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Item 1: Cover Page
Part 2A of Form ADV: Firm Brochure
March 2025
23 Royal Road, Suite 101
Flemington, NJ 08822
www.AllianceWMG.com
Firm Contact:
Steven M. Fox
Chief Compliance Officer
This brochure provides information about the qualifications and business practices of Alliance
Wealth Management Group, LLC (“AWMG”). If clients have any questions about the contents of this
brochure, please contact us at 908-751-7093. The information in this brochure has not been
approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any
State Securities Authority. Additional information about AWMG is also available on the SEC’s website
at www.adviserinfo.sec.gov by searching CRD #169573.
Please note that the use of the term “registered investment adviser” and description of AWMG and/or
our associates as “registered” does not imply a certain level of skill or training. Clients are encouraged
to review this Brochure and Brochure Supplements for AWMG’s associates who advise clients for
more information on the qualifications of AWMG and our employees.
Item 2: Material Changes
Alliance Wealth Management Group, LLC is required to make clients aware of information that has
changed since the last annual update to the Firm Brochure (“Brochure”) and that may be important
to them. Clients can then determine whether to review the brochure in its entirety or to contact us
with questions about the changes.
Since our last annual amendment filing on 03/13/2024, we have the following material change(s) to
disclose:
• We have amended our firm’s ownership. As of 1/1/2024, AWMG is wholly owned by Steven
E. Linden and Steven Fox.
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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 & Compensation ............................................................................................................................................. 5
Item 6: Performance-Based Fees & Side-By-Side Management ........................................................................... 7
Item 7: Types of Clients & Account Requirements .................................................................................................... 7
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ................................................................... 8
Item 9: Disciplinary Information..................................................................................................................................... 15
Item 10: Other Financial Industry Activities & Affiliations .................................................................................. 16
Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ............. 16
Item 12: Brokerage Practices ........................................................................................................................................... 17
Item 13: Review of Accounts or Financial Plans ....................................................................................................... 21
Item 14: Client Referrals & Other Compensation ..................................................................................................... 22
Item 15: Custody .................................................................................................................................................................... 23
Item 16: Investment Discretion ....................................................................................................................................... 23
Item 17: Voting Client Securities ..................................................................................................................................... 24
Item 18: Financial Information ........................................................................................................................................ 24
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Item 4: Advisory Business
AWMG is dedicated to providing individuals and other types of clients with a wide array of
investment advisory services. AWMG is a limited liability company formed under the laws of the State
of Delaware in 2014. AWMG is wholly owned by Steven E. Linden and Steven Fox.
AWMG provides asset management and investment consulting services for many different types of
clients to help meet their financial goals while remaining sensitive to risk tolerance and time
horizons. As a fiduciary, it is our duty to always act in the client’s best interest. This is accomplished
in part by knowing the client. AWMG has established a service-oriented advisory practice with open
lines of communication. Working with clients to understand their investment objectives while
educating them about our process, facilitates the kind of working relationship we value.
Types of Advisory Services Offered
Investment & Wealth Management Services:
AWMG provides clients with wealth management services which may include financial planning
services, as well as the discretionary management of investment portfolios. Under a wealth management
engagement, AWMG primarily allocates client assets among mutual funds, exchange-traded funds and
individual debt and equity securities, in accordance with their stated investment objectives.
Clients may also engage AWMG to manage and/or advise on certain investment products that are not
maintained at their primary custodian, such as variable life insurance and annuity contracts and assets
held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these
situations, AWMG directs or recommends the allocation of client assets among the various investment
options available with the product. These assets are generally maintained at the underwriting insurance
company or the custodian designated by the product’s provider. Where appropriate, AWMG may also
provide advice about any type of legacy position or other investment held in client portfolios.
AWMG tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a
continuous basis, that client portfolios are managed in a manner consistent with those needs and
objectives. AWMG consults with clients on an initial and ongoing basis to assess their specific risk
tolerance, time horizon, liquidity constraints and other related factors relevant to the management of
their portfolios. Clients are advised to promptly notify AWMG if there are changes in their financial
situation or if they wish to place any limitations on the management of their portfolios.
Our firm utilizes the sub-advisory services of Towercrest Capital Management, LLC, a third party
investment advisory firm (“Sub-Adviser”), to aid in the implementation of an investment portfolio.
Financial Planning & Consulting Services:
AWMG offers clients a broad range of value-based financial planning and consulting services, which
may include any or all of the following functions: Business Planning, Cash Flow Forecasting, Trust &
Estate Planning, Insurance Planning, Retirement Planning, Charitable Giving, Distribution Planning,
Tax Planning, Manager Due Diligence and/or Risk Management.
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While each of these services is available on a stand-alone basis, certain services may also be rendered in
conjunction with investment portfolio management as part of a comprehensive wealth management
engagement.
In performing these services, AWMG is not required to verify any information received from the client
or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to
rely on such information. AWMG may recommend clients engage AWMG for additional related services,
its Supervised Persons in their individual capacities as insurance agents or registered representatives of
a broker-dealer and/or other professionals to implement its recommendations. Clients are advised that
a conflict of interest exists if clients engage AWMG or its affiliates to provide additional services for
compensation. Clients retain absolute discretion over all decisions regarding implementation and are
under no obligation to act upon any of the recommendations made by AWMG under a financial
planning or consulting engagement. Clients are advised that it remains their responsibility to
promptly notify AWMG of any change in their financial situation or investment objectives for the
purpose of reviewing, evaluating or revising AWMG’s recommendations and/or services.
Tailoring of Advisory Services
AWMG offers individualized investment advice to our Investment & Wealth Management clients.
General investment advice will be offered to our Financial Planning & Consulting clients. Each
Investment & Wealth Management client has the opportunity to place reasonable restrictions on the
types of investments to be held in the portfolio. Restrictions on investments in certain securities or
types of securities may not be possible due to the level of difficulty this would entail in managing the
account.
Participation in Wrap Fee Programs
AWMG does not offer or sponsor a wrap fee program.
Regulatory Assets Under Management
As of 12/31/2024, AWMG managed $424,154,401 on a discretionary basis and $0 on a non-
discretionary basis.
