- Discretionary Accounts
- 1,119
- Non-Discretionary Accounts
- 10
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Investment Advisor Selection
Regulatory Filings
- SEC CRD Number
- 285169
Primary Brochure: FORM ADV PART 2A - AFFINITY WEALTH, LLC (2026-08-11)
View Document Text
Affinity Wealth LLC
4481 Munson St NW, Suite 302
Canton, OH 44718
(330) 526-8412
www.TAGplanning.com
ADV Part 2A Brochure
Date of Brochure: August 2026
The purpose of this brochure is to describe the services provided, qualifications & business practices offered by
Affinity Wealth, LLC. Affinity Wealth (AW) is a State of Ohio registered investment advisor. If you have any
questions about the contents of this brochure, please contact us at (330) 526-8412 or by email at:
info@TAGplanning.com. The information in this brochure has not been approved or verified by the United States
Securities and Exchange Commission or by any state securities authority.
Additional information about Affinity Wealth LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov. Affinity Wealth LLC’s CRD number is: 285169.
Registration does not imply a certain level of skill or training.
Affinity Wealth
Form ADV Part 2A Version 8/2026
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Item 2 – Material Changes
Since our last annual update was filed on 1/2026, material changes made to this brochure include:
Item 4:
B:
B:
Description of services provided under a Total Wealth Management agreement was reworded to be more
succinct.
Updating Language for “Business Services Agreement”.
Item 10:
C:
Item 10c has been updated to add additional language and description around outside business activities.
Item 12:
A:
A:
Item 12a a was modified to remove Altruist as a custodian utilized.
Item 12 was also modified to remove Ascensus as a 401k custodian currently being utilized.
Our Brochure is available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/
CRD number for the Firm is 285169. We may provide ongoing disclosure information about material
changes as necessary and will further provide a new Brochure as necessary based on changes or
new information, at any time, without charge.
Currently, you may request our Brochure by contacting us at (330) 526-8412 or by email at:
Info@TAGplanning.com.
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Form ADV Part 2A Version 8/2026
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Item 3: Table of Contents
Contents
Item 2 – Material Changes .........................................................................................................................................2
Item 3: Table of Contents ..........................................................................................................................................3
Item 4: Advisory Business .........................................................................................................................................4
Item 5: Fees and Compensation .................................................................................................................................6
Item 6: Performance-based Fees and Side-by-Side Management ..............................................................................9
Item 7: Types of Clients .............................................................................................................................................9
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss .........................................................................9
Items 9: Disciplinary Information ............................................................................................................................11
Item 10: Other Financial Industry Activities and Affiliations ..................................................................................11
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............................12
Item 12: Brokerage Practices ....................................................................................................................................13
Item 13: Review of Accounts ...................................................................................................................................14
Item 14: Client Referrals and Other Compensation .................................................................................................15
Item 15: Custody ......................................................................................................................................................15
Item 16: Investment Discretion ................................................................................................................................15
Item 17: Voting Client Securities (Proxy Voting) ....................................................................................................15
Item 18: Financial Information .................................................................................................................................16
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Item 4: Advisory Business
A. Description of Advisory Firm
Affinity Wealth LLC (hereinafter “AW”) is a company registered in the state of Ohio, and an Investment Advisor
registered with the SEC.
Scott A. Lowe is the firm’s owner and founded “The Affinity Group” which is the firms DBA in 2009 as an
independent wealth management firm. In 2016 Affinity Wealth LLC was created as the firm became a Registered
Investment Advisor. “The Affinity Group” is the marketing name that the firm operates under and includes both
the firms RIA “Affinity Wealth LLC” and its independent insurance agency “Affinity Insurance Strategies LLC”.
As used in the brochure, the words, “we,” “our,” and “us” refer to AW, and the words “you,” “your,” and “client”
refer to you as either a client or prospective client of our firm. In addition, you will see the term Supervised
Person throughout this brochure. As used in this brochure, our Supervised Persons are our firm’s officers,
employees and all individuals providing investment advice on behalf of our firm.
