View Document Text
Item 1: Cover Page
Atlantic Family Wealth, LLC
Firm Brochure - Form ADV Part 2A
This brochure provides information about the qualifications and business practices of Atlantic Family Wealth, LLC.
If you have any questions about the contents of this brochure, please contact us at (305) 222-0977 or by email at:
raul.isern@lpl.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 Atlantic Family Wealth, LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov. Atlantic Family Wealth, LLC’s CRD number is: 171062.
6705 S Red Road, Suite 604
Coral Gables, FL, 33143
(305)-222-0977
www.atlanticfamilywealth.com
raul.isern@lpl.com
Registration does not imply a certain level of skill or training.
Version Date: 03/27/2025
1
Item 2: Material Changes
Material changes are changes that relate to Atlantic Family Wealth, LLC’s policies, practices, or conflicts
of interest. The purpose of this section is to describe the material changes in this brochure from the
previous annual updating amendment of Atlantic Family Wealth, LLC submitted to regulators on March
27, 2024.
On March 27, 2025, we submitted our required annual updating amendment to regulators for fiscal year
2024. We had no material changes.
Please carefully review the entire brochure. If you have questions, or if you would like to receive a
complete copy of our most current Form ADV Part 2A Brochure at any time, free of charge, please call
us at (305) 222-0977 or email us at raul.isern@lpl.com.
2
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 .......................................................................................................................7
Item 6: Performance-Based Fees and Side-By-Side Management ............................................................9
Item 7: Types of Clients ....................................................................................................................................9
Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss ........................... 10
Item 9: Disciplinary Information ................................................................................................................. 16
Item 10: Other Financial Industry Activities and Affiliations ............................................................... 16
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Advisory Business ............................................................................................................................................ 18
Item 12: Brokerage Practices ........................................................................................................................... 19
Item 13: Reviews of Accounts ........................................................................................................................ 23
Item 14: Client Referrals and Other Compensation .................................................................................. 23
Item 15: Custody ............................................................................................................................................... 24
Item 16: Investment Discretion ...................................................................................................................... 24
Item 17: Voting Client Securities (Proxy Voting) ....................................................................................... 25
Item 18: Financial Information ...................................................................................................................... 25
PRIVACY NOTICE .......................................................................................................................................... 26
3
Item 4: Advisory Business
We provide services to individuals and high-net-worth individuals concerning mutual funds, fixed
income securities, real estate funds (including REITs), insurance products including annuities, equities,
ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation-
linked bonds, non-U.S. securities, and private placements. As a registered investment adviser, we are
held to the highest standard of client care – a fiduciary standard. As a fiduciary, we always put our
client’s interests first and must fully disclose any potential conflict of interest. We do not hold customer
funds or securities.
A. Description of the Advisory Firm
Atlantic Family Wealth, LLC (hereinafter “AFW”) is a Limited Liability Company organized in the
State of Florida.
The firm was formed in May 2014, and the principal owner is Raul Isern.
B. Types of Advisory Services
Portfolio Management Services
AFW offers ongoing portfolio management services based on the individual goals, objectives, time
horizon, and risk tolerance of each client.
AFW evaluates the current investments of each client with respect to their risk tolerance levels and time
horizon. AFW will request discretionary authority from clients in order to select securities and execute
transactions without permission from the client prior to each transaction. As such, AFW will determine
an appropriate investment strategy, construct, implement, monitor, and manage on an ongoing basis, a
portfolio of investments to be held within the Client’s account by a qualified custodian.
AFW seeks to provide that investment decisions are made in accordance with the fiduciary duties owed
to its accounts and without consideration of AFW’s economic, investment, or other financial interests. To
meet its fiduciary obligations, AFW attempts to avoid, among other things, investment or trading
practices that systematically advantage or disadvantage certain client portfolios, and accordingly, AFW’s
policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients
to avoid favoring one client over another over time. It is AFW’s policy to allocate investment
opportunities and transactions it identifies as being appropriate and prudent, including initial public
offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients
on a fair and equitable basis over time.
