Overview
- Headquarters
- Santa Monica, CA
- Total Firm Assets
- $2.8 billion
- Average High-Net-Worth Client Portfolio Size
- $12.2 million
- Stated Minimum Account Size
- $5,000,000
Fee Disclosure
AWM ADV 2A 8.12.2026
| Min | Max | Disclosed Annual Rate |
|---|---|---|
| $0 | and above | 0.50% – 1.00% |
Stated Minimum Annual Fee: $50,000
Estimated Annual Fees (Based on ADV disclosures. Where a range is given, we use the upper rate)
| Portfolio Value | Estimated Annual Fee | Effective Fee Rate |
|---|---|---|
| $1 million | Below minimum client size | |
| $5 million | $50,000 | 1.00% |
| $10 million | $100,000 | 1.00% |
| $50 million | $500,000 | 1.00% |
| $100 million | $1,000,000 | 1.00% |
Clients
- High-Net-Worth Share of Firm Assets
- 87.77%
- Number of High-Net-Worth Clients
- 203
- Total Client Accounts
- 212
- Discretionary Accounts
- 188
- Non-Discretionary Accounts
- 24
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 159952
Additional Brochure: AWM ADV 2A 8.12.2026 (2026-08-12)
View Document Text
Angeles Wealth Management, LLC
Form ADV 2A
Angeles Wealth Management Brochure
ITEM 1 – COVER PAGE
Part 2A of Form ADV
Brochure for:
ANGELES WEALTH MANAGEMENT, LLC
429 Santa Monica Boulevard, Suite 650 Santa Monica, CA 90401
(310) 393-6300
www.angeleswealth.com
August 12, 2026
This brochure provides information about the qualifications and business practices of
Angeles Wealth Management, LLC (“AWM”). If you have any questions about the
contents of this brochure, please contact Edward Lowndes at (310) 857-5843 or
elowndes@angeleswealth.com. 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.
Registration of an Investment Adviser does not imply any certain level of skill or
training.
Additional information about Angeles Wealth Management, LLC also is available on the
SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for the
advisor is 159952.
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ITEM 2 – SUMMARY OF MATERIAL CHANGES
This current brochure is dated August 12, 2026, and replaces the Annual Amendment brochure dated
March 31, 2026. The following material changes were made since the filing of our Annual
Amendment brochure dated March 31, 2026:
Item 14 – Added description of AWM’s internal referral program
This Item only includes (i) the material changes that were made from the last annual update and (ii)
the date of our last annual amendment. We will provide clients with a summary of any material
changes to this and subsequent brochures within 120 days of the close of our fiscal year end,
December 31. As necessary, we will provide ongoing disclosure regarding material changes made to
the brochure.
Further, we will provide Clients with a new brochure, as needed, based on changes or new
information, at any time, without charge. Currently, our brochure may be requested by calling
(310) 857-5843 or by emailing elowndes@angeleswealth.com.
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ITEM 3 – TABLE OF CONTENTS
ITEM 1 – COVER PAGE ............................................................................................................................ 1
ITEM 2 – MATERIAL CHANGES ............................................................................................................ 2
ITEM 3 – TABLE OF CONTENTS ............................................................................................................ 3
ITEM 4 – ADVISORY BUSINESS .............................................................................................................. 4
ITEM 5 – FEES AND COMPENSATION .................................................................................................. 6
ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .......................... 7
ITEM 7 – TYPES OF CLIENTS .................................................................................................................. 7
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ........... 8
ITEM 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………………………………………………………………....14
ITEM 13 – REVIEW OF ACCOUNTS ...................................................................................................... 17
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION ................................................ 18
ITEM 15 – CUSTODY ................................................................................................................................ 18
ITEM 16 – INVESTMENT DISCRETION ............................................................................................... 18
ITEM 17 – VOTING CLIENT SECURITIES .......................................................................................... 18
ITEM 18 – FINANCIAL INFORMATION .............................................................................................. 18
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ITEM 4 – ADVISORY BUSINESS
Angeles Wealth Management, LLC (“AWM” or the “Company”), is a Delaware limited liability
company, that was formed in November 2011 by the principal owners Jonathan R. Foster and Angeles
Investment Advisors, LLC (“AIA”), an SEC-registered investment adviser and the majority owner of
AWM. AIA is principally owned by Howard Perlow and Michael Rosen. AWM primarily operates out
of Santa Monica, California, in an office that it shares with AIA. AWM also maintains offices in New
York, New York and Houston, Texas. AWM and AIA are both 100% employee owned. For further
information about AIA, please refer to AIA’s brochure available on the SEC’s website at
www.adviserinfo@sec.gov.
AWM is also affiliated with Angeles Family Office (“AFO”). AFO is a Delaware limited liability
company formed in 2025 and is an SEC-registered investment adviser. AFO is principally owned by
Adam B. Stern, Jason R. Oclaray, and AWM. AFO primarily operates out of the same office as AWM
and AIA in Santa Monica, California, but also operates out of AWM’s other offices in New York and
Texas. For further information about AFO, please refer to AFO’s brochure available on the SEC’s
website at www.adviserinfo@sec.gov.
Discretionary Services
AWM provides personalized discretionary portfolio and wealth management services generally to
high-net-worth individuals, charitable organizations, corporations, and other business entities
(“Clients”). AWM tailors its advisory services based on the needs of its clients by consulting with
each Client to identify goals, risk tolerances, tax considerations, personal and family concerns, etc.
From this review, the Company recommends an investment allocation and weighting to AWM’s
investment strategies. AWM generally acts as a “manager of managers”, allocating to asset managers
with specific investment expertise to an asset class or marketplace to which AWM wishes to achieve
Client exposure. The Company also manages individual securities as well. Under certain circumstances
and as agreed upon by AWM in writing, Clients may impose restrictions on investing in specific
managers, securities or types of securities. The firm does not sponsor or participate in wrap fee
programs.