B. Types of Advisory Services
“Total Wealth Management” Relationship
For those that have accumulated sizable assets, business owners, or high-income earners, managing the many
aspects of your complete financial picture is complex. Total Wealth Management is a monthly retainer
relationship designed for those that appreciate a concierge approach to addressing these complexities and the
required integration of all professionals that is essential, such as income tax planning, investments, business
ownership, insurance, banking, etc. Our Wealth Management team takes ownership as we manage and integrate
with your various professionals, or introduce you to new ones as needed
All Total Wealth Management clients receive the following:
➢ Comprehensive Financial Planning and Ongoing Plan Management
➢ Personal eMoney Financial Website, Account Aggregation and Secure Document Vault
➢ Net Worth, Cash Flow and Spending Analysis
➢ Retirement Readiness, Income Sequencing and Work-Optional Planning
➢ Social Security Claiming Strategy and Medicare Planning
➢ Tax-Aware Investment, Retirement, Income and Charitable Planning
➢ Estate Planning Review, Alignment and Implementation Coordination
➢ Insurance and Personal Risk Management Analysis
➢ Investment Portfolio Analysis and Strategic Asset Allocation Recommendations
➢ Held-Away Employer Retirement Plan Allocation Guidance
➢ Two Comprehensive Advisor-Led Planning Reviews Each Year
➢ Dedicated Internal Advisory and Financial Planning Team
➢ Access to Affinity Wealth’s Curated Network of Independent Specialists
➢ Collaboration With the Client’s Existing Professional Team, as Appropriate
➢ Planning Implementation, Action-Item Oversight and Year-Round Advice and Support
•
• Bankers
• Realtors and other real estate
Insurance professionals (including
health insurance and property &
casualty insurance agents
professionals
TWM clients also have access to our selected “Network of Specialists” who can provide them feedback specific
to their needs and situations. The client can then take that advice and work with someone on their own or choose
to work with one of our specialists in a direct relationship with them.
• Estate planning attorneys
• CPAs and tax planners
• Mortgage professionals
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Each client who opts for a TWM relationship engages us in a “good until cancelled” relationship; if a client chooses
to no longer utilize our TWM service, we can enter an investment advisory only relationship with them; if they
choose to no longer be a client of the firm altogether, we make a professional courtesy of refunding their latest
month’s retainer fees.
TWM is a separate service offering from any of the other items listed in this section.
Investment Advisory Agreement
AW offers ongoing investment advisory services based on the individual goals, objectives, time horizon and risk
tolerance of each client. Investment advisory services can be stand alone, or in addition to a “Total Wealth
Management” relationship. Either way, the below items are services that each AW client receives.
1. Investment Management/Research
• Quarterly Performance and cost research across the universe of 35,000 investment options
• Model Portfolio rebalancing as allocation levels exceed 5% of threshold.
•
If systematically withdrawing, raising cash 2-3 times per year to ensure that the next 12 months of
withdrawals are maintained and re-evaluating this figure twice per year.
2. Custodian Evaluations
• Evaluating custody fees
• Technology Platform comparisons
• Paper statement layout design
•
Investment capabilities
3. Personal Needs Analysis (this applies specifically to clients who are not TWM and solely investment advisory
clients of Affinity Wealth)
• Goal review to determine if the current Investment Allocation is still appropriate.
• Maintaining updated “static” net worth statement based upon client provided figures for all accounts.
• Retirement Projections based upon current net worth statement as well as client provided income and
“living expense stated estimates.” Since there is no eMoney financial planning tool, this information
will be out of date unless a client provides our team with updated information prior to review meetings.
We provide discretionary and non-discretionary Portfolio Advisory Services in accordance with each clients’
individual investment objectives and signed Investment Advisory Agreement.
Clients who engage AW for “Investment Advisory” must grant either grant us:
Discretionary Authority: To manage your account, which is granted by the investment advisory agreement you
sign with our firm. We have the authority and responsibility to formulate investment strategies on your behalf. This
includes deciding which securities to buy and sell, when to buy and sell, and in what amounts, in accordance with
your investment program, without obtaining your prior consent or approval for each transaction.