Item 5: Fees & Compensation
Compensation for Advisory Services
Investment & Wealth Management:
This service requires a minimum account balance of $500,000. In certain circumstances, this
minimum can be negotiated or waived at our firm’s discretion. The maximum annual fee charged for
this service will not exceed 1.95%. Fees to be assessed will be outlined in the advisory agreement to
be signed by the client. Annualized fees are billed on a pro-rata basis quarterly in advance based on
the value of the account(s) on the last day of the previous quarter. Fees are negotiable and will be
deducted from client account(s). Adjustments will be made for deposits and withdrawals during the
quarter. Our firm bills on cash unless indicated otherwise in writing. In rare cases, AWMG will agree
to direct bill clients. As part of our advisory fee deduction process, clients understand the following:
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a) The client’s independent custodian sends statements at least quarterly showing the market
values for each security included in the assets and all account disbursements, including the
amount of the advisory fees paid to AWMG and/or the Sub-Adviser.
b) Clients will provide authorization permitting AWMG and/or the Sub-Adviser to be directly
paid by these terms. AWMG will send an invoice directly to the custodian.
c) If AWMG sends a copy of our invoice to the client, it will include a disclosure urging the
comparison of information provided in our statement with those from the qualified
custodian.
If sub-advisory services are rendered to our clients, our firm compensates the Sub-Adviser a
percentage of the overall investment advisory fee charged by our firm. The advisory fee paid shall
not exceed the fee published for this service.
Financial Planning & Consulting:
Financial Planning fees are waived for any clients that engage AWMG for investment management
services. AWMG may provide stand-alone financial planning and/or consulting services for a fixed
and/or hourly fee. Fees are negotiable, but generally range from $3,500 to $15,000 on a fixed fee
basis and/or from $300 to $750 on an hourly basis, depending upon the scope and complexity of the
engagement and the professional rendering the financial planning and/or the consulting services. If
the client engages AWMG for additional investment advisory services, AWMG may offset all or a
portion of its fees for those services based upon the amount paid for the financial planning and/or
consulting services.
The terms and conditions of the financial planning and/or consulting engagement are set forth in the
Advisory Agreement to be signed by the client. AWMG generally requires 1/2 of the estimated fee
payable upon execution of the Advisory Agreement. The outstanding balance is generally due upon
delivery of the financial plan or completion of the agreed upon services. AWMG will not require pre-
payment of fees exceeding $1,200 when services cannot be rendered within 6 months.
Other Types of Fees & Expenses
Clients will incur transaction fees for trades executed by their chosen custodian. These transaction
fees are separate from our firm’s advisory fees and will be disclosed by the chosen custodian. Our
recommended custodian, Charles Schwab & Co., Inc. (“Schwab”), does not charge transaction fees for
U.S. listed equities and exchange traded funds.
Clients may also pay holdings charges imposed by the chosen custodian for certain investments,
charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be
disclosed in the fund’s prospectus (e.g., fund management fees), distribution fees, surrender charges,
variable annuity fees, IRA and qualified retirement plan fees, mark-ups and mark-downs, spreads
paid to market makers, fees for trades executed away from custodian, wire transfer fees and other
fees and taxes on brokerage accounts and securities transactions. Our firm does not receive a portion
of these fees.
Termination & Refunds
Either party may terminate the advisory agreement signed for Investment & Wealth Management
services by providing notice in writing to the other party at any time. Upon notice of termination,
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AWMG will process a pro-rata refund of any unearned portion of the advisory fees charged in advance
at the beginning of the quarter.
Financial Planning & Consulting clients may terminate their agreement at any time before the
delivery of a financial plan by providing written notice. For purposes of calculating refunds, all work
performed by AWMG up to the point of termination shall be calculated at the hourly fee currently in
effect. Clients will receive a pro-rata refund of unearned fees based on the time and effort expended
by AWMG.
Commissionable Securities Sales
AWMG’s representatives include registered representatives of Purshe Kaplan Sterling Investments,
Inc (“PKS”), member FINRA/SIPC. They are able to accept compensation for the sale of securities or
other investment products, including distribution or service (“trail”) fees from the sale of mutual
funds. Clients should be aware that the practice of accepting commissions for the sale of securities
presents a conflict of interest and gives AWMG and/or its representatives an incentive to recommend
investment products based on the compensation received. AWMG generally addresses
commissionable sales conflicts that arise when explaining to clients these sales create an incentive
to recommend based on the compensation to be earned and/or when recommending
commissionable mutual funds, explaining that “no-load” funds are also available. AWMG does not
prohibit clients from purchasing recommended investment products through other unaffiliated
brokers or agents.
Item 6: Performance-Based Fees & Side-By-Side Management
AWMG does not charge performance-based fees.
Item 7: Types of Clients & Account Requirements
AWMG has the following types of clients:
•
Individuals and High Net Worth Individuals;
• Trusts, Estates or Charitable Organizations;
• Pension and Profit Sharing Plans;
• Corporations, Limited Liability Companies and/or Other Business Types
Our firm does not impose requirements for opening and maintaining accounts or otherwise engaging
us.
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Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
General Risks of Owning Securities
The prices of securities held in client accounts and the income they generate may decline in response
to certain events taking place around the world. These include events directly involving the issuers
of securities held as underlying assets of mutual funds in a client’s account, conditions affecting the
general economy, and overall market changes. Other contributing factors include local, regional, or
global political, social, or economic instability and governmental or governmental agency responses
to economic conditions. Finally, currency, interest rate, and commodity price fluctuations may also
affect security prices and income.
The prices of, and the income generated by, most debt securities held by a client’s account may be
affected by changing interest rates and by changes in the effective maturities and credit ratings of
these securities. For example, the prices of debt securities in the client’s account generally will decline
when interest rates rise and increase when interest rates fall. In addition, falling interest rates may
cause an issuer to redeem, “call” or refinance a security before its stated maturity, which may result
in our firm having to reinvest the proceeds in lower yielding securities. Longer maturity debt
securities generally have higher rates of interest and may be subject to greater price fluctuations than
shorter maturity debt securities. Debt securities are also subject to credit risk, which is the possibility
that the credit strength of an issuer will weaken and/or an issuer of a debt security will fail to make
timely payments of principal or interest and the security will go into default.
The guarantee of a security backed by the U.S. Treasury or the full faith and credit of the U.S.
government only covers the timely payment of interest and principal when held to maturity. This
means that the current market values for these securities will fluctuate with changes in interest rates.
Investments in securities issued by entities based outside the United States may be subject to
increased levels of the risks described above. Currency fluctuations and controls, different
accounting, auditing, financial reporting, disclosure, regulatory and legal standards and practices
could also affect investments in securities of foreign issuers. Additional factors may include
expropriation, changes in tax policy, greater market volatility, different securities market structures,
and higher transaction costs.
Finally, various administrative difficulties, such as delays in clearing and settling portfolio
transactions, or in receiving payment of dividends can increase risk. Finally, investments in securities
issued by entities domiciled in the United States may also be subject to many of these risks.
Methods of Analysis
AWMG utilizes a largely fundamental method of analysis while employing an asset allocation strategy
based on a derivative of Modern Portfolio Theory.
