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Part 2A of Form ADV: Firm Brochure
Item 1: Cover Page
April 2025
70 Center Street, 2nd Floor,
Portland, ME 04101
Firm Contact:
Jason Viola
Chief Compliance Officer
Firm Website Address:
www.arieswealthllc.com
This brochure provides information about the qualifications and business practices of Aries Wealth
Management, LLC. If you have any questions about the contents of this brochure, please contact us
by telephone at 207-536-0530 or email at jviola@arieswealthllc.com. The information in this
brochure has not been approved or verified by the United States Securities and Exchange
Commission or by any State Securities Authority.
Additional information about Aries Wealth Management, LLC also is available on the SEC’s website
at www.adviserinfo.sec.gov. Please note that the use of the term “registered investment adviser” and
description of Aries Wealth Management, LLC and/or our associates as “registered” does not imply a
certain level of skill or training. You are encouraged to review this Brochure and Brochure
Supplements for our firm’s associates who advise you for more information on the qualifications of
our firm and our employees.
Item 2: Material Changes to Our Part 2A of Form ADV: Firm Brochure
Aries Wealth Management, LLC is required to advise you of any material changes to the Firm
Brochure (“Brochure”) from our last annual update. Since our last annual amendment filed on
03/06/2024, we do not have any material changes to disclose.
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Item 3: Table of Contents
Item 1: Cover Page .................................................................................................................................................................. 1
Item 2: Material Changes to Our Part 2A of Form ADV: Firm Brochure ........................................................... 2
Item 3: Table of Contents ..................................................................................................................................................... 3
Item 4: Advisory Business.................................................................................................................................................... 4
Item 5: Fees & Compensation ............................................................................................................................................. 6
Item 6: Performance-Based Fees & Side-By-Side Management ........................................................................... 8
Item 7: Types of Clients & Account Requirements .................................................................................................... 8
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ................................................................... 8
Item 9: Disciplinary Information..................................................................................................................................... 10
Item 10: Other Financial Industry Activities & Affiliations .................................................................................. 10
Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ............. 11
Item 12: Brokerage Practices ........................................................................................................................................... 11
Item 13: Review of Accounts or Financial Plans ....................................................................................................... 14
Item 14: Client Referrals & Other Compensation ..................................................................................................... 14
Item 15: Custody .................................................................................................................................................................... 15
Item 16: Investment Discretion ....................................................................................................................................... 16
Item 17: Voting Client Securities ..................................................................................................................................... 16
Item 18: Financial Information ........................................................................................................................................ 16
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Item 4: Advisory Business
We are dedicated to providing individuals and other types of clients with a wide array of investment
advisory services. Our firm is a limited liability company formed in the State of Maine. Our firm has
been in business as an investment adviser since 2015 and is owned as follows:
•
Jason Viola – 100% Owner
Description of the Types of Advisory Services We Offer
Asset Management:
We emphasize continuous and regular account supervision. As part of our asset management service,
we generally create a portfolio, consisting of individual stocks or bonds, exchange traded funds (“ETFs”),
options, mutual funds and other public and private securities or investments. The client’s individual
investment strategy is tailored to their specific needs and may include some or all of the previously
mentioned securities. Each portfolio will be initially designed to meet a particular investment goal,
which we determine to be suitable to the client’s circumstances. Once the appropriate portfolio has been
determined, we review the portfolio at least quarterly and if necessary, rebalance the portfolio based
upon the client’s individual needs, stated goals and objectives. We also offer financial planning and
consulting on a case by case basis.
Comprehensive Portfolio Management:
As part of our Comprehensive Portfolio Management service, clients will be provided asset
management and financial planning or consulting services. This service is designed to assist clients
in meeting their financial goals through the use of a financial plan or consultation. Our firm conducts
client meetings to understand their current financial situation, existing resources, financial goals, and
tolerance for risk. Based on what is learned, an investment approach is presented to the client,
consisting of individual stocks, bonds, ETFs, options, mutual funds and other public and private
securities or investments. Once the appropriate portfolio has been determined, portfolios are
continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual
needs, stated goals and objectives. Upon client request, our firm provides a summary of observations
and recommendations for the planning or consulting aspects of this service.