4
Depending on the Client’s investment needs, AFW may engage certain third-party money managers
and/or sub-advisors (collectively, “Independent Managers”) to manage all or a portion of the assets
contained in the Client account to obtain exposure to certain asset classes, investment styles/models, or
strategies. When this occurs, all or a portion of assets contained in the Client account shall be allocated
to and directly managed by the selected Independent Manager(s) who shall be responsible for (i)
implementing the investment strategy or strategies selected by AFW for the account; (ii) conducting all
related investment research; and (iii) implementing all trading decisions with respect to the allocated
assets on a discretionary basis. AFW will act as a co-advisor with respect to the allocated assets,
monitoring the Independent Manager’s activities to ensure the Independent Manager’s adherence to the
investment strategy or model chosen by AFW and that the Independent Manager’s performance,
portfolio strategies, and management remain aligned with Client’s financial profile, needs, and
limitations. AFW will also act as the Client’s primary point of contact regarding questions or concerns
with respect to the Independent Manager’s performance and management of the allocated assets.
AFW shall monitor the performance of the Client account (including any portion allocated to
Independent Managers) on an ongoing basis and implement changes within the Client’s portfolio as
needed or appropriate, in consideration of current economic conditions, AFW’s market opinions and
assumptions, and the Client’s individual financial circumstances and goals.
In limited circumstances and in our sole discretion, we also offer non-discretionary portfolio
management services. If you enter into a non-discretionary arrangement with our firm, we must obtain
your approval prior to executing any transactions on behalf of your account. You have an unrestricted
right to decline to implement any advice provided by our firm on a non-discretionary basis. LPL
Sponsored programs are available on a discretionary basis only.
LPL Financial Sponsored Advisory Programs
AFW may provide advisory services through certain programs sponsored by LPL Financial LLC (LPL),
a registered investment advisor and broker-dealer. For more information regarding the LPL programs,
including more information on the advisory services and fees that apply, the types of investments
available in the programs, and the potential conflicts of interest presented by the programs please see the
program account packet (which includes the account agreement and LPL Form ADV program brochure)
and the Form ADV, Part 2A of LPL or the applicable program.
Manager Access Select Program
Manager Access Select offers clients the ability to participate in the Separately Managed Account
Platform (the “SMA Platform”) or the Model Portfolio Platform (the “MP Platform”). In the SMA
Platform, AFW will assist the client in identifying a third-party portfolio manager (SMA Portfolio
Manager) from a list of SMA Portfolio Managers made available by LPL, and the SMA Portfolio Manager
manages the client’s assets on a discretionary basis. AFW will provide initial and ongoing assistance
5
regarding the SMA Portfolio Manager selection process. In the MP Platform, clients authorize LPL to
direct the investment and reinvestment of the assets in their accounts, in accordance with the selected
model portfolio provided by LPL’s Research Department or a third-party investment advisor. A
minimum account value of $50,000 is required for Manager Access Select, however, in certain instances,
the minimum account size may be lower or higher.
Ad-Hoc Financial Consulting; Advice Regarding Held-Away Assets
in Held-Away Accounts. Client
further understands
AFW will be reasonably available to provide ad-hoc financial consulting advice regarding common
financial questions, topics, and concerns (e.g., questions concerning retirement planning, education
planning, insurance coverage, and similar topics) as may be raised by the Client from time to time. Where
requested, such advice may include recommendations for the allocation and investment of assets held
outside of the account directly managed by AFW (“Held-Away Accounts”). Client understands that
AFW’s ad-hoc financial consulting advice is entirely non-discretionary in nature and that Client will
make all final investment decisions and be responsible for the implementation and monitoring of all
investments contained
that AFW’s
recommendations with respect to certain Held-Away Accounts (e.g., employer sponsored retirement
accounts) will be limited to recommending an appropriate allocation of Client’s holdings among the
various investment options made available by the sponsor, issuer, or custodian of such accounts. AFW
reserves the right to charge additional fees for this portion of its services for particularly complex or time
or resource intensive financial consulting requests. Any additional fees to be charged in connection with
the same shall be agreed upon in writing with the Client prior to AFW’s rendering of any such additional
services.