Philanthropy Services
AWM provides limited philanthropy consulting services at no additional fee as part of the overall
management relationship upon request. These philanthropy consulting services include, upon client
request and pursuant to the client’s agreement, advice related to the creation of corporate social
responsibility plans (CSR), conducting organizational assessments, strategic planning, financial
restructuring, management and board development, prospect research and evaluation, proposal
drafting, due diligence, and funder communications.
Relationship with AIA
As of December 31, 2025, AIA managed $5,996,612,974 of client assets on a discretionary basis, and
$1,275,803,575 of client assets on a non-discretionary basis. AWM has a relationship with AIA
wherein AIA creates and maintains the model portfolios and pooled investment vehicles (see Fund of
Funds below) utilized by AWM in allocating the majority of Client assets. AWM may make
investments in securities not included in the AIA model portfolios for tax or other Client specific
considerations. AWM may also utilize AIA for certain additional advisory services as detailed below
under “Selected AIA Services”. AWM Clients’ primary contact will be with AWM personnel. AWM
does not compensate AIA for its services; however, AIA receives an economic benefit through its
ownership in AWM. All services described below are expected to be delivered by AWM.
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Relationship with AFO
As of December 31, 2025, AFO had no assets under management. AFO offers a variety of advisory
services, which include financial planning, consulting, and investment management services. AWM
will trade regulatory assets for AFO clients.
Model Allocations
The risk profiles and investing guidelines for AWM Clients generally fall into the following
categories:
Fixed Income- Invests primarily in fixed income and cash reserves.
Ultra Conservative Balanced- Invests primarily in equity and fixed income instruments and
cash reserves. Equity instrument positions generally between 10-30% of the portfolio.
Conservative Balanced- Invests primarily in equity and fixed income instruments and cash
reserves. Equity instrument positions generally between 30-50% of the portfolio.
Balanced- Invests primarily in equity and fixed income instruments and cash reserves.
Equity instrument positions generally between 50-70% of the portfolio.
Aggressive Balanced- Invests primarily in equity and fixed income instruments and cash
reserves. Equity instrument positions generally between 65-85% of the portfolio.
Equity- Invests primarily in equity and alternative instruments.
Additionally, AWM utilizes alternative investment vehicles (“Alternatives”) as part of the above asset
mix. Alternatives include but are not limited to hedge funds, private equity, and venture capital
vehicles, including the investment vehicles sponsored by AIA (individually a “Fund” and collectively
the “Funds”). Investments in these vehicles are subject to Client qualification, and to the execution
and acceptance of offering memorandums and other documentation provided by the offeror.
Selected AIA services
AWM utilizes certain services offered by AIA in addition to the Model Allocations discussed above.
These services are available to AWM Clients, but some or all of these services may not be used.
Portfolio Structure Analysis: Studies to determine the percentage policy allocation and the
minimum and maximum ranges to sub-asset categories such as style, size, active, passive,
quality, maturity, and market allocations are conducted.
Investment Manager Research and Selection: Proprietary manager research is conducted
on public and private category managers, funds and private placements are evaluated to
determine success factors and suitability for Clients. This manager research is used to
conduct manager searches and selection for Clients.
Manager Fiduciary Oversight: AIA monitors investment managers for changes in
organization, ownership, personnel, investment philosophy, investment process, historical
performance, and policies and procedures on behalf of our Clients. Return information
supplied by the Client or third-party data vendor is analyzed and interpreted.
Performance Measurement and Evaluation: With return information supplied by the
Client or third-party data vendor, AIA performs performance measurement services and
provides appropriate reporting to Clients. As part of this service, AIA routinely monitors
and evaluates the performance of the Client's money managers and the overall portfolio.
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Assets Under Management
As of December 31, 2025, AWM managed $2,727,688,772 of client assets on a discretionary basis,
and $82,729,323 on a non-discretionary basis as of that same date.
ITEM 5 – FEES AND COMPENSATION
AWM charges an asset-based fee. Fees are charged on a tiered basis and generally range from .50%
to 1%. We generally accept clients with a minimum account size of $5 million, which would generally create a
minimum fee of $50,000. In certain circumstances fees and minimums may be negotiated. Negotiated fees
may be higher or lower than those stated above. Generally, fees are payable on a quarterly basis in
advance, based upon fair market appraisals of the Client's investments, as of the beginning of the
quarter. Clients will receive a quarterly statement from AWM and also typically receive a
statement from their custodian on a monthly basis, but no less than quarterly. See Item 12 for a more
complete discussion of the custodian/broker relationship. A Client’s custodian account will be
automatically debited on a quarterly basis in accordance with the fee calculations described above
unless other arrangements are made. The specific manner in which fees are calculated by AWM and paid
by Client will be established in a client’s written Investment Advisory Agreement (the “Advisory
Agreement”). AWM urges you to review the fee calculation prepared by AWM and compare it to the
fee schedule in your Advisory Agreement; your custodian will not review this calculation.
Our advisory agreement can be terminated by AWM with 30 days’ written notice, and the client may
terminate the advisory agreement at any time. Upon termination of an advisory agreement, any prepaid,
unearned fees will be refunded at quarter end, and any earned, unpaid fees will be due and payable.
Clients incur fees in addition to those charged by AWM (“Other Fees”). AWM purchases certain
NASDAQ securities for Clients where AWM does not have direct access to market makers. As a
result, such orders are placed with other financial institutions thus causing a Client to pay an agency
commission. This cost may be in addition to the mark-up or mark-down assessed by the market maker.