Retirement Plan Consulting:
Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing
basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing,
monitoring and reviewing their company's participant-directed retirement plan. As the needs of the
plan sponsor dictate, areas of advising may include:
•
• Establishing an Investment Policy Statement – Our firm will assist in the development or
review of a statement that summarizes the investment goals and objectives along with the
broad strategies to be employed to meet the objectives.
Investment Options – Our firm will work with the Plan Sponsor to evaluate existing
investment options and make recommendations for appropriate changes.
• Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation
models to aid Participants in developing strategies to meet their investment objectives, time
horizon, financial situation and tolerance for risk.
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•
Investment Monitoring – Our firm will monitor the performance of the investments and
notify the client in the event of over/underperformance and in times of market volatility.
• Participant Education – Our firm will provide opportunities to educate plan participants
about their retirement plan offerings, different investment options, and general guidance on
allocation strategies.
In providing services for retirement plan consulting, our firm does not provide any advisory services
with respect to the following types of assets: employer securities, real estate (excluding real estate
funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other
illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement
plan consulting services shall be in compliance with the applicable state laws regulating retirement
consulting services. This applies to client accounts that are retirement or other employee benefit
plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide
services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section
3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to
the provision of services described therein.
Tailoring of Advisory Services
We offer individualized investment advice to clients utilizing our Asset Management and
Comprehensive Portfolio Management services. General investment advice will be offered to our
Retirement Plan Consulting clients.
Each 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. Restrictions would
be limited to our Asset Management and Comprehensive Portfolio Management services. We do not
manage assets through our other services.
Participation in Wrap Fee Programs
We do not offer wrap fee programs.
Regulatory Assets Under Management
As of December 31st, 2024, our firm managed $529,956,930 on a discretionary basis and $750,934
on a non-discretionary basis for a total of $530,707,864.
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Item 5: Fees & Compensation
How We Are Compensated for Our Advisory Services
Asset Management:
Assets Under Management
Up to $1,000,000
Over $1,000,000
Annual Percentage of Assets Charge
1.25%
0.75%
Our firm’s annualized fees are billed on a pro-rata basis quarterly in advance typically based on the
value of your account(s) on the last day of the previous quarter. Adjustments will be made for
deposits and withdrawals. Our firm bills on cash and cash equivalents unless indicated otherwise in
writing. For certain clients with margin accounts, the advisory fee calculation is based on the total
asset long value of the account as calculated by the custodian and reported in the custodial statement
rather than the total account value. Using the total asset long value instead of the total account value
results in a higher client account valuation because it does not net out margin loan balances. Clients
charged an advisory fee based on the total long value of their margin account pay a higher advisory
fee because the calculation is based on the greater client account valuation. Fees are negotiable and
will be deducted from your account(s). As part of this process, the client is made aware of the
following:
a) Your independent custodian sends statements at least quarterly to you showing the market
values for each security included in the assets and all disbursements in your account
including the amount of the advisory fees paid to us.
b) You provide authorization permitting us to be directly paid by these terms. We send our
invoice directly to the custodian.
c) It is the client’s responsibility to verify the calculation of advisory fees deducted from the
account.
d) If we send a copy of our invoice to you, it will include a disclosure urging you to compare
information provided in our statement with those from the qualified custodian.
Comprehensive Portfolio Management:
Assets Under Management
$250,000 to $1,000,000
Over $1,000,000
Annual Percentage of Assets Charge
1.35%
0.85%
Our firm’s annualized fees are billed on a pro-rata basis quarterly in advance typically based on the
value of your account(s) on the last day of the previous quarter. Adjustments will be made for
deposits and withdrawals. Our firm bills on cash and cash equivalents unless indicated otherwise in
writing. For certain clients with margin accounts, the advisory fee calculation is based on the total
asset long value of the account as calculated by the custodian and reported in the custodial statement
rather than the total account value. Using the total asset long value instead of the total account value
results in a higher client account valuation because it does not net out margin loan balances. Clients
charged an advisory fee based on the total long value of their margin account pay a higher advisory
fee because the calculation is based on the greater client account valuation. Fees are negotiable and
will be deducted from your account(s). As part of this process, the client is made aware of the
following:
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a) Your independent custodian sends statements at least quarterly to you showing the market
values for each security included in the assets and all disbursements in your account
including the amount of the advisory fees paid to us.
b) You provide authorization permitting us to be directly paid by these terms. We send our
invoice directly to the custodian.
c) It is the client’s responsibility to verify the calculation of advisory fees deducted from the
account.
d) If we send a copy of our invoice to you, it will include a disclosure urging you to compare
information provided in our statement with those from the qualified custodian.