Retirement Plan Consulting Services
AW offers ongoing consulting services for pensions or other employee benefit plans (including but not limited to
401(k) plans) based on the demographics, goals, objectives, time horizon, and/or risk tolerance of the plan’s
participants.
In providing pension consulting services we currently maintain record-keeping and third-party administrators:
July Benefit Services and Mid-Atlantic Trust Company
•
• Vanguard Investments and Ascensus Trust Company
• Employee Fiduciary and MG Trust Company
“Ongoing Business Services Agreement”
Like our personal “Total Wealth Management” relationship, for businesses we offer a monthly retainer relationship
where clients are engaging AW to provide ongoing advice in any or all the selected areas below:
• Business Sale preparation.
• Executive Benefit Planning
• 401k plans/Retirement Plan startup and employee education.
• Coordination of Group Life Insurance, Health Insurance & Property and casualty Insurance Services
• Advising on optimal business entity structure: LLC’s, s-corps, c-corps
Clients of AW, through their Ongoing Business Services Agreement, select the areas where they want AW to
provide ongoing advice and services. Within this relationship, Affinity Wealth coordinates with outside
professionals from time to time and compensates them directly for the services that they provide to our outsourced
CFO business clients to complete the above tasks.
C. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that includes management
fees, transaction costs, fund expenses, and other administrative fees. AW does not participate in any wrap fee
programs.
D. Assets Under Management & Advisement
When calculating regulatory assets under management, an investment adviser must include the value of any
advisory account over which it exercises continuous and regular advisory or management services. As of January
1st 2026, Affinity reports $217,526,961 in client assets under management.
Item 5: Fees and Compensation
A. Total Wealth Management Relationship
TWM clients pay a monthly ongoing retainer, which is based upon:
1.) The complexity of each client’s financial situation.
2.) The number of TWM services selected and outlined in the TWM client agreement.
3.) If the client has “investment advisory assets” with the firm.
The monthly renewable retainer for new clients engaging our firm as a TWM client starts at $300 per month and
goes up based upon services desired, complexity of the client’s situation, and estimated annual time commitment
needed by AW. The retainer is reviewed each year based upon the client's changing and ongoing circumstances
and needs.
AW does have long-term “legacy clients” that also have investment advisory assets with the firm, some of these
clients may pay a lower TWM fee than new clients being onboarded today.
This retainer is collected monthly through automatic ACH bank draft from the client’s checking account. Total
Wealth Management is an ongoing “good until cancelled” relationship.
B. Investment Advisory Agreement
The annualized fee schedule for investment management is as follows:
Annual Management Fee
Total Household Account Asset Value
0 - $499,999
First
From $500,000- $1,999,999
From $2,000,000- $4,999,999
From $5,000,000- $7,999,999
1.50%
1.00%
.85%
.70%
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From $8,000,000 or more
.60%
For example:
A client with $1,750,000 in total assets under management will be billed 1.5% on the first $499,999, and 1% on the
next $1,250,000.
AW’s fee is calculated based on the fair market value of the client’s assets under management as of the last
business day of the prior billing period. AW’s fees will be automatically debited from the client’s investment
accounts.
• Accounts held at SEI Private Trust Company (“SEI”) are billed quarterly in arrears.
• Accounts held at Capital Bank & Trust (American Funds) are billed quarterly in arrears.
• Accounts held at Nationwide Wealth Advisory (Nationwide) are billed monthly in arrears.
In addition to our investment management fee, the client, relative to all mutual fund purchases with any of our
relationships, shall also incur charges imposed at the mutual fund level (e.g., management fees and other fund
expenses).
At our discretion, we may combine the account values of family members living in the same household to
determine the applicable advisory fee. For example, we may combine account values for you and your minor
children, joint accounts with your spouse, and other types of related accounts. Combining account values may
increase the asset total, which may result in your paying reduced investment management fees based on the
available breakpoints in our fee schedule stated above.
Either party may terminate the management agreement within five days of the date of acceptance without penalty.