AWM’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and
expenses, which may be incurred by the Client. Clients may incur certain charges imposed by
custodians, brokers and other third parties such as fees charged by other managers, fees related to
private fund investments (as set forth in relevant private fund offering documents), custodial fees,
deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and
other fees and taxes on brokerage accounts and securities transactions. Money market funds, mutual
funds, and exchange-traded funds also charge internal management fees, which are disclosed in a
fund’s prospectus.
If a Client later terminates AWM’s services but wishes to remain in or is prohibited from withdrawing
from one of the Funds, the Client will become subject to such Fund’s fee schedule detailed in the
allocation agreement immediately upon termination of AWM’s Advisory Agreement and may result
in increased fees paid by the Client. A Client investing in a Fund will also indirectly incur fund expenses
(e.g., administrative fee, legal, audit, etc.) that they would otherwise not incur if that Client invested
directly with the Sub-Funds.
Clients of AWM invested in certain AIA Funds will pay a performance-based fee on assets invested
in the fund. These assets are excluded from AWM’s management fee. AWM will share in the
performance fee charged by AIA for these funds. Please see Item 6 titled Performance-Based Fees
and Side-By-Side Management for further information on performance-based fees.
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All fees paid to AWM for investment advisory services, both through managed accounts and the
Funds, are in addition to the fees and expenses charged by the mutual funds, ETF’s, commingled
funds, hedge funds, unaffiliated investment advisers providing sub-advisory services, separately
managed accounts, custodians, brokers, and Sub-Funds of the Funds. When recommending mutual
funds, AWM will typically use no-load, or load-waived funds. Fees and expenses are described in the
offering documents of each respective investment and will generally include a management fee,
administrative, legal, audit, travel, research, and other expenses. Fees for sub- advisory services are
disclosed in the relevant sub-advisory agreement and/or sub-advisory ADV provided to the client.
Commingled funds, separately managed accounts and Sub-Funds of the Funds could also charge a
performance-based fee. Custodian fees will vary by vendor, as will the related brokerage fees.
Please see the item 12 titled Brokerage Practices for further information on brokerage fees.
A Client could invest in certain of the above-mentioned products without the services of AWM. In the
event a client did not utilize the services of AWM, the client would not receive the services provided
by AWM which are designed, among other things, to assist the client in determining which investment
is most appropriate to each client's financial condition and objectives. Accordingly, the client should
understand the total fees paid to AWM and the underlying managers and evaluate the advisory service
being provided.
ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE
MANAGEMENT
AWM’s affiliate AIA charges performance-based fees on certain private funds for which AIA serves
as the investment manager and/or controls the private fund’s general partner or managing member.
Because the general partner for the AIA Funds is entitled to the carried interest with respect to profitable
investments, the investment manager has an incentive to make riskier or more speculative investments
in order to generate greater profits than they would if they were receiving only asset-based
compensation. This risk is magnified given the Fund’s carried interest terms since each investment is
tracked separately without losses from other investments offsetting gains from profitable ones. In
addition, tax considerations relevant to the carried interest may influence the Fund’s holding period
with respect to an investment.
In addition, AWM is an entity that is majority-owned by the AIA, the investment manager, and
focuses on high-net worth individuals. AWM participates in a portion of the carried interest that is
attributable to AWM’s clients that invest in the Fund and thus is subject to incentives to encourage
its clients to invest in the Fund. In addition to the foregoing, individual wealth advisers of AWM
will receive a portion of the carried interest that is calculated based on how well the investments in
the Funds perform. This creates a conflict of interest as the wealth advisers have an incentive to
recommend that their clients’ assets are invested in the Fund. Nevertheless, AWM as a firm, as well
as each individual wealth adviser, are required to only recommend that a client invest its assets
in the Fund when AWM and the individual wealth adviser believe the investment is in the client’s
best interest.
ITEM 7 – TYPES OF CLIENTS
AWM generally provides discretionary portfolio management services to high-net-worth individuals,
charitable organizations, and corporations.
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We generally accept clients with a minimum account size of $5 million, which would generally
create a minimum fee of $50,000; however, fees and minimums may be negotiated. Assets of
family members are generally aggregated for the purpose of meeting asset minimums.
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES, &
RISK OF LOSS
Methods of Analysis and Sources of Information
When selecting or monitoring investments without the services provided by AIA, AWM gathers
information on investments from various sources including, but not limited to, research materials
prepared by others, corporate rating services, annual reports, prospectuses, company press releases,
and various online and software solutions. Information is analyzed based on fundamental, technical
or cyclical criteria and periodic evaluations are made regarding what AWM believes will be the most
efficient and effective strategy to accomplish a particular Client’s goal. AWM will generally follow a
strategic allocation but may employ an occasional, tactical short-term buy or sell trade.
When utilizing the investment services of AIA, certain of its methods of analysis and sources of
information that apply to Clients of AWM are as follows:
Methods of Analysis and Sources of Information
AIA conducts proprietary fund/manager research to evaluate and find suitable investment
management organizations to recommend to Clients, to manage Client assets on a
discretionary basis, or to include as a Sub-Fund in the Funds. As part of its proprietary
fund/manager research, AIA utilizes databases, industry contacts, and other industry
resources to find individual firms and their products available in the marketplace. AIA
then conducts independent research by communicating in person or via conference call
with the investment firm's management and portfolio managers, evaluating their
investment ability and monitoring these firms over time. Investing in securities involves
risk of loss, including the loss of principal, which Clients should be prepared to bear.
Types of Investments, Generally
AIA utilizes no-load mutual funds, load-waived mutual funds, separately managed
accounts, ETFs, government securities, exchange-listed closed-end funds, limited
partnerships, offshore corporations, and/or private placements, including hedge funds.
Additionally, frequent trading of securities can affect investment performance,
particularly through increased brokerage, transaction costs, and taxes. There are
additional risks associated with private placements, and those risks are discussed below.