Retirement Plan Consulting:
Our firm charges a fee based on percentage of plan assets for our Retirement Plan Consulting service.
The maximum fee will not exceed 1.00%. The fee-paying arrangements will be determined on a case-
by-case basis and will be detailed in the signed consulting agreement.
Other Types of Fees & Expenses
Clients will incur transaction charges for trades executed by their custodian via individual
transaction charges. These transaction fees are separate from our fees and will be disclosed by the
custodian. Charles Schwab & Co., Inc. (“Schwab”) does not charge transaction fees for U.S. listed
equities and exchange traded funds. Our firm recommends Pershing Advisor Solutions, LLC
(“Pershing”) as a custodian for client accounts. Other major custodians have recently eliminated
transaction fees for all ETFs and U.S. listed equities, so clients may pay more for investing in the same
securities at Pershing.
Clients may also pay holding charges imposed by the 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
We charge our advisory fees in advance. Either party to an Asset Management Agreement or
Comprehensive Portfolio Management Agreement may terminate the service at any time by
providing written notice to the other party. Upon notice of termination, we will proceed to close out
your account and process a pro-rata refund of any unearned advisory fees charged in advance.
Either party to a Retirement Plan Consulting Agreement may terminate the service at any time by
providing written notice to the other party. Full refunds will only be made in cases where cancellation
occurs within 5 business days of signing an agreement. After 5 business days from initial signing,
either party must provide the other party 30 days written notice to terminate billing. Billing will
terminate 30 days after receipt of termination notice. Clients will be charged on a pro-rata basis,
which takes into account work completed by our firm on behalf of the client. Clients will incur charges
for bona fide advisory services rendered up to the point of termination (determined as 30 days from
receipt of said written notice) and such fees will be due and payable.
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Commissionable Securities Sales
We do not sell securities for a commission in our advisory accounts.
Item 6: Performance-Based Fees & Side-By-Side Management
We do not accept performance-based fees.
Item 7: Types of Clients & Account Requirements
We have the following types of clients:
•
Individuals and High Net Worth Individuals;
• Trusts, Estates or Charitable Organizations;
• Corporations, Limited Liability Companies and/or Other Business Types.
Our firm does not impose requirements for opening and maintaining accounts or otherwise engaging
us.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
We use the following methods of analysis in formulating our investment advice and/or managing
client assets:
Charting: In this type of technical analysis, we review charts of market and security activity in an
attempt to identify when the market is moving up or down and to predict when how long the trend
may last and when that trend might reverse.
Cyclical Analysis: In this type of technical analysis, we measure the movements of a particular stock
against the overall market in an attempt to predict the price movement of the security.
Fundamental Analysis: We attempt to measure the intrinsic value of a security by looking at
economic and financial factors (including the overall economy, industry conditions, and the financial
condition and management of the company itself) to determine if the company is underpriced
(indicating it may be a good time to buy) or overpriced (indicating it may be time to sell).
Fundamental analysis does not attempt to anticipate market movements. This presents a potential
risk, as the price of a security can move up or down along with the overall market regardless of the
economic and financial factors considered in evaluating the stock.
Technical Analysis: We analyze past market movements and apply that analysis to the present in
an attempt to recognize recurring patterns of investor behavior and potentially predict future price
movement. Technical analysis does not consider the underlying financial condition of a company.
This presents a risk in that a poorly-managed or financially unsound company may underperform
regardless of market movement.
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Investment Strategies We Use
We use the following strategies in managing client accounts, provided that such strategies are
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizons, among other considerations:
Long-Term Purchases: When utilizing this strategy, we may purchase securities with the idea of
holding them for a relatively long time (typically held for at least a year). A risk in a long-term
purchase strategy is that by holding the security for this length of time, we may not take advantages
of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a
security may decline sharply in value before we make the decision to sell. Typically we employ this
sub-strategy when we believe the securities to be well valued; and/or we want exposure to a
particular asset class over time, regardless of the current projection for this class.