Fundamental Analysis involves an evaluation of the fundamental financial condition and competitive
position of a particular fund or issuer. For AWMG, this process typically involves an analysis of an
issuer’s management team, investment strategies, style drift, past performance, reputation and
financial strength in relation to the asset class concentrations and risk exposures of AWMG’s model
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asset allocations. A substantial risk in relying upon fundamental analysis is that while the overall
health and position of a company may be good, evolving market conditions may negatively impact
the security.
Modern Portfolio Theory (“MPT”) is a mathematical based investment discipline that seeks to
quantify expected portfolio returns in relation to corresponding portfolio risk. The basic premise of
MPT is that the risk of a particular holding is to be assessed by comparing its price variations against
those of the market portfolio. However, MPT disregards certain investment considerations and is
based on a series of assumptions that may not necessarily reflect actual market conditions. As such,
the factors for which MPT does not account (e.g., tax implications, regulatory constraints and
brokerage costs) may negate the upside or add to the actual risk of a particular allocation.
Nevertheless, AWMG’s investment process is structured in such a way to integrate those assumptions
and real life considerations for which MPT analytics do not account.
Mutual Fund and/or Exchange Traded Fund (“ETF”) Analysis involves the examination of the
experience and track record of the manager of the mutual fund or ETF in an attempt to determine if
that manager has demonstrated an ability to invest over a period of time and in different economic
conditions. The underlying assets in a mutual fund or ETF are also reviewed in an attempt to
determine if there is significant overlap in the underlying investments held in another fund(s) in the
Client’s portfolio. The funds or ETFs are monitored in an attempt to determine if they are continuing
to follow their stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all
securities investments, past performance does not guarantee future results. A manager who has been
successful may not be able to replicate that success in the future. In addition, as our firm does not
control the underlying investments in a fund or ETF, managers of different funds held by the Client
may purchase the same security, increasing the risk to the Client if that security were to fall in value.
There is also a risk that a manager may deviate from the stated investment mandate or strategy of
the fund or ETF, which could make the holding(s) less suitable for the Client’s portfolio.
Sub-Adviser Analysis: The analysis of the experience, investment philosophies, and past
performance of independent third-party investment advisers in an attempt to determine if that
adviser has demonstrated an ability to invest over a period of time and in different economic
conditions. Analysis is completed by monitoring the adviser’s underlying holdings, strategies,
concentrations and leverage as part of our overall periodic risk assessment. Additionally, as part of
the due-diligence process, the adviser’s compliance and business enterprise risks are surveyed and
reviewed. A risk of investing with a sub-adviser who has been successful in the past is that they may
not be able to replicate that success in the future. In addition, as our firm does not control the
underlying investments in a sub-adviser’s portfolio, there is also a risk that a sub-adviser may deviate
from the stated investment mandate or strategy of the portfolio, making it a less suitable investment
for our clients. Moreover, as our firm does not control the sub-adviser’s daily business and
compliance operations, our firm may be unaware of the lack of internal controls necessary to prevent
business, regulatory or reputational deficiencies. The following investment strategies may be utilized
by chosen sub-advisers:
• Portfolio Diversification: Diversification is a risk management technique that mixes a wide
variety of investments within a portfolio. The rationale behind this technique contends that
a portfolio constructed of different kinds of investments will, on average, yield higher returns
and pose a lower risk than any individual investment found within the portfolio.
Diversification strives to smooth out unsystematic risk events in a portfolio so the positive
performance of some investments neutralizes the negative performance of others. Therefore,
the benefits of diversification hold only if the securities in the portfolio are not perfectly
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correlated. Further diversification benefits can be gained by investing in foreign securities
because they tend to be less closely correlated with domestic investments.
• Tactical Asset Allocation: Tactical asset allocation is a strategy in which an investor takes a
more active approach that tries to position a portfolio into those assets, sectors, or individual
stocks that show the most potential for perceived gains. While an original asset mix is
formulated much like strategic and dynamic portfolio, tactical strategies are often traded
more actively and are free to move entirely in and out of their core asset classes.
• Portfolio Rebalancing: Rebalancing is the process of realigning the weightings of a portfolio
of assets. Rebalancing involves periodically buying or selling assets in a portfolio to maintain
an original desired level of asset allocation. Rebalancing a portfolio involves the reallocation
of assets to a defined makeup. This applies whether the target allocation is 50/50, 70/30 or
40/60. Often, these steps are taken to ensure the amount of risk involved is at the investor's
desired level. As stock performance can vary more dramatically than bonds, the percentage
of assets associated with stocks will change with market conditions. Along with the
performance variable, investors may adjust the overall risk within their portfolios to meet
changing financial needs.
Investment Strategies & Asset Classes
Asset Allocation: The implementation of an investment strategy that attempts to balance risk versus
reward by adjusting the percentage of each asset in an investment portfolio according to the
investor's risk tolerance, goals and investment time frame. Asset allocation is based on the principle
that different assets perform differently in different market and economic conditions. A fundamental
justification for asset allocation is the notion that different asset classes offer returns that are not
perfectly correlated, hence diversification reduces the overall risk in terms of the variability of
returns for a given level of expected return. Although risk is reduced as long as correlations are not
perfect, it is typically forecast (wholly or in part) based on statistical relationships (like correlation
and variance) that existed over some past period. Expectations for return are often derived in the
same way.
An asset class is a group of economic resources sharing similar characteristics, such as riskiness and
return. There are many types of assets that may or may not be included in an asset allocation strategy.
The "traditional" asset classes are stocks (value, dividend, growth, or sector-specific [or a "blend" of
any two or more of the preceding]; large-cap versus mid-cap, small-cap or micro-cap; domestic,
foreign [developed], emerging or frontier markets), bonds (fixed income securities more generally:
investment-grade or junk [high-yield]; government or corporate; short-term, intermediate, long-
term; domestic, foreign, emerging markets), and cash or cash equivalents. Allocation among these
three provides a starting point. Usually included are hybrid instruments such as convertible bonds
and preferred stocks, counting as a mixture of bonds and stocks. Other alternative assets that may be
considered include: commodities: precious metals, nonferrous metals, agriculture, energy, others.;
Commercial or residential real estate (also REITs); Collectibles such as art, coins, or stamps;
insurance products (annuity, life settlements, catastrophe bonds, personal life insurance products,
etc.); derivatives such as long-short or market neutral strategies, options, collateralized debt, and
futures; foreign currency; venture capital; private equity; and/or distressed securities.