Many AIA clients elect to limit their exposure to private placements to less than 30% of
their overall portfolio. These securities can carry greater risk than an exchange-traded
security for a number of reasons. Private placements are less liquid than exchange-traded
securities, with withdrawals generally prohibited. Investment Managers can also invest in
a wider range of securities, including synthetic positions known as derivatives. They can
also employ margin to increase leverage, which in turn increases the risk of loss. AIA
clients investing in these private securities will receive an offering memorandum that
details the full range of risks present. Clients will be asked to sign a separate application
to invest in these securities and attest to their having read and understood the offering
memorandum. The Funds are examples of private placements. The Sub-Funds AIA selects
employ a wide range of investment strategies including, but not limited to, investing in
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bank debt, convertible arbitrage, capital structure arbitrage, high yield debt, structured
credit, merger arbitrage, special situations, distressed debt, and global long/short equity,
co-investments. The expected volatility of these sectors ranges from low to very high. The
Sub-Funds may also utilize short-selling and leverage as discussed above. Clients
investing in the Funds will be asked to sign a separate application and attest to their having
read and understood the offering memorandum. The Funds’ offering memorandums are
available upon request to accredited investors and/or qualified purchasers.
For tax-paying Clients of AWM, some of the above strategies are short-term in nature and may result
in the recognition of short-term capital gains or losses. Additionally, certain tax-exempt Clients in
certain private investments may be subject to Unrelated Business Taxable Income.
Private Fund Investments
AWM utilizes certain Funds managed by AIA to fill the Alternatives portion of a Client’s portfolio
when AWM deems such investment to be appropriate for the client.
AIA acts as the investment adviser to the Funds. The Funds rely on the exclusion to the
definition of “Investment Company” provided by Section 3(c)(1) and/or Section 3(c)(7) of
the Investment Company Act of 1940. The Funds are managed in reliance on the
Commodity Futures Trading Commission Regulation 4.7(b), which requires that investors
be limited to “qualified eligible persons” (including non-US persons).
While AIA has complete discretion and authority to manage and direct the investment
capital for the Funds, it generally does not invest the Funds’ capital directly. Instead, AIA
identifies third-party managers (“Investment Managers”) whose investment strategies and
styles are suited to the investment objective, policies, and restrictions of the Funds. AIA
then allocates the majority of the capital of the Funds to the investment discretion of one
or more Investment Managers and/or invests the Funds’ capital in selected investment
funds advised by the Investment Managers (Sub-Funds). This structure is commonly
referred to as a Fund of Funds. AIA will occasionally buy bonds or ETFs in the Funds to
obtain market exposure not otherwise covered by the Investment Managers. AIA will
(where applicable) manage the domestic and offshore versions of the Funds identically,
but there will be allocation differences due to the size and timing of the investments.
Risk of Loss
These methods, strategies, and investments described above involve risk of loss to the Clients, which
could be substantial. Investing in securities involves risk of loss that Clients should be prepared to
bear.
The Company’s principal strategies are subject to several risks, any of which could cause an investor to
lose money. The principal risks of investing are as follows:
Equity Market Risk is the risk stock prices overall will decline. Stock markets tend to move
in cycles, with periods of rising prices and periods of falling prices. When the stock market
is subject to significant volatility, the risks associated with investing generally increase.
Foreign Securities and Emerging Markets Risk is the risk associated with investments in
foreign countries and emerging markets. The following factors make foreign securities
more volatile: political, economic, and social instability; foreign securities may be less
liquid, brokerage commissions and other fees may be higher for foreign securities, and
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foreign companies are generally subject to different disclosure and reporting standards as
U.S. companies.
Currency Risk is the risk that the value of foreign securities are generally affected by
changes in currency exchange rates. Additionally, positions may be held in foreign
currencies, which are affected by changes in exchange rates to the investor’s home
currency.
Interest Rate Risk is the chance that the value of debt securities overall will decline
because of rising interest rates.
Income Risk is the chance that income will decline because of falling interest rates.
Credit Risk is the chance that a debt issuer will fail to pay interest and principal on time,
or that negative perceptions of the issuer’s ability to make such payments will cause the
price of that debt to decline.
Counterparty Risk is the risk that the other party to an agreement will default.
Derivatives Risk is the risk that the greater complexity involved with the use of derivatives
has the potential to expose the Client to greater risks and result in poorer overall
performance.
Short Sale Risk is the risk that a Client will incur a theoretically unlimited loss if the price
of a security sold short increases between the time of the short sale and the time the
account replaces the borrowed security.
Smaller and Mid-Sized Companies Risk is the risk that the securities of such issuers may
be comparatively more volatile in price than those of companies with larger
capitalizations, and in certain cases lack the depth of management, diversity in products,
and established markets for their products and/or services often associated with
investments in larger issuers.
Cybersecurity risk is the risk that AWM and the companies in which it recommends
investment are subject to certain operational and information security risks, including
those resulting from cyber-attacks.
Natural & Unavoidable Events: Global markets are interconnected, and events like natural
disasters, war, terrorism, civil disorder, public health crises such as a pandemic have led
and may, in the future, lead to short-term market volatility and potentially have an adverse
long- term and wide-spread effects on world economies and markets. Clients may have
exposure to countries and markets impacted by such events, which could result in material
losses.
Manager risk: AWM and certain private funds in which AWM invests client assets have
key personnel. The loss of such key personnel creates a key person risk for the underlying
investments.
Valuation Risk: Private fund investments, in many cases, will be difficult to value due to
various factors, including the absence of readily ascertainable market values and limited
sources of useful valuation information. In the case of many of the Fund’s investments, it
is unlikely that readily available price quotations will exist. Angeles will generally
account for its illiquid investments as if they were liquid and include their “fair value” in
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calculating the value of the Fund (subject to any terms set forth in the relevant Fund
documents). Valuations may be affected by changes in accounting standards, policies, and
practices, and there is no guarantee that the value determined will be realized by Angeles
on the eventual disposition of the investment or that would, in fact, be realized upon
immediate disposition of the investment.