Short-Term Purchases: When utilizing this strategy, we may also purchase securities with the idea
of selling them within a relatively short time (typically a year or less). We do this in an attempt to
take advantage of conditions that we believe will soon result in a price swing in the securities we
purchase.
Trading: We purchase securities with the idea of selling them very quickly (typically within 30 days
or less). We do this in an attempt to take advantage of our predictions of brief price swings.
Margin Transactions: Our firm may purchase securities for a client’s portfolio with money
borrowed from their brokerage account. This allows the client to purchase more stock than they
would be able to with their available cash and allows us to purchase securities without selling other
holdings. Margin accounts and transactions are risky and not necessarily appropriate for every client.
Our firm charges advisory fees on securities purchased on margin, which creates a financial incentive
for us to utilize margin in client accounts. The potential risks associated with these transactions are
(1) the client can lose more funds than are deposited into the margin account; (2) the forced sale of
securities or other assets in the client’s account; (3) the sale of securities or other assets without
contacting the client; (4) the client may not be entitled to choose which securities or other assets in
their account(s) are liquidated or sold to meet a margin call; and (5) custodians charge interest on
margin balances which will reduce the client’s returns over time.
Option Writing: We may use options as an investment strategy. An option is a contract that gives
the buyer the right, but not the obligation, to buy or sell an asset (such as a share of stock) at a specific
price on or before a certain date. An option, just like a stock or bond, is a security. An option is also a
derivative, because it derives its value from an underlying asset. The two types of options are calls
and puts. A call gives us the right to buy an asset at a certain price within a specific period of time.
We will buy a call if we have determined that the stock will increase substantially before the option
expires. A put gives us the holder the right to sell an asset at a certain price within a specific period
of time. We will buy a put if we have determined that the price of the stock will fall before the option
expires.
We will use options to "hedge" a purchase of the underlying security; in other words, we will use an
option purchase to limit the potential upside and downside of a security we have purchased for your
portfolio.
We use "covered calls", in which we sell an option on security you own. In this strategy, you receive
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Aries Wealth Management, LLC
a fee for making the option available, and the person purchasing the option has the right to buy the
security from you at an agreed-upon price.
We use a "spreading strategy", in which we purchase two or more option contracts (for example, a
call option that you buy and a call option that you sell) for the same underlying security. This
effectively puts you on both sides of the market, but with the ability to vary price, time and other
factors.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. While the stock
market may increase and your account(s) could enjoy a gain, it is also possible that the stock market
may decrease and your account(s) could suffer a loss. It is important that you understand the risks
associated with investing in the stock market, are appropriately diversified in your investments, and
ask us any questions you may have.
Description of Material, Significant or Unusual Risks
We generally invest client’s cash balances in money market funds, FDIC Insured Certificates of
Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, we
try to achieve the highest return on our client’s cash balances through relatively low-risk
conservative investments. In most cases, at least a partial cash balance will be maintained in a money
market account so that our firm may debit advisory fees for our services related to Asset Management
and Comprehensive Portfolio Management services, as applicable.
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to the evaluation of our advisory business
or the integrity of our management.
Item 10: Other Financial Industry Activities & Affiliations
Representatives of our firm are Certified Public Accountants. Accounting services are not offered
through our firm. Should a client of our firm require accounting services, they will be referred to a
separate Certified Public Accountant. Our firm will not receive any additional compensation for these
referrals.
A representative of our firm is a licensed attorney. Legal services are not offered through our firm.
Should a client of our firm require legal services, they will be referred to a separate attorney. Our firm
will not receive any additional compensation for these referrals.
A representative of our firm is a licensed insurance agent. A conflict of interest exists because
commissionable securities sales create an incentive to recommend products based on the
compensation earned. To mitigate this potential conflict, our firm will act in the client’s best interest.
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Item 11: Code of Ethics, Participation or Interest in Client
Transactions & Personal Trading
An investment adviser is considered a fiduciary and our firm has a fiduciary duty to all clients. 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. Our fiduciary duty is
considered the core underlying principle for our Code of Ethics which also includes Insider Trading and
Personal Securities Transactions Policies and Procedures. If a client or a potential client wishes to review
our Code of Ethics in its entirety, a copy will be provided upon request.