Debt Securities (Bonds): Issuers use debt securities to borrow money. Generally, issuers pay
investors periodic interest and repay the amount borrowed either periodically during the life of the
security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero
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coupon bonds, which do not pay current interest, but rather are priced at a discount from their face
values and their values accrete over time to face value at maturity. The market prices of debt
securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In
general, market prices of debt securities decline when interest rates rise and increase when interest
rates fall. Bonds with longer rates of maturity tend to have greater interest rate risks.
Certain additional risk factors relating to debt securities include: (a) When interest rates are
declining, investors have to reinvest their interest income and any return of principal, whether
scheduled or unscheduled, at lower prevailing rates.; (b) Inflation causes tomorrow’s dollar to be
worth less than today’s; in other words, it reduces the purchasing power of a bond investor’s future
interest payments and principal, collectively known as “cash flows.” Inflation also leads to higher
interest rates, which in turn leads to lower bond prices.; (c) Debt securities may be sensitive to
economic changes, political and corporate developments, and interest rate changes. Investors can
also expect periods of economic change and uncertainty, which can result in increased volatility of
market prices and yields of certain debt securities. For example, prices of these securities can be
affected by financial contracts held by the issuer or third parties (such as derivatives) relating to the
security or other assets or indices. (d) Debt securities may contain redemption or call provisions
entitling their issuers to redeem them at a specified price on a date prior to maturity. If an issuer
exercises these provisions in a lower interest rate market, the account would have to replace the
security with a lower yielding security, resulting in decreased income to investors. Usually, a bond is
called at or close to par value. This subjects investors that paid a premium for their bond risk of lost
principal. In reality, prices of callable bonds are unlikely to move much above the call price if lower
interest rates make the bond likely to be called.; (e) If the issuer of a debt security defaults on its
obligations to pay interest or principal or is the subject of bankruptcy proceedings, the account may
incur losses or expenses in seeking recovery of amounts owed to it.; (f) There may be little trading in
the secondary market for particular debt securities, which may affect adversely the account's ability
to value accurately or dispose of such debt securities. Adverse publicity and investor perceptions,
whether or not based on fundamental analysis, may decrease the value and/or liquidity of debt
securities.
Our firm attempts to reduce the risks described above through diversification of the client’s portfolio
and by credit analysis of each issuer, as well as by monitoring broad economic trends and corporate
and legislative developments, but there can be no assurance that our firm will be successful in doing
so. Credit ratings for debt securities provided by rating agencies reflect an evaluation of the safety of
principal and interest payments, not market value risk. The rating of an issuer is a rating agency's
view of past and future potential developments related to the issuer and may not necessarily reflect
actual outcomes. There can be a lag between the time of developments relating to an issuer and the
time a rating is assigned and updated.
Exchange Traded Funds: An ETF is a type of Investment Company (usually, an open-end fund or
unit investment trust) whose primary objective is to achieve the same return as a particular market
index. The vast majority of ETFs are designed to track an index, so their performance is close to that
of an index mutual fund, but they are not exact duplicates. A tracking error, or the difference between
the returns of a fund and the returns of the index, can arise due to differences in composition,
management fees, expenses, and handling of dividends. ETFs benefit from continuous pricing; they
can be bought and sold on a stock exchange throughout the trading day. Because ETFs trade like
stocks, you can place orders just like with individual stocks - such as limit orders, good-until-canceled
orders, stop loss orders etc. They can also be sold short. Traditional mutual funds are bought and
redeemed based on their net asset values (“NAV”) at the end of the day. ETFs are bought and sold at
the market prices on the exchanges, which resemble the underlying NAV but are independent of it.
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However, arbitrageurs will ensure that ETF prices are kept very close to the NAV of the underlying
securities. Although an investor can buy as few as one share of an ETF, most buy in board lots.
Anything bought in less than a board lot will increase the cost to the investor. Anyone can buy any
ETF no matter where in the world it trades. This provides a benefit over mutual funds, which
generally can only be bought in the country in which they are registered.
One of the main features of ETFs are their low annual fees, especially when compared to traditional
mutual funds. The passive nature of index investing, reduced marketing, and distribution and
accounting expenses all contribute to the lower fees. However, individual investors must pay a
brokerage commission to purchase and sell ETF shares; for those investors who trade frequently,
this can significantly increase the cost of investing in ETFs. That said, with the advent of low-cost
brokerage fees, small or frequent purchases of ETFs are becoming more cost efficient.
Fixed Income: Fixed income is a type of investing or budgeting style for which real return rates or
periodic income is received at regular intervals and at reasonably predictable levels. Fixed-income
investors are typically retired individuals who rely on their investments to provide a regular, stable
income stream. This demographic tends to invest heavily in fixed-income investments because of the
reliable returns they offer. Fixed-income investors who live on set amounts of periodically paid
income face the risk of inflation eroding their spending power.
Some examples of fixed-income investments include treasuries, money market instruments,
corporate bonds, asset-backed securities, municipal bonds and international bonds. The primary risk
associated with fixed-income investments is the borrower defaulting on his payment. Other
considerations include exchange rate risk for international bonds and interest rate risk for longer-
dated securities. The most common type of fixed-income security is a bond. Bonds are issued by
federal governments, local municipalities and major corporations. Fixed-income securities are
recommended for investors seeking a diverse portfolio; however, the percentage of the portfolio
dedicated to fixed income depends on your own personal investment style. There is also an
opportunity to diversify the fixed-income component of a portfolio. Riskier fixed-income products,
such as junk bonds and longer-dated products, should comprise a lower percentage of your overall
portfolio.
The interest payment on fixed-income securities is considered regular income and is determined
based on the creditworthiness of the borrower and current market rates. In general, bonds and fixed-
income securities with longer-dated maturities pay a higher rate, also referred to as the coupon rate,
because they are considered riskier. The longer the security is on the market, the more time it has to
lose its value and/or default. At the end of the bond term, or at bond maturity, the borrower returns
the amount borrowed, also referred to as the principal or par value.
Individual Stocks: A common stock is a security that represents ownership in a corporation. Holders
of common stock exercise control by electing a board of directors and voting on corporate policy.
Investing in individual common stocks provides us with more control of what you are invested in and
when that investment is made. Having the ability to decide when to buy or sell helps us time the
taking of gains or losses. Common stocks, however, bear a greater amount of risk when compared to
certificate of deposits, preferred stock and bonds. It is typically more difficult to achieve
diversification when investing in individual common stocks. Additionally, common stockholders are
on the bottom of the priority ladder for ownership structure; if a company goes bankrupt, the
common stockholders do not receive their money until the creditors and preferred shareholders
have received their respective share of the leftover assets.