ITEM 9 – DISCIPLINARY INFORMATION
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of them or the integrity of their
management. AWM has no disciplinary history to report for the firm, its owners, or its employees.
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND
AFFILIATIONS
AWM has arrangements with other unaffiliated investment advisers to provide sub-advisory services
for its clients. Clients acknowledge AWM’s discretion to appoint a sub-adviser and that the
compensation owed to the sub-adviser is in addition to the advisory fee paid to AWM.
Michael Rosen, a Managing Member of AIA, is the sole owner and employee of MarketForce, LLC, a
separate investment adviser with the appropriate state regulatory authority. Mr. Rosen works full time
at AIA and generally manages MarketForce before and after normal business hours. Mr. Rosen
receives management fees earned by MarketForce. MarketForce provides investment advisory
services to individuals, primarily friends and family of Mr. Rosen. Mr. Rosen recommends friends,
family, and other prospects that fail to meet the account profile of AWM, become investment advisory
Clients of MarketForce. You may view the MarketForce ADV at the SEC’s website:
https://adviserinfo.sec.gov/ The CRD number is 111233.
MarketForce Clients, including Michael Rosen, may trade in some of the same securities as AWM
Clients and may receive pricing and execution on those trades that are better or worse than the pricing
and execution AWM Clients will receive. In addition, there is a potential conflict in that Mr. Rosen
might refer Clients to MarketForce instead of AWM because of the higher fees available.
This potential conflict is mitigated in a number of ways. First, AWM Clients are anticipated to be
large, high net worth individuals with a minimum account size of $5 million, whereas MarketForce
Clients generally have a smaller average account size.
MarketForce does not have the infrastructure to successfully attract or retain a sophisticated high net
worth client base. Mr. Rosen does not represent MarketForce at all publicly, nor does he generate any
marketing material for this firm. Business is entirely generated by referrals. AIA will periodically
review certain disclosures from Mr. Rosen regarding MarketForce trading and clients added/lost to
determine overlap and will resolve any questions directly with Mr. Rosen. Finally, AIA requires
disclosure from Mr. Rosen regarding MarketForce trade practices and clients added/lost and will
resolve any questions directly with Mr. Rosen.
AWM is also affiliated with AIA, as more fully explained in Item 4 above.
Angeles Private Investment Company, LLC (“APIC”), is a relying adviser of AIA that is principally
owned by AIA and located in the Santa Monica, California office with AIA and AWM. APIC was
formed in 2023. APIC’s offering is limited to serving as an investment adviser to private funds and/or
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fund-of-funds. As of this filing, APIC does not manage any assets or advise any clients. AIA and
APIC operate out of the same office and will utilize some of the same employees. APIC has its own
Chief Executive Officer, who is also an employee of AIA. A conflict exists since AIA and APIC share
some of the same employees, thereby creating a conflict of allocation of time between the two entities
for these shared employees. This risk is mitigated by AIA and APIC monitoring the business needs
of each entity and adding resources and/or staff as necessary.
As set forth in Item 4 above, AWM is also affiliated with AFO. AFO utilizes some of the same
employees as AWM, including Ed Lowndes, who serves as the Chief Compliance Officer of both
AWM and AFO. A conflict exists since AWM and AFO utilize some of the same employees and
AFO utilizes the back-office support of AWM, including AWM handling the trading and reporting
for AFO; thereby creating a conflict of allocation of time and resources between the two entities. This
conflict is mitigated by taking measures to ensure that the trading is fair for both firms, that one firm
is not being favored over another, and monitoring the business needs of each entity, including adding
resources and/or staff as necessary.
AWM has entered into an agreement to serve as a Trust Representative Office of National Advisors
Holdings, Inc., the sole shareholder of National Advisors Trust Company, a federally chartered trust
company that provides trust administration services. As part of the agreement, AWM pays a
membership fee to National Advisors Holdings for National Advisors Trust Company to provide trust
administration services to AWM clients. AWM does not have custody over assets under this
arrangement. This creates a potential conflict as AWM may be inclined to recommend National
Advisors Trust Company over another trust administrator. This potential conflict of interest is
mitigated because AWM does not receive compensation for these referrals.
ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN
CLIENT TRANSACTIONS AND PERSONAL TRADING
AWM has adopted a Code of Ethics (“Code”) that describes the standards of business conduct that it
requires of employees and accounts owned predominantly by persons associated with AWM, and
establishes procedures intended to prevent AWM, and its personnel and certain of their relatives, from
inappropriately benefiting from AWM’s relationships with its Clients.
The Code provides that (i) AWM’s Clients’ interests come before AWM’s or employees’ interests;
(ii) AWM must disclose to Clients all material facts about conflicts of which it is aware between
AWM’s and its employees’ interests on the one hand and Clients’ interests on the other;
(iii) employees must operate on AWM’s and their own behalf consistently with AWM’s disclosures to
and arrangements with Clients regarding conflicts and its efforts to manage the impacts of those
conflicts; (iv) AWM and its employees must not take inappropriate advantage of AWM’s Clients or
their positions of trust with or responsibility to Clients; and (v) AWM and its employees must comply
with all applicable securities laws.
In order to avoid potential conflicts of interest that could be created by personal trading among AWM
access persons, each access person must provide quarterly reports of their personal transactions within
30 days of the end of each calendar quarter, which may consist of monthly brokerage statements for
all accounts in which they have a beneficial interest, to the Chief Compliance Officer (“CCO”).