We recognize that the personal investment transactions of members and employees of our firm demand
the application of a high Code of Ethics and require that all such transactions be carried out in a way that
does not endanger the interest of any client. At the same time, we believe that if investment goals are
similar for clients and for members and employees of our firm, it is logical and even desirable that there
be common ownership of some securities.
Therefore, in order to prevent conflicts of interest, we have in place a set of procedures (including a pre-
clearing procedure) with respect to transactions effected by our members, officers and employees for
their personal accounts1. In order to monitor compliance with our personal trading policy, we have a
quarterly securities transaction reporting system for all of our associates. Upon employment or
affiliation and at least annually thereafter, all supervised persons will sign an acknowledgement that
they have read, understand, and agree to comply with our Code of Ethics.
Neither our firm nor a related person recommends to clients, or buys or sells for client accounts,
securities in which our firm or a related person has a material financial interest. Related persons of
our firm 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 our firm’s Code of Ethics. 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 done
so after the client execution or concurrently as a part of a block trade. If related persons’ accounts are
included in a block trade, our related persons accounts will be traded in the same manner every time.
Our firm and supervised persons 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.
Item 12: Brokerage Practices
Selecting a Brokerage Firm
We seek to recommend a custodian/broker who will hold your assets and execute transactions on
terms that are overall most advantageous when compared to other available providers and their
services. We consider a wide range of factors, including, among others, these:
• Timeliness of execution
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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• 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, our firm has an arrangement with Pershing Advisor Solutions LLC, a Bank of
New York/Mellon Company (“Pershing”) and Charles Schwab & Co. Inc (“Schwab”) (hereinafter
collectively referred to as the “Custodians”). Our Custodians offer services to independent investment
advisers which include custody of securities, trade execution, clearance and settlement of
transactions.
Our Custodians may make certain research and brokerage services available at no additional cost to
our firm, all of which qualify for the safe harbor exemption defined in Section 28(e) of the Securities
Exchange Act of 1934. These services may be directly from independent research companies, as
selected by our firm (within specific parameters). Research products and services provided by our
Custodians 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 our Custodians to our firm in the
performance of our investment decision-making responsibilities.
We do not use client brokerage commissions to obtain research or other products or services. The
aforementioned research and brokerage services are used by our firm to manage accounts for which
we have investment discretion. Without this arrangement, our firm might be compelled to purchase
the same or similar services at our own expense.
As a result of receiving these services, we may have an incentive to continue to use or expand the use of
our Custodians’ services. Our firm examined this potential conflict of interest when we chose to enter
into the relationship with our Custodians, and we have determined that the relationship is in the best
interest of our firm’s clients and satisfies our fiduciary obligations, including our duty to seek best
execution.
Our Custodians charge brokerage commissions and transaction fees for effecting certain securities
transactions (i.e., transaction fees are charged for certain no-load mutual funds, commissions are
charged for debt securities transactions, commissions are charged for individual equities by
Pershing). Schwab does not charge transaction fees for U.S. listed equities and exchange traded funds.
Our Custodians enable us to obtain many no-load mutual funds without transaction charges and other
no-load funds at nominal transaction charges. Our Custodians’ commission rates are generally
discounted from customary retail commission rates. The commission and transaction fees charged
our Custodians may be higher or lower than those charged by other custodians and broker-dealers.
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Our clients may pay a commission to Pershing or Schwab that is higher than another qualified broker
dealer might charge to effect the same transaction where we determine in good faith that the
commission is reasonable in relation to the value of the brokerage and research services received. 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. Accordingly, although we will seek competitive rates, to the benefit of all
clients, we may not necessarily obtain the lowest possible commission rates for specific client
account transactions.
Soft Dollars
Although the investment research products and services that may be obtained by our firm will
generally be used to service all of our clients, a brokerage commission paid by a specific client may
be used to pay for research that is not used in managing that specific client’s account.
Our firm does not accept products or services that do not qualify for Safe Harbor outlined in Section
28(e) of the Securities Exchange Act of 1934, such as those services that do not aid in investment
decision-making or trade execution.