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Mutual Funds: A mutual fund is a company that pools money from many investors and invests the
money in a variety of differing security types based the objectives of the fund. The portfolio of the
fund consists of the combined holdings it owns. Each share represents an investor’s proportionate
ownership of the fund’s holdings and the income those holdings generate. The price that investors
pay for mutual fund shares is the fund’s per share net asset value (“NAV”) plus any shareholder fees
that the fund imposes at the time of purchase (such as sales loads). Investors typically cannot
ascertain the exact make-up of a fund’s portfolio at any given time, nor can they directly influence
which securities the fund manager buys and sells or the timing of those trades. With an individual
stock, investors can obtain real-time (or close to real-time) pricing information with relative ease by
checking financial websites or by calling a broker or your investment adviser. Investors can also
monitor how a stock’s price changes from hour to hour—or even second to second. By contrast, with
a mutual fund, the price at which an investor purchases or redeems shares will typically depend on
the fund’s NAV, which is calculated daily after market close.
The benefits of investing through mutual funds include: (a) Mutual funds are professionally managed
by an investment adviser who researches, selects, and monitors the performance of the securities
purchased by the fund; (b) Mutual funds typically have the benefit of diversification, which is an
investing strategy that generally sums up as “Don’t put all your eggs in one basket.” Spreading
investments across a wide range of companies and industry sectors can help lower the risk if a
company or sector fails. Some investors find it easier to achieve diversification through ownership of
mutual funds rather than through ownership of individual stocks or bonds.; (c) Some mutual funds
accommodate investors who do not have a lot of money to invest by setting relatively low dollar
amounts for initial purchases, subsequent monthly purchases, or both.; and (d) At any time, mutual
fund investors can readily redeem their shares at the current NAV, less any fees and charges assessed
on redemption.
Mutual funds also have features that some investors might view as disadvantages: (a) Investors must
pay sales charges, annual fees, and other expenses regardless of how the fund performs. Depending
on the timing of their investment, investors may also have to pay taxes on any capital gains
distribution they receive. This includes instances where the fund went on to perform poorly after
purchasing shares.; (b) Investors typically cannot ascertain the exact make-up of a fund’s portfolio at
any given time, nor can they directly influence which securities the fund manager buys and sells or
the timing of those trades.; and (c) With an individual stock, investors can obtain real-time (or close
to real-time) pricing information with relative ease by checking financial websites or by calling a
broker or your investment adviser. Investors can also monitor how a stock’s price changes from hour
to hour—or even second to second. By contrast, with a mutual fund, the price at which an investor
purchases or redeems shares will typically depend on the fund’s NAV, which the fund might not
calculate until many hours after the investor placed the order. In general, mutual funds must calculate
their NAV at least once every business day, typically after the major U.S. exchanges close.
When investors buy and hold an individual stock or bond, the investor must pay income tax each year
on the dividends or interest the investor receives. However, the investor will not have to pay any
capital gains tax until the investor actually sells and makes a profit. Mutual funds are different. When
an investor buys and holds mutual fund shares, the investor will owe income tax on any ordinary
dividends in the year the investor receives or reinvests them. Moreover, in addition to owing taxes
on any personal capital gains when the investor sells shares, the investor may have to pay taxes each
year on the fund’s capital gains. That is because the law requires mutual funds to distribute capital
gains to shareholders if they sell securities for a profit, and cannot use losses to offset these gains.
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Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. While the stock
market may increase and the account(s) could enjoy a gain, it is also possible that the stock market
may decrease and the account(s) could suffer a loss. It is important that clients understand the risks
associated with investing in the stock market, are appropriately diversified in investments, and ask
any questions.
Capital Risk: Capital risk is one of the most basic, fundamental risks of investing; it is the risk that
you may lose 100% of your money. All investments carry some form of risk and the loss of capital is
generally a risk for any investment instrument.
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 the risk that the company will
perform poorly or have its value 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 may be reduced.
Credit Risk: Credit risk can be a factor in situations where an investment’s performance relies on a
borrower’s repayment of borrowed funds. With credit risk, an investor can experience a loss or
unfavorable performance if a borrower does not repay the borrowed funds as expected or required.
Investment holdings that involve forms of indebtedness (i.e. borrowed funds) are subject to credit
risk.
Currency Risk: Fluctuations in the value of the currency in which your investment is denominated
may affect the value of your investment and thus, your investment may be worth more or less in the
future. All currency is subject to swings in valuation and thus, regardless of the currency
denomination of any particular investment you own, currency risk is a realistic risk measure. That
said, currency risk is generally a much larger factor for investment instruments denominated in
currencies other than the most widely used currencies (U.S. dollar, British pound, German mark,
Euro, Japanese yen, French franc, etc.).
Economic Risk: The prevailing economic environment is important to the health of all businesses.
Some companies, however, are more sensitive to changes in the domestic or global economy than
others. These types of companies are often referred to as cyclical businesses. Countries in which a
large portion of businesses are in cyclical industries are thus also very economically sensitive and
carry a higher amount of economic risk. If an investment is issued by a party located in a country that
experiences wide swings from an economic standpoint or in situations where certain elements of an
investment instrument are hinged on dealings in such countries, the investment instrument will
generally be subject to a higher level of economic risk.
ETF & 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. Clients will also
incur brokerage costs when purchasing ETFs.
Financial Risk: Financial risk is represented by internal disruptions within an investment or the
issuer of an investment that can lead to unfavorable performance of the investment. Examples of
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Alliance Wealth Management Group, LLC
financial risk can be found in cases like Enron or many of the dot com companies that were caught
up in a period of extraordinary market valuations that were not based on solid financial footings of
the companies.
Inflation Risk: Inflation risk involves the concern that in the future, your investment or proceeds
from your investment will not be worth what they are today. Throughout time, the prices of resources
and end-user products generally increase and thus, the same general goods and products today will
likely be more expensive in the future. The longer an investment is held, the greater the chance that
the proceeds from that investment will be worth less in the future than what they are today. Said
another way, a dollar tomorrow will likely get you less than what it can today.
Interest Rate Risk: Certain investments involve the payment of a fixed or variable rate of interest to
the investment holder. Once an investor has acquired or has acquired the rights to an investment that
pays a particular rate (fixed or variable) of interest, changes in overall interest rates in the market
will affect the value of the interest-paying investment(s) they hold. In general, changes in prevailing
interest rates in the market will have an inverse relationship to the value of existing, interest paying
investments. In other words, as interest rates move up, the value of an instrument paying a particular
rate (fixed or variable) of interest will go down. The reverse is generally true as well.
Legal/Regulatory Risk: Certain investments or the issuers of investments may be affected by
changes in state or federal laws or in the prevailing regulatory framework under which the
investment instrument or its issuer is regulated. Changes in the regulatory environment or tax laws
can affect the performance of certain investments or issuers of those investments and thus, can have
a negative impact on the overall performance of such investments.