Alternately, each access person may direct their brokers to send copies of all brokerage confirmations
relating to all personal securities transactions in which they have a beneficial ownership interest. Each
access person must also submit to AWM's CCO statements of their personal holdings in reportable
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securities as well as information about any brokerage accounts in which securities may be held within
10 days after becoming subject to the Code of Ethics and on an annual basis thereafter.
The Code may prohibit employees from trading in any securities held by Client accounts without first
obtaining pre-approval as further described below and requires employees to report personal securities
holdings quarterly. In addition, AWM monitors all employees’ securities transactions: employees
must arrange for duplicate copies of their brokerage statements and trade confirmations to be sent to
the Chief Compliance Officer.
The Code includes procedures for and restrictions on employee trading intended to prevent employees
from benefiting from, or appearing to benefit from, any price movement that may be caused by Client
transactions or AWM’s recommendations regarding securities. These procedures may include
requirements that employees make a written request for and receive pre- clearance from AWM’s Chief
Compliance Officer (or designee) before they buy or sell any security managed on a discretionary
basis by AWM (other than certain government securities, shares of mutual funds, and certain other
types of securities that AWM does not believe create a potential for conflicts of interest). Pre-cleared
transactions must be completed within a specified time frame.
The Code also contains restrictions and procedures to prevent inappropriate trading while AWM or
an affiliate possesses material nonpublic information.
Neither AWM nor any of its employees buy for AWM or AWM’s related persons securities from
advisory clients, or sell securities owned by AWM or AWM’s related persons to advisory clients.
AWM and its related persons buy or sell securities for themselves that it also recommends to advisory
clients and recommends the purchase or sale of securities to advisory clients for which it has a material
financial interest. This presents a conflict of interest in that it creates an incentive to cause a Client
to act in a manner that benefits AWM and its related persons. The Code mitigates this conflict of
interest by providing that AWM and its employees owe a fiduciary duty to AWM’s clients to conduct
their affairs, including their personal securities transactions, in such a manner as to avoid (i) serving
their own personal interests ahead of clients, (ii) taking inappropriate advantage of their position with
the firm and (iii) any actual or potential conflicts of interest or any abuse of their position of trust and
responsibility.
On occasion, employees of AWM may buy or sell securities or other instruments for their own
accounts that AWM has recommended to Clients and may engage in transactions for their own
accounts in a manner that is inconsistent with AWM's recommendations to a Client. Personal
securities transactions by employees may raise potential conflicts of interest when such persons trade
in a security that is owned by, or considered for purchase or sale for, a Client. AWM has adopted
policies and procedures designed to detect and prevent such conflicts of interest and when they do
arise, to ensure that it effects transactions for Clients in a manner that is consistent with its fiduciary
duty to its Clients and in accordance with applicable law. To this end, for recommended securities
priced throughout a given day, AWM has implemented a pre-clearing system whereby employees
must obtain permission to trade. In this way, AWM can control the potential conflict of interest that
would exist if an employee received a better price in a security traded on the same day as a client.
Employees are required to report personal securities transactions to AWM's Chief Compliance Officer
on no less than a quarterly basis.
A copy of AWM’s Code is available upon request. Such a request may be sent to the address on the
cover page of this brochure.
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ITEM 12 – BROKERAGE PRACTICES
AWM recommends one or several FINRA-registered SIPC-member broker-dealers, commercial
banks or trust companies ("BD" or “BDs”) to Clients to act as custodian. AWM intends to participate
in the institutional services programs offered to independent investment advisers by these BD’s. As
part of these BD programs, AWM receives benefits that it would not receive if it did not offer
investment advice. These benefits are more fully described below under “Other Benefits”.
Not all advisers require their clients to use a certain BD. AWM may recommend Charles Schwab &
Company, Inc. a FINRA-registered broker-dealer, member SIPC, ("Schwab" or “Recommended BD”)
to Clients for custody and brokerage services. Clients may direct AWM to use their approved broker-
dealer. In doing so, Client transaction costs may be more or less than would have been obtained
through the Recommended BD’s. In addition, Client orders that are not placed through the
Recommended BD will generally be placed after the rest of AWM Client’s and as a result, may obtain
less favorable price execution. AWM participates in the Schwab Advisor Services program (“Schwab
Services”) offered to independent investment advisers. As part of the Programs, AWM receives
benefits that it would not receive if it did not offer investment advice. These benefits are more fully
described below under “Other Benefits”. AWM may have an incentive to select or recommend a
broker-dealer based on your interest in receiving the research or other products or services, rather than
on your clients’ interest in receiving most favorable execution.
In evaluating whether to recommend that Clients custody their assets at the Recommended BD, AWM
may take into account the availability of some of those other benefits as part of the total mix of factors
it considers and not solely the nature, cost or quality of custody and brokerage services provided
by the Recommended BD, which can create a conflict of interest. However, AWM believes this
conflict is mitigated by the following facts. The Client must decide to use the Recommended BD and
sign a separate account opening document with full disclosure of fees and expenses. In recommending
the Recommended BDs, AWM considers the following factors: the products offered, the level of
service, commission rates, and the ability to meet Client needs. In assessing the reasonableness of
their commissions, AWM compares various brokerage firm rates and will advise Clients if AWM
believes the Recommended BD are no longer a reasonable choice.
Finally, AWM remains flexible in the use of other brokerage firms upon Client request or where
otherwise appropriate.
In assessing the reasonableness of their commissions, AWM compares various brokerage firm rates
and will advise Clients if AWM believes the Recommended BD are no longer a reasonable choice.
Finally, AWM remains flexible in the use of other brokerage firms upon Client request or where
otherwise appropriate.
AWM urges you to compare the balances reported by the third-party custodians to those reported by
AWM.