Client Brokerage Commissions
We do not use client brokerage commissions to obtain research or other products or services. The
aforementioned research and brokerage services are used by our firm to manage accounts for which
we have investment discretion. Without this arrangement, our firm might be compelled to purchase
the same or similar services at our own expense.
Procedures to Direct Client Transactions in Return for Soft Dollars
We do not direct client transactions to a particular broker-dealer in return for soft dollar benefits.
Brokerage for Client Referrals
Our firm does not receive brokerage for client referrals.
Directed Brokerage
Neither we nor any of our firm’s related persons have discretionary authority in making the
determination of the brokers with whom orders for the purchase or sale of securities are placed for
execution, and the commission rates at which such securities transactions are effected. We routinely
recommend that a client directs us to execute through a specified broker-dealer. Our firm
recommends the use of Pershing and Schwab. Each client will be required to establish their account(s)
with Pershing or Schwab if not already done. Please note that not all advisers have this requirement.
Permissibility of Client-Directed Brokerage
We allow clients to direct brokerage outside our recommendation. We may be unable to achieve the
most favorable execution of client transactions. Client directed brokerage may cost clients more
money. For example, in a directed brokerage account, you may pay higher brokerage commissions
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because we may not be able to aggregate orders to reduce transaction costs, or you may receive less
favorable prices.
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, we 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.
Aggregation of Purchase or Sale
We perform investment management services for various clients. There are occasions on which
portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same
security for numerous accounts served by our firm, which involve accounts with similar investment
objectives. Although such concurrent authorizations potentially could be either advantageous or
disadvantageous to any one or more particular accounts, they are affected only when we believe that to
do so will be in the best interest of the effected accounts. When such concurrent authorizations occur,
the objective is to allocate the executions in a manner which is deemed equitable to the accounts
involved. In any given situation, we attempt to allocate trade executions in the most equitable manner
possible, taking into consideration client objectives, current asset allocation and availability of funds
using price averaging, proration and consistently non-arbitrary methods of allocation.
Item 13: Review of Accounts or Financial Plans
We review accounts on at least a quarterly basis for our clients subscribing to our Asset Management
and Comprehensive Portfolio Management services. The nature of these reviews is to learn whether
clients’ accounts are in line with their investment objectives, appropriately positioned based on
market conditions, and investment policies, if applicable. We do not provide written reports to
clients, unless asked to do so. Verbal reports to clients take place on at least an annual basis when we
contact clients who subscribe to our Asset Management and Comprehensive Portfolio Management
services. Only our financial advisors or portfolio managers will conduct reviews.
We 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.
Item 14: Client Referrals & Other Compensation
Referral Fees
In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not provide
cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or
endorsements (which include client referrals).
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Aries Wealth Management, LLC
Pershing & Schwab
We may receive reimbursement from Pershing and Schwab for non-soft-dollar support services or
products, to assist us to better monitor and service client accounts maintained at such institutions.
Included within the support services we may receive investment-related research, pricing
information and market data, software and other technology that provide access to client account
data.
Item 15: Custody
Deduction of Advisory Fees:
Our clients receive account statements directly from their qualified custodians at least quarterly
upon opening of an account. If our firm 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 our firm.
Trustee for Client Accounts:
Representative(s) of our firm act as a trustee for certain client accounts. As such, our firm is deemed
to have custody. The client funds and securities of which our firm has custody are verified by actual
examination at least once during each calendar year by an independent public accountant (“IPA”)
registered with the Public Company Accounting Oversight Board (“PCAOB”), at a time that is chosen
by the accountant without prior notice or announcement to our firm and that is irregular from year
to year.
Third Party Money Movement:
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 in conjunction with Pershing and Schwab:
• 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.
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Aries Wealth Management, LLC
• 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 provide our firm with investment discretion on their behalf, pursuant to an executed
investment advisory client agreement. By granting investment discretion, we are authorized to
execute securities transactions, 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 our firm’s written acknowledgement.
Item 17: Voting Client Securities
We do not accept 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 our
firm, we will forward them on to you and ask the party who sent them to mail them directly to you 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
We are not required to provide financial information in this Brochure because:
• We do not require the prepayment of more than $1,200 in fees and six or more months in
advance.
• We do not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
• We have never been the subject of a bankruptcy proceeding.
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Aries Wealth Management, LLC