Liquidity Risk: Certain assets may not be readily converted into cash or may have a very limited
market in which they trade. Thus, you may experience the risk that your investment or assets within
your investment may not be able to be liquidated quickly, thus, extending the period of time by which
you may receive the proceeds from your investment. Liquidity risk can also result in unfavorable
pricing when exiting (i.e. not being able to quickly get out of an investment before the price drops
significantly) a particular investment and therefore, can have a negative impact on investment
returns.
Market Risk: Investing involves risk, including the potential loss of principal, and all investors
should be guided accordingly. The profitability of a significant portion of AWMG’s recommendations
and/or investment decisions may depend to a great extent upon correctly assessing the future course
of price movements of stocks, bonds and other asset classes. There can be no assurance that AWMG
will be able to predict those price movements accurately or capitalize on any such assumptions.
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to the evaluation of AWMG’s advisory
business or the integrity of AWMG’s management.
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Item 10: Other Financial Industry Activities & Affiliations
AWMG’s representatives include registered representatives of PKS, member FINRA/SIPC, and
licensed insurance agents. As a result of these transactions, they receive normal and customary
commissions. A conflict of interest exists as these commissionable securities sales create an incentive
to recommend products based on the compensation earned. To mitigate this potential conflict,
AWMG will act in the client’s best interest.
Mr. Linden and Mr. McCabe are Certified Public Accountants with an accounting firm under common
ownership with Alliance Accounting Group (“AAG”). AWMG does not render accounting services to
clients. AWMG may recommend that certain advisory clients engage AAG to render various
accounting and tax preparation services. While AWMG does not receive a fee for referrals to AAG, Mr.
Linden and Mr. McCabe are generally entitled to receive distributions relative to their ownership
stake in AAG. A conflict of interest exists to the extent that AWMG recommends the services of AAG
where Mr. Linden and Mr. McCabe receive compensation as a result. AWMG seeks to ensure that all
such recommendations are made in its client’s best interests.
Please see Item 4 above for more information about the use of a Sub-Adviser. The compensation paid
to a Sub-Adviser may vary, and thus, creates a conflict of interest in recommending a Sub-Adviser who
shares a smaller portion of the advisory fees over another Sub-Adviser. Prior to the use of a Sub-
Adviser, our firm will ensure that the Sub-Adviser is licensed or notice filed with the respective
authorities. In order to minimize this conflict, our firm will make our recommendations/selections
in the best interest of our clients.
Item 11: Code of Ethics, Participation or Interest in
Client Transactions & Personal Trading
As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material
facts and to act solely in the best interest of each of our clients at all times. AWMG’s fiduciary duty is the
underlying principle for AWMG’s Code of Ethics, which includes procedures for personal securities
transaction and insider trading. AWMG requires all representatives to conduct business with the highest
level of ethical standards and to comply with all federal and state securities laws at all times. Upon
employment with AWMG, and at least annually thereafter, all representatives of AWMG will
acknowledge receipt, understanding and compliance with AWMG’s Code of Ethics. AWMG and
representatives must conduct business in an honest, ethical, and fair manner and avoid all circumstances
that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure
is provided to give all clients a summary of our Code of Ethics. If a client or a potential client wishes to
review our Code of Ethics in its entirety, a copy will be provided promptly upon request.
AWMG recognizes that the personal investment transactions of our representatives demands the
application of a Code of Ethics with high standards and requires that all such transactions be carried out
in a way that does not endanger the interest of any client. At the same time, AWMG also believes that if
investment goals are similar for clients and for our representatives, it is logical, and even desirable, that
there be common ownership of some securities.
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In order to prevent conflicts of interest, AWMG has established procedures for transactions effected by
our representatives for their personal accounts1. In order to monitor compliance with our personal
trading policy, AWMG has pre-clearance requirements and a quarterly securities transaction reporting
system for all of our representatives.
Neither AWMG nor a related person recommends, buys or sells for client accounts, securities in which
AWMG or a related person has a material financial interest without prior disclosure to the client.
Related persons of AWMG may buy or sell securities and other investments that are also
recommended to clients. In order to minimize this conflict of interest, our related persons will place
client interests ahead of their own interests and adhere to AWMG’s Code of Ethics, a copy of which is
available upon request.
Likewise, related persons of AWMG buy or sell securities for themselves at or about the same time they
buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our
related persons will place client interests ahead of their own interests and adhere to AWMG’s Code of
Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying
or selling the same securities prior to buying or selling for our clients in the same day unless it has been
pre-cleared by the CCO.
Item 12: Brokerage Practices
Selecting a Brokerage Firm
AWMG does not maintain custody of client assets. Client assets must be maintained by a qualified
custodian. AWMG seeks to recommend a custodian who will hold client assets and execute
transactions on terms that are overall most advantageous when compared to other available
providers and their services. The factors considered, among others, are these:
• Timeliness of execution
• Timeliness and accuracy of trade confirmations
• Research services provided
• Ability to provide investment ideas
• Execution facilitation services provided
• Record keeping services provided
• Custody services provided
• Frequency and correction of trading errors
• Ability to access a variety of market venues
• Expertise as it relates to specific securities
• Financial condition
• Business reputation
• Quality of services
With this in consideration, AWMG has an arrangement with Charles Schwab & Co., Inc. (“Schwab”), a
qualified custodian from whom AWMG is independently owned and operated. Schwab offers services
1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse, his/her minor children
or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our associate controls, including our client
accounts which our associate controls and/or a member of his/her household has a direct or indirect beneficial interest in.
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to independent investment advisers which includes custody of securities, trade execution, clearance
and settlement of transactions. Schwab enables AWMG to obtain many no-load mutual funds without
transaction charges and other no-load funds at nominal transaction charges. Schwab does not charge
client accounts separately for custodial services. Client accounts will be charged transaction fees,
commissions or other fees on trades that are executed or settle into the client’s custodial account.
Transaction fees are negotiated with Schwab and are generally discounted from customary retail
commission rates. This benefits clients because the overall fee paid is often lower than would be
otherwise.
Schwab may make certain educational, research and brokerage services available at no additional
cost to AWMG. Research products and services provided by Schwab may include: research reports on
recommendations or other information about particular companies or industries; economic surveys,
data and analyses; financial publications; portfolio evaluation services; financial database software and
services; computerized news and pricing services; quotation equipment for use in running software
used in investment decision-making; and other products or services that provide lawful and appropriate
assistance by Schwab to AWMG in the performance of our investment decision-making responsibilities.