Other Benefits
As discussed above, AWM may recommend that Clients establish brokerage accounts with the
Recommended BD to maintain custody of Clients' assets and to effect trades for their accounts.
Although AWM may recommend that Clients establish accounts at the Recommended BD, it is the
Client's decision to custody assets with Schwab. AWM is independently-owned and operated and not
affiliated with the Recommended BDs.
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For Clients’ accounts it maintains, the Recommended BD generally does not charge separately for
custody services but is compensated by charging commissions or other fees on trades that they execute
or that settle into a Client’s Recommended BD account. Schwab’s commission rates applicable to
AWM Client accounts were negotiated based on AWM’s parent company, AIA’s relationship with
the Recommended BD.
Products and Services Available to Us from Schwab
Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business unit serving
independent investment advisory firms like AWM. They provide AWM and our Clients with access
to their institutional brokerage – trading, custody, reporting and related services – many of which are
not typically available to Schwab retail customers. Schwab also makes available various support
services. Some of those services help AWM manage or administer our Clients’ accounts while others
help AWM manage and grow our business. Schwab’s support services are generally available on an
unsolicited basis (we don’t have to request them) and at no charge to AWM.
Here is a more detailed description of Schwab’s support services:
Services that Benefit You. Schwab’s institutional brokerage services include access to a broad range
of investment products, execution of securities transactions, and custody of Client assets. The
investment products available through Schwab include some to which we might not otherwise have
access or that would require a significantly higher minimum initial investment by our Clients.
Schwab’s services described in this paragraph generally benefit you and your account.
Services that May Not Directly Benefit You. Schwab also makes available to AWM other products and
services that benefit AWM but may not directly benefit you or your account. These products and
services assist AWM in managing and administering our Clients’ accounts. They include investment
research, both Schwab’s own and that of third parties. We may use this research to service all or some
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:
o provide access to Client account data (such as duplicate trade confirmations and
o
account statements);
facilitate trade execution and allocate aggregated trade orders for multiple
Client accounts;
facilitate payment of our fees from our Clients’ accounts; and
assist with back-office functions, recordkeeping, and Client reporting.
o provide pricing and other market data;
o
o
Services that Generally Benefit Only AWM. Schwab also offers other services intended to help AWM
manage and further develop our business enterprise. These services include:
commission-free trading for employees
educational conferences and events
technology, compliance, legal, and business consulting;
o
o
o
o publications and conferences on practice management and business succession; and
access to employee benefits providers, human capital consultants, and insurance
o
providers.
Schwab may provide some of these services itself. In other cases, it will arrange for third-party
vendors to provide the services to AWM. Schwab may also provide AWM with other benefits such
as occasional business entertainment of our personnel.
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Our Interest in Schwab’s Services
The availability of these services from Schwab benefits AWM because we do not have to produce or
purchase them. We do not have to pay for Schwab’s services and these services are not contingent
upon AWM committing any specific amount of business to Schwab in trading commissions or assets
in custody.
Other Brokerage Practices
Clients may incur transaction costs in addition to any commission charges by the broker-dealer when
fixed income securities or securities traded over the counter are affected on their behalf through the
custodial broker-dealer on an agency basis.
AWM seeks to correct all trade errors directly through the Client’s custodian account where
applicable. If there is a loss, AWM will review the facts and circumstances surrounding the trade and,
based upon that review, will determine the source(s) of the error and the most appropriate resolution.
Conversely, if there is a gain due to a trade error, the custodian may net out any gain before losses are
calculated. Therefore, AWM may receive a benefit from this arrangement if AWM reimburses a
Client for a net loss incurred.
AWM considers rebalancing accounts when a defined portfolio varies by certain amounts from its
target weights. Rebalancing may not take place for all accounts at the same time based on tax
considerations, and it is possible that two Clients could buy or sell the same security during the same
rebalance and receive different prices for that security based on the timing of trades executed.
AWM’s policy is to aggregate all eligible Client accounts, if possible, when trading securities that may
have price movement throughout the day, such as ETFs, then allocate an average price to
those
Clients. In addition, when trading the same ETF or other exchange-traded security, AIA clients will
be included in block trades with AWM clients. In this way, no Client receives a price advantage at the
expense of another Client. Clients may have different commission schedules with their custodians, and
this schedule may not be impacted by AWM’s aggregation of trades.
Mutual funds have one price per trading day, so aggregation is not necessary when multiple Clients trade
the same mutual fund at the same time.
AWM may direct execution of agency transactions in over-the-counter debt securities to certain
market-makers. In these situations, the Client may pay an agency commission in addition to the mark-
up or mark-down assessed by the market maker. AWM aggregates or bunches Clients’ trade orders
from time to time and its method for allocating bunched trades and partially-filled bunched orders is
as follows: for trades which are fully executed, each Client receives the number of shares originally
intended for their account; for trades which are only partially executed, a random allocation sequence
is adopted by AWM. For aggregated orders that are executed in more than one transaction, a Client’s
portion of such order may be deemed to have been at the weighted average of the prices at which all
of such transactions were executed.
AWM does not typically “cross” fixed income securities between Client accounts; however, AWM
may utilize cross trades for fixed income securities when it specifically deems the practice to be
advantageous for each participant. These transactions are affected if AWM independently determines
that the cross transaction is in accordance with the investment objectives of all Clients involved.
Generally, due to lower transaction costs and a narrowing of the dealer spread, both the buyer and the
seller of the fixed income security involved in the cross transaction may receive a better execution.
By written notice, a Client may elect not to be involved in cross transactions.
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AWM acting as an advisor and fiduciary to both buyer and seller may affect cross trades only if it is
consistent with AWM’s policies and procedures. Pursuant to current regulations, ERISA accounts
will not be provided the opportunity to effect cross trades with any other AWM advisory Client.