IRA Rollover Considerations
As a normal extension of financial advice, we provide education or recommendations related to the
rollover of an employer-sponsored retirement plan. A plan participant leaving employment has several
options. Each choice offers advantages and disadvantages, depending on desired investment options
and services, fees and expenses, withdrawal options, required minimum distributions, tax treatment,
and the investor's unique financial needs and retirement plans. The complexity of these choices may lead
an investor to seek assistance from us.
An associated person of AFW who recommends an investor roll over plan assets into an Individual
Retirement Account (“IRA”) may earn an asset-based fee as a result, but no compensation if assets are
retained in the plan. Thus, we have an economic incentive to encourage an investor to roll plan assets
into an IRA. In most cases, fees and expenses will increase for the investor as a result because the above-
described fees will apply to assets rolled over to an IRA and outlined ongoing services will be extended
to these assets.
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice
to you regarding your retirement plan account or individual retirement account, we are also fiduciaries
6
within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal
Revenue Code, as applicable, which are laws governing retirement accounts. We have to act in your best
interests and not put our interests ahead of yours. At the same time, the way we make money creates
some conflicts with your interests.
AFW generally provides investment advice on mutual funds, fixed income securities, real estate funds
(including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold
and precious metal sectors), treasury inflation protected/inflation-linked bonds, non-U.S. securities, and
private placements. AFW may use other securities as well to help diversify a portfolio when applicable.
C. Client Tailored Services and Client Imposed Restrictions
AFW offers the same suite of services to all of its clients. However, specific client investment strategies
and their implementation are dependent upon the client’s goals, risk tolerance, and investment objectives
which together outline each client’s current situation (income, tax levels, and investment experience).
Clients may impose restrictions in investing in certain securities or types of securities in accordance with
their values or beliefs. However, if the restrictions prevent AFW from properly servicing the client
account, or if the restrictions would require AFW to deviate from its standard suite of services, AFW
reserves the right to end the relationship.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that includes
management fees, transaction costs, fund expenses, and other administrative fees. AFW does not
manage, sponsor, or participate in any wrap fee programs.
E. Assets Under Management
AFW has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts:
Date Calculated:
$ 206,067,626
$ 7,083,490
12/31/2024
Item 5: Fees and Compensation
A. Fee Schedule
Asset-Based Fees for Portfolio Management
AFW’s maximum advisory fee is 1.25% and is negotiable. The agreed-upon fee will be set forth in the
advisory agreement and will be calculated based on the average daily balance.
7
The account fee charged to the client for each LPL advisory program is negotiable, subject to the following
maximum account fees for MAS accounts. The MAS account fee consists of an LPL program fee, a
strategist fee (if applicable), and AFW’s fee for a maximum combined fee of up to 1.85%. See the MAS
program brochure for more information.
B. Payment of Fees
Payment of Asset-Based Portfolio Management Fees
Asset-based portfolio management fees are withdrawn directly from the client's accounts with the client's
written authorization on a quarterly basis from the custodian. A F W ’ s fees are billed quarterly in
advance.
Where LPL serves as a program sponsor, investment adviser, and broker-dealer for the LPL advisory
programs, any associated program fees are billed quarterly in advance. See relevant program disclosures
and program agreements for detailed billing information.
C. Client Responsibility For Third-Party Fees
Clients are responsible for the payment of all third-party fees (i.e., custodian fees, brokerage fees, mutual
fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged
by AFW. Please see Item 12 of this brochure regarding broker-dealer/custodian.
D. Prepayment of Fees
AFW collects fees in advance as indicated above. At the inception of services, the first pay period’s fees
will be calculated on a pro-rata basis. If the Client did not receive AFW’s ADV Part 2 disclosures at least
48 hours prior to or at the time the Client entered into the advisory agreement with AFW, the Client may
terminate the agreement without penalty. Thereafter, either party may terminate the agreement upon
written notice to the other party. The Client will incur a pro rata charge for services rendered prior to the
termination of the agreement, which means the Client will incur advisory fees only in proportion to the
number of days in the quarter for which the Client is a Client of AFW. If the Client has pre-paid advisory
fees that AFW has not yet earned, the Client will receive a prorated refund of those fees.