After the five-day period, you may terminate the investment advisory agreement by providing 30 days’ written
notice to our firm. The asset allocation fee will be prorated for the quarter in which the termination notice is given,
which means that you will incur advisory fees only in proportion to the number of days in the quarter for which you
are a client. If you have prepaid any advisory fees that we have not yet earned, you will receive a prorated refund of
those fees.
C. Fees for Retirement Plan Services/Pension Consulting
Fees for the Retirement Plan Services ("Fees") are negotiable based upon the size of the plan, the number of
participants in the plan, and the services that the plan sponsor desires. Excluding “solo-401k plans” which fall
under the normal Investment Management fee schedule, the fee for Pension Consulting is negotiable and ranges
between .50% and 1.75%. The minimum annualized fee for Pension Consulting services is $1800.
Sponsors instruct the Plan’s recordkeeper or custodian to automatically deduct our Fees from the Plan account;
however, in some cases a Sponsor may request that we send invoices directly to the Sponsor/Company for direct
payment. Depending upon the capabilities and requirements of the Plan’s recordkeeper or custodian, we can collect
our fees in arrears or in advance based upon the needs of the client.
Unless we agree otherwise, no adjustments or refunds will be made in respect of any period for (i) appreciation or
depreciation in the value of the Plan account during that period or (ii) any partial withdrawal of assets from the
account during that period. If the Agreement is terminated by us or by Sponsor, we will refund certain Fees to
Sponsor to the extent provided in Section 8 of the Agreement. Unless we agree otherwise, all Fees shall be based on
the total value of the assets in the account without regard to any debit balance.
All Fees paid to AW for Retirement Plan Services are separate and distinct from the fees and expenses charged by
mutual funds and exchange traded funds to their shareholders. These fees and expenses are described in each
investment's prospectus. These fees will include a management fee and other expenses.
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The Retirement Plan Services provided by AW may, among other things, assist the client in determining which
investments are most appropriate to each client's financial condition and objectives and to provide other
administrative assistance as selected by the client. Accordingly, the client should review both the fees charged by
the funds, the fund manager, the Plan's other service providers and the fees charged by AW to fully understand the
total amount of fees to be paid by the client and to evaluate the Retirement Plan Services being provided.
D. Rollover Recommendations
As part of our investment advisory services to you, we may recommend that you roll assets from your employer’s
retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively, a “Plan Account”), to an individual
retirement account, such as a SIMPLE IRA, SEP IRA, Traditional IRA, or Roth IRA (collectively, an “IRA
Account”) that we will manage on your behalf. We may also recommend rollovers from IRA Accounts to Plan
Accounts, from Plan Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. When we provide any
of the foregoing rollover recommendations we are acting as fiduciaries within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as
set forth in the advisory agreement you executed with our firm. This creates a conflict of interest because it creates
a financial incentive for our firm to recommend the rollover to you (i.e., receipt of additional fee-based
compensation). You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you
do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. Due to the
foregoing conflict of interest, when we make rollover recommendations, we operate under a special rule that
requires us to act in your best interests and not put our interests ahead of yours.
Under this special rule’s provisions, we must:
avoid misleading statements about conflicts of interest, fees, and investments
follow policies and procedures designed to ensure that we give advice that is in your best interests
charge no more than a reasonable fee for our services; and
• meet a professional standard of care when making investment recommendations (give prudent advice)
• never put our financial interests ahead of yours when making recommendations (give loyal advice)
•
•
•
• give you basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company plan. Also, current
employees can sometimes move assets out of their company plan before they retire or change jobs. In determining
whether to complete the rollover to an IRA, and to the extent the following options are available, you should
consider the costs and benefits of a rollover.
Note that an employee will typically have four options in this situation:
1. Leaving the funds in your employer’s (former employer’s) plan
2. Moving the funds to a new employer’s retirement plan
3. Cashing out and taking a taxable distribution from the plan; or
4. Rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance of understanding the
differences between these types of accounts, we will provide you with a written explanation of the advantages and
disadvantages of both account types and the basis for our belief that the rollover transaction we recommend is in
your best interests.