The aforementioned research and brokerage services qualify for the safe harbor exemption defined in
Section 28(e) of the Securities Exchange Act of 1934.
Schwab does not make client brokerage commissions generated by client transactions available for
AWMG’s use. The aforementioned research and brokerage services are used by AWMG to manage
accounts for which AWMG has investment discretion. Without this arrangement, AWMG might be
compelled to purchase the same or similar services at our own expense.
As part of our fiduciary duty to our clients, AWMG will endeavor at all times to put the interests of
our clients first. Clients should be aware, however, that the receipt of economic benefits by AWMG or
our related persons creates a potential conflict of interest and may indirectly influence AWMG’s
choice of Schwab as a custodial recommendation. AWMG examined this potential conflict of interest
when AWMG chose to recommend Schwab and have determined that the recommendation is in the best
interest of AWMG’s clients and satisfies our fiduciary obligations, including our duty to seek best
execution.
Our clients may pay a transaction fee or commission to Schwab that is higher than another qualified
broker dealer might charge to effect the same transaction where AWMG determines in good faith that
the commission is reasonable in relation to the value of the brokerage and research services provided
to the client as a whole.
In seeking best execution, the determinative factor is not the lowest possible cost, but whether the
transaction represents the best qualitative execution, taking into consideration the full range of a
broker-dealer’s services, including the value of research provided, execution capability, commission
rates, and responsiveness. Although AWMG will seek competitive rates, to the benefit of all clients,
AWMG may not necessarily obtain the lowest possible commission rates for specific client account
transactions.
Products and Services Available to Us from Schwab
Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like
ours. They provide us and our clients with access to their institutional brokerage services (trading,
custody, reporting, and related services), many of which are not typically available to Schwab retail
customers. However, certain retail investors may be able to get institutional brokerage services from
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Schwab without going through our firm. Schwab also makes available various support services. Some
of those services help us manage or administer our clients’ accounts, while others help us manage
and grow our business. Schwab’s support services are generally available at no charge to us.
Following is a more detailed description of Schwab’s support services:
Services That Benefit Clients
Schwab’s institutional brokerage services include access to a broad range of investment products,
execution of securities transactions, and custody of client assets. The investment products available
through Schwab include some to which we might not otherwise have access or that would require a
significantly higher minimum initial investment by our clients. Schwab’s services described in this
paragraph generally benefit you and your account.
Services That Do Not Directly Benefit Clients
Schwab also makes available to us other products and services that benefit us but do not directly
benefit you or your account. These products and services assist us in managing and administering
our clients’ accounts and operating our firm. They include investment research, both Schwab’s own
and that of third parties. We use this research to service all or a substantial number of our clients’
accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab
also makes available software and other technology that:
• Provide access to client account data (such as duplicate trade confirmations and account
statements)
• Facilitate trade execution and allocate aggregated trade orders for multiple client accounts
• Provide pricing and other market data
• Facilitate payment of our fees from our clients’ accounts
• Assist with back-office functions, record keeping, and client reporting
Services that Generally Only Benefit Us
Schwab also offers other services intended to help us manage and further develop our business
enterprise. These services include:
• Educational conferences and events
• Consulting on technology and business needs
• Publications and conferences on practice management and business succession
• Access to employee benefits providers, human capital consultants, and insurance providers
• Marketing consulting and support
Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors
to provide the services to us. Schwab also discounts or waives its fees for some of these services or
pays all or a part of a third party’s fees. Schwab also provides us with other benefits, such as
occasional business entertainment of our personnel. If you did not maintain your account with
Schwab, we would be required to pay for these services from our own resources.
Our Interest in Schwab’s Services
The availability of these services from Schwab benefits us because we do not have to produce or
purchase them. We don’t have to pay for Schwab’s services. These services are not contingent upon
us committing any specific amount of business to Schwab in trading commissions or assets in
custody. The fact that we receive these benefits from Schwab is an incentive for us to recommend the
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use of Schwab rather than making such decision based exclusively on your interest in receiving the
best value in custody services and the most favorable execution of your transactions. This is a conflict
of interest. We believe, however, that taken in the aggregate, our recommendation of Schwab as
custodian and broker is in the best interests of our clients. Our selection is primarily supported by
the scope, quality, and price of Schwab’s services and not Schwab’s services that benefit only us.
Soft Dollars
AWMG does not receive soft dollars in excess of what is allowed by Section 28(e) of the Securities
Exchange Act of 1934. The safe harbor research products and services obtained by AWMG will
generally be used to service all of our clients but not necessarily all at any one particular time.
Client Brokerage Commissions
Schwab does not make client brokerage commissions generated by client transactions available for
AWMG’s use.
Client Transactions in Return for Soft Dollars
AWMG does not direct client transactions to a particular broker-dealer in return for soft dollar
benefits.
Brokerage for Client Referrals
AWMG does not receive brokerage for client referrals.
Directed Brokerage
The client may direct AWMG in writing to use a particular Financial Institution to execute some or all
transactions for the client. In that case, the client will negotiate terms and arrangements for the
account with that Financial Institution and AWMG will not seek better execution services or prices
from other Financial Institutions or be able to “batch” client transactions for execution through other
Financial Institutions with orders for other accounts managed by AWMG. As a result, the client may
pay higher commissions or other transaction costs, greater spreads or may receive less favorable net
prices, on transactions for the account than would otherwise be the case. Subject to its duty of best
execution, AWMG may decline a client’s request to direct brokerage if, in AWMG’s sole discretion,
such directed brokerage arrangement would result in additional operational difficulties or violate
restrictions imposed by other broker-dealers (as further discussed below).
Special Considerations for ERISA Clients
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account
through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such
direction is permitted provided that the goods and services provided are reasonable expenses of the
plan incurred in the ordinary course of its business for which it otherwise would be obligated and
empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services
purchased are not for the exclusive benefit of the plan. Consequently, AWMG will request that plan
sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will
be for the exclusive benefit of the plan.
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Aggregation of Purchase or Sale
Transactions for each client generally will be effected independently, unless AWMG decides to
purchase or sell the same securities for several clients at approximately the same time. AWMG may
(but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more
favorable commission rates or to allocate equitably among AWMG’s clients differences in prices and
commissions or other transaction costs that might not have been obtained had such orders been
placed independently. Under this procedure, transactions will generally be averaged as to price and
allocated among AWMG’s clients pro-rata to the purchase and sale orders placed for each client on
any given day. To the extent that AWMG determines to aggregate client orders for the purchase or
sale of securities, including securities in which AWMG’s Supervised Persons may invest, AWMG
generally does so in accordance with applicable rules promulgated under the Advisers Act and no-
action guidance provided by the staff of the U.S. Securities and Exchange Commission. AWMG does
not receive any additional compensation or remuneration as a result of the aggregation.