ITEM 13 – REVIEW OF ACCOUNTS
Client accounts will be formally reviewed at least quarterly if the client schedules a meeting for that
quarter. If the client does not schedule a meeting, the review will happen as AWM deems necessary.
The review will provide a written report discussing general market conditions, performance, and any
other relevant Client-specific information. More frequent monitoring may be triggered by a material
change in variables such as the Client’s individual circumstances, or the market, political, or economic
environment.
Each AWM Client advisor is assigned specified Client accounts for which he/she has review
responsibility. AWM has the following general guidelines in connection with reviews: (i) provide
objective advice and avoid personal bias; (ii) when advising a Client, keep the Client’s objective
foremost in mind; and (iii) act as a fiduciary.
Private Fund Investment Review and Monitoring
AIA, the parent of AWM, monitors the performance of the Sub-Funds in which the Funds invest. AIA
periodically contacts the Investment Managers of the Sub-Funds regarding their performance and for
analysis of significant events as they relate to their investment strategies and influence their
investment decisions. AIA may also visit the offices of the Investment Managers to review their
activities, travel conditions permitting. If a Sub-Fund’s relative performance is poor or if significant
changes occur in an Investment Manager’s approach or investments, the capital allocation of a Fund
to such Sub-Fund may be reduced or withdrawn (if applicable).
In addition to the quarterly statements and confirmations of transactions that Clients receive from their
custodian, AIA (via AWM) will provide to AWM Clients invested in the Funds. AIA or its designated
agent will provide each investor in the Funds with periodic reports in accordance with the terms of the
Offering Memorandum. Such reports generally include a monthly or quarterly report summarizing
the Funds’ performance, a monthly or quarterly investor specific account statement, and the audited
financial statements sent to all investors in the Funds within 180 days of the fiscal year end for Funds
that are fund of funds and within 120 days of the fiscal year end for Funds that are private funds
promptly after completion of the audit.
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
Angeles Wealth Management (AWM) maintains an internal referral program under which certain
employees of the firm or an affiliated firm, and/or the affiliated firm itself, may receive compensation
for introducing prospective clients to the firm. The eligible referring party responsible for referring a
prospective client that subsequently enters into an advisory relationship with the firm may receive
compensation based on the referred client's advisory fees generated, for a period of time that is
determined by the referral program.
This arrangement presents a conflict of interest, as the referring party has a financial incentive to refer
prospective clients to the firm independent of whether the firm’s investment strategies and services are
well-suited to that client's objectives, mandate, or constraints. AWM mitigates this potential conflict
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through the following: (i) all internal referral compensation arrangements are subject to review and
approval by the CCO of AWM as well as the CCO of an affiliate, if applicable; (ii) employees
participating in the program remain subject to the respective firm's Code of Ethics and are prohibited
from making materially false or misleading representations; and (iii) fee sharing arrangements will be
disclosed to clients, and such clients will not pay higher fees regardless of whether AWM pays a referral
fee and/or provides certain ownership rights to a referring party; and (iv) internal referral compensation
arrangements will not change the terms of the investment management agreement other than the
inclusion of a disclosure referencing this referral program.
Prospective clients introduced through this program undergo the firm's standard onboarding and due
diligence process. The existence of a referral arrangement has no bearing on the investment advice,
portfolio management, or level of service provided to the client. Regardless of any referral arrangement,
AWM remains subject to its fiduciary duty to act in the best interest of each client.
ITEM 15 – CUSTODY
Pursuant to our Advisory Agreement with you, we may have the authority to debit fees directly from
your brokerage account. Account statements are produced and sent to you by the account custodian
on a monthly or quarterly basis. We urge you to carefully review and compare custodial account
statements with our quarterly performance reports. Each statement will include the amount we charged
and the amount deducted. Our statements may vary from the broker- dealer’s custodial statements
based on their accounting procedures, reporting dates, or valuation methodologies of certain
securities.
With respect to private fund investments, the Funds’ assets are held at qualified third-party
custodians. Independent third-party custodians or fund administrators send monthly or quarterly
capital statements to the Funds’ investors. AWM posts Fund investor account statements as well. In
addition, the assets of the Funds are audited, and the audited financial statements are sent to all
investors in the Funds as legally required.
AWM urges you to compare the balances reported by the third-party custodians or fund
administrators, both for the Funds and for individual investors, to those reported by AWM.
ITEM 16 – INVESTMENT DISCRETION
AWM receives discretionary authority unless otherwise stated in the client’s advisory agreement.
Discretionary authority is generally in the form of a limited power of attorney, from the Client at the
outset of an advisory relationship to select the identity and number of securities to be bought or sold.
In certain cases, clients place restrictions on certain assets, which AWM classifies as non- discretionary
assets for the client. In all cases, however, such discretion is to be exercised in a manner consistent
with the stated investment objectives for the Client account. AWM uses its best judgment, together
with any investment objectives, guidelines, policies and limitations as the Client may from time to time
furnish to AWM pursuant to Client’s Advisory Agreement.
ITEM 17 – VOTING CLIENT SECURITIES
As detailed in our standard Advisory Agreement, AWM does not vote proxies on behalf of Clients. The
clients will receive their proxies directly from their custodian or transfer agent and may contact AWM
with questions about a particular solicitation. Clients may request a copy of AWM’s Proxy Voting
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Policies and Procedures by contacting AWM at the phone number and/or email address listed on the
cover page.
ITEM 18 – FINANCIAL INFORMATION
AWM does not require or solicit Clients to prepay fees more than six months in advance. AWM has
no financial commitment that impairs its ability to meet contractual and fiduciary commitments to
Clients. In addition, Angeles does not require or solicit prepayment of more than $1,200 per client, six
months or more in advance. AWM has not been the subject of a bankruptcy petition.
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