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Item 6: Performance-based Fees and Side-by-Side
Management
AW does not accept performance-based fees or other fees based on a share of capital gains or capital appreciation
of the assets of a client.
Item 7: Types of Clients
AW provides advisory services to the following types of clients:
• Pre-retiree’s/Retiree’s
• Business-owners and executives
• High-Net-Worth Individuals
• Up and coming wealthy
We do not require a minimum dollar amount to open and maintain an advisory account; however, we have the right
to terminate your Account if it falls below a minimum size which, in our sole opinion, is too small to effectively
manage.
A. Termination of Client Relationship
The following is the outline of how AW handles the termination of a client relationship who no longer wishes AW
to be the RIA on their account:
• The firm’s CCO contacts the client through either email, phone-call or both to fully understand the client’s
reason for moving their accounts as well as to collect all information as to where they will be moving the
accounts. This is done in order for AW to assist the client in making the transition as seamless and easy for
the client as possible.
• AW will submit to the custodian a letter of instruction informing the custodian that Affinity Wealth is to be
removed as the Investment Advisor immediately.
• The client’s investments will remain with the custodian until when/if the client decides to move the account
elsewhere.
• AW will maintain the client’s file and all corresponding notes in our database and mark the client inactive.
Item 8: Methods of Analysis, Investment Strategies & Risk
of Loss
A. Methods of Analysis and Investment Strategies
AW’s process in determining how we invest for each client is based upon the type of relationships for which they
engage our firm.
A) For our “Total Wealth Management” clients:
a. First, our Wealth Management Team constructs a comprehensive financial plan utilizing our wealth
management technology “eMoney” to determine the rate of return needed for the client to achieve
their desired goal or outcome.
b. The financial plan includes the client’s income, Assets, Debt, tax rate, detailed monthly expenses,
social security projections, pension projections, future inflation assumptions,
c. Using this financial plan to determine a detailed forward-looking cash-flow analysis. The cash
flow analysis helps AW determine when the client will need the money in which they are investing.
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d. With this analysis, AW then places the client into one of our managed Asset Allocation Model
Portfolios. This is what is known as “Prudent Asset Allocation” within our industry, first widely
discussed by Louis S. Harvey, the founder of Dalbar.
B) For our investment only clients where we do not have a detailed financial plan:
a. Building a “Financial Profile” for the clients within our wealth management technology “eMoney”.
This financial profile will include the client’s income, assets, and liabilities.
b. This allows us to understand the client’s current net worth as well as current asset allocation across
all assets.
c. Understand the time horizon for the goal in which they are investing.
d. Along with the client, we then determine the proper asset allocation model into which the client is
invested.
Regardless of the type of relationship the client chooses, Affinity Wealth investment strategies revolve
around a long-term buy and hold strategy that focuses on when the clients need the money that's invested as
well as a full understanding of the clients net worth statement, which allows us to utilize “Prudent Asset
Allocation”.
Fundamental Analysis involves analyzing individual companies and their industry groups, such as a company’s
financial statements, details regarding the company’s product line, the experience and expertise of the company’s
management, and the outlook for the company and its industry. The resulting data is used to measure the true value
of the company’s stock compared to the current market value.
Risk- The risk of fundamental analysis is that information obtained may be incorrect and the analysis may not
provide an accurate estimate of earnings, which may be the basis for a stock’s value. If securities prices adjust
rapidly to new information, utilizing fundamental analysis may not result in favorable performance.
Long-term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term
investment strategy can expose clients to various types of risk that will typically surface at various intervals during
the time the client owns the investments. These risks include but are not limited to inflation (purchasing power)
risk, interest rate risk, economic risk, market risk, and political/regulatory risk.
Selection of Other Advisers: AW's selection process cannot ensure that money managers will perform as desired,
and AW will have no control over the day-to-day operations of any of its selected money managers. AW would not
necessarily be aware of certain activities at the underlying money manager level, including without limitation a
money manager's engaging in unreported risks, investment “style drift” or even regulatory breaches or fraud.
Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.