In the event that AWMG determines that a prorated allocation is not appropriate under the particular
circumstances, the allocation will be made based upon other relevant factors, which may include: (i)
when only a small percentage of the order is executed, shares may be allocated to the account with
the smallest order or the smallest position or to an account that is out of line with respect to security
or sector weightings relative to other portfolios, with similar mandates; (ii) allocations may be given
to one account when one account has limitations in its investment guidelines which prohibit it from
purchasing other securities which are expected to produce similar investment results and can be
purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot
participate in an allocation, shares may be reallocated to other accounts (this may be due to
unforeseen changes in an account’s assets after an order is placed); (iv) with respect to sale
allocations, allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation
of a potential execution would result in a de minimis allocation in one or more accounts, AWMG may
exclude the account(s) from the allocation; the transactions may be executed on a pro rata basis
among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in
all accounts, shares may be allocated to one or more accounts on a random basis.
Item 13: Review of Accounts or Financial Plans
Our management personnel or financial advisors review accounts on at least a quarterly basis for our
Investment & Wealth Management clients. The nature of these reviews is to learn whether client
accounts are in line with their investment objectives, appropriately positioned based on market
conditions, and investment policies, if applicable. AWMG does not provide written reports to clients,
unless asked to do so. Verbal reports to clients take place on at least an annual basis when our
Investment & Wealth Management clients are contacted.
Clients are provided with transaction confirmation notices and regular summary account statements
directly from the Financial Institutions where their assets are custodied. From time-to-time or as
otherwise requested, clients may also receive written or electronic reports from AWMG and/or an
outside service provider, which contain certain account and/or market-related information, such as
an inventory of account holdings or account performance. Clients should compare the account
statements they receive from their custodian with any documents or reports they receive from
AWMG or an outside service provider.
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AWMG may review client accounts more frequently than described above. Among the factors which
may trigger an off-cycle review are major market or economic events, the client’s life events, requests
by the client, etc.
Financial Planning clients do not receive reviews of their written plans unless they take action to
schedule a financial consultation with us. AWMG does not provide ongoing services to financial
planning clients, but are willing to meet with such clients upon their request to discuss updates to
their plans, changes in their circumstances, etc. Financial Planning clients do not receive written or
verbal updated reports regarding their financial plans unless they separately engage AWMG for a
post-financial plan meeting or update to their initial written financial plan.
Item 14: Client Referrals & Other Compensation
Charles Schwab & Co., Inc.
We receive an economic benefit from Schwab in the form of the support products and services it
makes available to us and other independent investment advisors that have their clients maintain
accounts at Schwab. These products and services, how they benefit us, and the related conflicts of
interest are described above (see Item 12 – Brokerage Practices). The availability to us of Schwab’s
products and services is not based on us giving particular investment advice, such as buying
particular securities for our clients.
Referral Fees
In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm provides cash or
non-cash compensation directly or indirectly to unaffiliated persons for testimonials or
endorsements (which include client referrals). Such compensation arrangements will not result in
higher costs to the referred client. In this regard, our firm maintains a written agreement with each
unaffiliated person that is compensated for testimonials or endorsements in an aggregate amount of
$1,000 or more (or the equivalent value in non-cash compensation) over a trailing 12-month period
in compliance with Rule 206 (4)-1 of the Investment Advisers Act of 1940 and applicable state and
federal laws. The following information will be disclosed clearly and prominently to referred
prospective clients at the time of each testimonial or endorsement:
• Whether or not the unaffiliated person is a current client of our firm,
• A description of the cash or non-cash compensation provided directly or indirectly by our
firm to the unaffiliated person in exchange for the referral, if applicable, and
• A brief statement of any material conflicts of interest on the part of the unaffiliated person
giving the referral resulting from our firm’s relationship with such unaffiliated person.
In cases where state law requires licensure of solicitors, our firm ensures that no solicitation fees are
paid unless the solicitor is registered as an investment adviser representative of our firm. If our firm
is paying solicitation fees to another registered investment adviser, the licensure of individuals is the
other firm’s responsibility.
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Item 15: Custody
All of our clients receive account statements directly from their qualified custodians at least quarterly
upon opening of an account. If AWMG decides to also send account statements to clients, such notice
and account statements include a legend that recommends that the client compare the account
statements received from the qualified custodian with those received from AWMG.
The SEC issued a no‐action letter (“Letter”) with respect to the Rule 206(4)‐2 (“Custody Rule”) under
the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody
Rule as well as clarified that an adviser who has the power to disburse client funds to a third party
under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, our firm has
adopted the following safeguards:
• The client provides an instruction to the qualified custodian, in writing, that includes the
client’s signature, the third party’s name, and either the third party’s address or the third
party’s account number at a custodian to which the transfer should be directed.
• The client authorizes the investment adviser, in writing, either on the qualified custodian’s
form or separately, to direct transfers to the third party either on a specified schedule or from
time to time.
• The client’s qualified custodian performs appropriate verification of the instruction, such as
a signature review or other method to verify the client’s authorization, and provides a
transfer of funds notice to the client promptly after each transfer.
• The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
• The investment adviser has no authority or ability to designate or change the identity of the
third party, the address, or any other information about the third party contained in the
client’s instruction.
• The investment adviser maintains records showing that the third party is not a related party
of the investment adviser or located at the same address as the investment adviser.
• The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
Clients are encouraged to raise any questions with us about the custody, safety or security of their
assets and our custodial recommendations.
Item 16: Investment Discretion
Clients are required to provide AWMG with investment discretion on their behalf, pursuant to an
executed investment advisory client agreement. By granting investment discretion, AWMG is
authorized to execute securities transactions, determine which securities are bought and sold, and
the total amount to be bought and sold. Limitations may be imposed by the client in the form of
specific constraints on any of these areas of discretion with AWMG’s written acknowledgement.
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Alliance Wealth Management Group, LLC
Item 17: Voting Client Securities
AWMG does not accept the proxy authority to vote client securities. Clients will receive proxies or
other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent
to AWMG, AWMG will forward them to the appropriate client and ask the party who sent them to
mail them directly to the client in the future. Clients may call, write or email us to discuss questions
they may have about particular proxy votes or other solicitations.
Item 18: Financial Information
AWMG is not required to provide financial information in this Brochure because:
• AWMG does not require the prepayment of more than $1,200 in fees and six or more months
in advance.
• AWMG does not take custody of client funds or securities.
• AWMG does not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
AWMG has never been the subject of a bankruptcy proceeding.
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Alliance Wealth Management Group, LLC