Overview

Assets Under Management: $426 million
Headquarters: PORTLAND, ME
High-Net-Worth Clients: 157
Average Client Assets: $3 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting

Fee Structure

Primary Fee Schedule (FORM ADV PART 2A - FIRM BROCHURE - ARIES WEALTH MANAGEMENT, LLC)

MinMaxMarginal Fee Rate
$0 $1,000,000 1.25%
$1,000,001 and above 0.75%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $12,500 1.25%
$5 million $42,500 0.85%
$10 million $80,000 0.80%
$50 million $380,000 0.76%
$100 million $755,000 0.76%

Clients

Number of High-Net-Worth Clients: 157
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 84.12
Average High-Net-Worth Client Assets: $3 million
Total Client Accounts: 557
Discretionary Accounts: 553
Non-Discretionary Accounts: 4

Regulatory Filings

CRD Number: 175477
Last Filing Date: 2024-03-07 00:00:00
Website: https://arieswealthllc.com

Form ADV Documents

Primary Brochure: FORM ADV PART 2A - FIRM BROCHURE - ARIES WEALTH MANAGEMENT, LLC (2025-04-30)

View Document Text
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. ADV Part 2A – Firm Brochure Page 2 Aries Wealth Management, LLC 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 ADV Part 2A – Firm Brochure Page 3 Aries Wealth Management, LLC 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. ADV Part 2A – Firm Brochure Page 4 Aries Wealth Management, LLC • 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. ADV Part 2A – Firm Brochure Page 5 Aries Wealth Management, LLC 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: ADV Part 2A – Firm Brochure Page 6 Aries Wealth Management, LLC 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. ADV Part 2A – Firm Brochure Page 7 Aries Wealth Management, LLC 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. ADV Part 2A – Firm Brochure Page 8 Aries Wealth Management, LLC 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 ADV Part 2A – Firm Brochure Page 9 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. ADV Part 2A – Firm Brochure Page 10 Aries Wealth Management, LLC 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. ADV Part 2A – Firm Brochure Page 11 Aries Wealth Management, LLC • 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. ADV Part 2A – Firm Brochure Page 12 Aries Wealth Management, LLC 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 ADV Part 2A – Firm Brochure Page 13 Aries Wealth Management, LLC 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). ADV Part 2A – Firm Brochure Page 14 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. ADV Part 2A – Firm Brochure Page 15 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. ADV Part 2A – Firm Brochure Page 16 Aries Wealth Management, LLC