B. Risks of Specific Securities Utilized
Clients should be aware that there is a material risk of loss using any investment strategy. The investment types
listed below are not guaranteed or insured by the FDIC or any other government agency.
Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in
mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income”
nature (lower risk) or stock “equity” nature.
Stocks & ETFs: Investing in stocks & ETFs carries the risk of capital loss (sometimes up to a 100% loss, in the case
of a stock holding bankruptcy). Investments in these securities are not guaranteed or insured by the FDIC or any
other government agency.
Real Estate Investment Trusts (“REITs”): have specific risks including valuation due to cash flows, dividends paid
in stock rather than cash, and the payment of debt resulting in dilution of shares.
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Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee
they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued
by a life insurance company designed to meet requirements or other long-term goals. An annuity is not a life
insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-
range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance
company charges may apply if you withdraw your money early. Variable annuities also involve investment risks,
just as mutual funds do.
Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a
client, should be prepared to bear.
Items 9: Disciplinary Information
A. Criminal or Civil Actions
There are no criminal or civil actions to report.
B. Administrative Proceedings
There are no administrative proceedings to report.
C. Self-regulatory Organization (SRO) Proceedings
There are no self-regulatory organizational proceedings to report.
Item 10: Other Financial Industry Activities and Affiliations
A. Registration as a Broker/Dealer or Broker/Dealer Representative
Neither AW nor its representatives are registered as, or have pending applications to become, a broker/dealer or a
representative of a broker/dealer.
B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a
Commodity Trading
Adviser AW and our related persons are not registered as and do not have any pending application(s) to become
registered as a futures commission merchant, commodity pool operator, a commodity trading advisor, or associated
persons of any of the foregoing.
C. Relationships Material to this Advisory Business and Possible Conflicts of
Interests
Scott Lowe is owner of Affinity Private Tax LLC, a tax advisory firm providing services to Affinity Wealth clients.
Any client engaging A.P.T for any tax services does so through a separate engagement and agreement directly with
Affinity Private Tax, as Affinity Wealth LLC does not provide tax services.
Scott Lowe is owner of Affinity Insurance Strategies LLC, a State of Ohio licensed insurance agency. From time to
time, will offer clients advice or products from those activities.
Where appropriate, and in line with their fiduciary duty to AW’s advisory clients, they may offer clients advice
with respect to insurance products and may sell insurance products to clients and collect separate and customary
fees and commissions in connection with such transactions. The fees you pay to AW for advisory services are
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separate and distinct for any compensation our related persons may receive as a result of selling insurance products
to clients. These arrangements create a conflict of interest, insofar as they create a financial incentive for our related
persons to recommend insurance products to clients in view of the additional compensation they may receive, rather
than the client’s best interests. AW always acts in the best interests of its clients, including with respect to the
recommendation and sale of any commissionable insurance products. Clients are never obligated to implement
insurance recommendations through any of our related persons. AW is always willing to disclose any compensation
received by our related persons in connection with insurance products. We encourage you to inquire with us
regarding the conflicts of interest arising from these insurance licensing of our related persons.
Scott A. Lowe is a State of Ohio licensed Mortgage Loan Officer, license #1972148, and works in an independent
contractor arrangement with Pioneer Financial Services, Canton Ohio.
D. Relationships Material to this Advisory Business and Possible Conflicts of
Interests
Clients should be aware that these services pay a commission or other compensation and involve a conflict of
interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. AW
always acts in the best interest of the client, including working in conjunction with AIS and Pioneer Financial
Services in the sale of commissionable products to advisory clients. Clients are in no way required to utilize the
services of any representative of AW in connection with such individual's activities outside of AW.
Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
Code of Ethics
AW has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading,
Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and
Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws
and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer
Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. AW's Code of Ethics is available
free upon request to any client or prospective client.
Recommendations Involving Material Financial Interests
AW does not recommend that clients buy or sell any security in which AW or a person to which AW is related has
a material financial interest.
Investing Personal Money in the Same Securities as Clients
From time to time, representatives of AW may buy or sell securities for themselves that they also recommend to
clients. This may provide an opportunity for representatives of AW to buy or sell the same securities before or after
recommending the same securities to clients resulting in representatives profiting from the recommendations they
provide to clients. Such transactions may create a conflict of interest. AW will always document any transactions
that could be construed as conflicts of interest and will never engage in trading that operates to the client’s
disadvantage when similar securities are being bought or sold.
Trading Securities At/Around the Same Time as Clients’ Securities
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From time to time, representatives of AW may buy or sell securities for themselves at or around the same time as
clients. This may provide an opportunity for representatives of AW to buy or sell securities before or after
recommending securities to clients resulting in representatives profiting from the recommendations they provide to
clients. Such transactions may create a conflict of interest; however, AW will never engage in trading that operates
to the client’s disadvantage if representatives of AW buy or sell securities at or around the same time as clients.
Item 12: Brokerage Practices
A. Factors Used to Select Custodians
AW does not directly custody any client’s assets. Depending on the financial circumstances of the client as well as
the type of investments that are desired to be utilized, and account type, Affinity Wealth assists the client determine
the best custodian or their situation.
In selecting custodians in general, we have an obligation to seek the “best execution” of transactions in your
account. This duty requires that we seek to execute securities transactions for clients such that the total costs or
proceeds in each transaction are the most favorable under the circumstances. The determinative factor in the
analysis of best execution is not the lowest possible commission cost, but whether the transaction represents the
best qualitative execution, taking into consideration the full range of the recommended broker-dealer’s services.
The factors we consider when evaluating a
broker-dealer for best execution include, without limitation, the broker-dealer’s:
• Custodian capabilities
• Execution capability
• Research services/ancillary brokerage services provided
• Commission rates
• Any other factors that we consider relevant.
• Financial responsibility
• Responsiveness and customer service
SEI is currently AW’s largest independent custody relationship. AW has selected SEI based upon the above-
mentioned criteria and how they rank very favorably against their competitors. SEI’s role as a custodian is to
simply provide custody, the investment platform that we create investment accounts within, electronic access to
client accounts, quarterly statements, IRS reporting functions and 1099 preparation, and internal accounting or all
our client accounts on the platform. For these services SEI currently charges a 10-basis point platform fee to
Affinity Wealth, however the firm pays this platform fee on behalf of all our clients as a part of our investment
advisory agreement asset charges. The only fees that the client would ever incur from SEI would be wire transfer
fees or overnight check processing fees.
Capital Bank & Trust (“CB&T”), whose parent company is Capital Client Group, Inc. and is reflected in the firm’s
Form ADV Part 1A, is another custody relationship that AW maintains for the firm's clients. CB&T however unlike
an independent custodian, only custodies our client assets that are fully invested within American funds, which is a
wholly owned subsidiary of CB&T. CB&T’s custody fee is internally irreversibly placed within the mutual fund
operating expenses of the funds themselves that our clients are invested in, so therefore our clients at capital bank
and trust are paying for their own custody fees within their mutual funds operating expense ratios.
Nationwide Advisory is the custodian for Affinity Wealth’s “fee-based variable annuity” accounts. Nationwide’s
platform is utilized for clients who desire the tax-deferred nature of a variable annuity structure, with the ability to
invest amongst 360 subaccounts from various money managers. Nationwide deducts their platform and custody fee
from the Net Asset Value of the mutual funds in the account. Nationwide deducts AW’s fee monthly in arrears.
In the area of 401K and retirement plan custody relationships:
• Mid-Atlantic Trust Company is the custodian for our 401K plans managed with July benefit services as
well as Employee Fiduciary.
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• MG Trust Company is the custodian for any 403B plans managed through the Aspire platform.
Research and Other Soft-Dollar Benefits
AW may from time to time be provided with research, market commentary, or be invited to attend conferences
from our providers where both are provided.
Brokerage for Client Referrals
AW receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party.
Client Directed Brokerage
Affinity Wealth does not participate in any client-directed brokerage activity.
B. Aggregating or Block Trading for Multiple Client Accounts
AW maintains the ability to block trade purchases across accounts. The decision to block trade (or not) has no
impact on fees paid by clients.
Item 13: Review of Accounts
A. Frequency and Nature of Periodic Reviews and Who Makes Those Review
Scott A. Lowe, the Principal of Affinity Wealth will review the firms’ client accounts on a periodic basis and will
offer to conduct account reviews annually to ensure the advisory services provided to the clients and the portfolio
mix are consistent with their current investment needs and objectives. Additional reviews may be conducted based
on various circumstances, including, but not limited to:
• security specific events, and/or
• changes in risk/return objectives
• contributions and withdrawals
• year-end tax planning
• market moving events
AW may provide the client with additional written reports in conjunction with account reviews or upon your
request. Reports we provide to you will contain relevant account and/or market-related information such as an
inventory of account holdings and account performance, etc. You will receive trade confirmations and monthly or
quarterly statements from your account custodian.
B. Factors that will trigger a non-periodic review of client accounts
Reviews may be triggered by material markets, economic or political events, or by changes in a client’s financial
situations (such as retirement, termination of employment, physical move, or inheritance).
C. Content and Frequency of Regular Reports Provided to Clients
Depending upon the asset manager and custodian selected by AW, the custodian will deliver clients’ investment
asset statements either on a monthly or quarterly basis. AW does not directly construct or provide any statements
for investment accounts as we do not directly custody any clients’ assets. In addition to the custodian’s
statements, clients who engage our firm in “Total Wealth Management” (TWM) services have daily updating
account values via their eMoney personal financial website. Both client statements and the personal financial
website will include complete details of their client accounts such as prices per share, cost basis, unit values, and
total current values.
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Item 14: Client Referrals and Other Compensation
We do not receive any compensation from any third party in connection with providing investment advice to you
nor do we compensate any individual or firm for client referrals. We do not receive any economic benefits or
other compensation of any kind from any third parties in connection with the investment advice we render to our
clients. As your fiduciary, we always put your interests first. Our firm does not pay referral fees (non-commission
based) to independent solicitors (nonregistered representatives) for the referral of their clients to our firm.
Item 15: Custody
When you engage us for investment advisory agreements, your funds and securities will be held in an account
titled in your name and maintained at an independent qualified custodian. The custodian will be authorized to
execute trades within your account upon our instruction, acting within the scope of the discretionary authority you
grant us in our written investment advisory agreement and/or the custodian’s account opening documents. Except
for our ability to directly deduct our advisory fees, we will not maintain custody of any client funds or securities
or the authority to obtain possession of them. This ability to deduct our advisory fees from your accounts causes
our firm to exercise limited custody over your funds or securities.
You will receive account statements from the independent, qualified custodian(s) holding your funds and
securities at least quarterly. The account statements from your custodian(s) will indicate the amount of our
advisory fees deducted from your account(s) each billing period. You should carefully review account statements
for accuracy.
Item 16: Investment Discretion
In engaging our firm in an Investment Management relationship, you either grant our firm discretion or non-
discretion over the selection and amount of securities to be purchased or sold for your account(s) without
obtaining your consent or approval prior to each transaction. In all cases, we exercise this authority in a manner
consistent with our fiduciary duty to you and our understanding of your unique investment profile, objectives,
needs, and restrictions. Our discretionary authority is formalized in a written advisory agreement executed by the
client and in the account opening documents of your custodian.
Item 17: Voting Client Securities (Proxy Voting)
AW will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the
issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of security.
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Item 18: Financial Information
A. Balance Sheet
AW does not require the prepayment of any fees for services in advance that would exceed $500 and is therefore
not required to maintain individualized client balance sheets.
B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual
Commitments to Clients
Our firm does not have any financial condition or impairment that would prevent us from meeting our contractual
commitments to you. As required by SEC guidelines, we disclose that our firm did not accept any type of
government stimulus, loans, or financial incentives throughout the COVID-19 pandemic.
C. Bankruptcy
We have not filed a bankruptcy petition at any time in the past ten years, or ever. Therefore, we are not required to
include a financial statement with this brochure.
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