See the relevant LPL program agreement for detailed information regarding account termination and
prorated fees.
8
E. Outside Compensation For the Sale of Securities to Clients
AFW or its supervised persons may accept compensation for the sale of securities or other investment
products, including asset-based sales charges or service fees from the sale of mutual funds.
Raul Alfonso Isern is a registered representative of a broker-dealer and an insurance agent and, in these
roles, accepts compensation for the sale of securities and other products to AFW clients.
1. This is a Conflict of Interest
Supervised persons may accept compensation for the sale of securities or other investment
products, including asset-based sales charges or service fees from the sale of mutual funds to
AFW's clients. This presents a conflict of interest and gives the supervised person an incentive to
recommend products based on the compensation received rather than on the client’s needs. When
recommending the sale of securities or investment products for which the supervised persons
receive compensation, AFW will document the conflict of interest in the client file and inform the
client of the conflict of interest.
2. Clients Have the Option to Purchase Recommended Products From Other Brokers
Clients always have the option to purchase AFW recommended products through other brokers
or agents that are not affiliated with AFW.
3. Commissions are not the Primary Source of Income for AFW
Commissions are not the primary source of compensation for licensed individuals associated with
AFW.
Item 6: Performance-Based Fees and Side-By-Side Management
AFW does not accept performance-based fees or other fees based on a share of capital gains on or capital
appreciation of the assets of a client.
Item 7: Types of Clients
AFW generally provides advisory services to the following types of clients:
Individuals
High-Net-Worth Individuals
9
Minimum Account Size
There is no account minimum for any of AFW’s services. However, some LPL programs or third-party
programs may impose account minimums.
Item 8: Methods of Analysis, Investment Strategies, and Risk of
Investment Loss
A. Methods of Analysis and Investment Strategies
Methods of Analysis
AFW utilizes modern portfolio theory. Modern portfolio theory is a theory of investment that attempts
to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk
for a given level of expected return, by carefully choosing the proportions of various assets.
Investment Strategies
AFW uses long-term trading, short-term trading, short sales, margin transactions, and options trading
(including covered options, uncovered options, or spreading strategies).
Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.
B. Material Risks Involved
Methods of Analysis
Modern Portfolio Theory assumes that investors are risk-averse, meaning that given two portfolios that
offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on
increased risk only if compensated by higher expected returns. Conversely, an investor who wants
higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but
different investors will evaluate the trade-off differently based on individual risk aversion characteristics.
The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a
more favorable risk-expected return profile – i.e., if for that level of risk, an alternative portfolio exists
which has better expected returns.
Investment Strategies
AFW's use of short sales, margin transactions, and options trading generally hold greater risk, and clients
10
should be aware that there is a material risk of loss using any of those strategies.
inflation
(purchasing power) risk,
Long-term trading is designed to capture market rates of both return and risk. Due to its nature, the
long-term investment strategy can expose clients to various types of risk that will typically surface at
various intervals during the time the client owns the investments. These risks include but are not limited
to
interest rate risk, economic risk, market risk, and
political/regulatory risk.
Short-term trading risks include liquidity, economic stability, and inflation, in addition to the long-term
trading risks listed above. Frequent trading can affect investment performance, particularly through
increased brokerage and other transaction costs and taxes.
Short sales entail the possibility of infinite loss. An increase in the applicable securities’ prices will result
in a loss and, over time, the market has historically trended upward.
Margin transactions use leverage that is borrowed from a brokerage firm as collateral. When losses
occur, the value of the margin account may fall below the brokerage firm’s threshold thereby triggering
a margin call. This may force the account holder to either allocate more funds to the account or sell assets
in a shorter time frame than desired.
Options transactions involve a contract to purchase a security at a given price, not necessarily at market
value, depending on the market. This strategy includes the risk that an option may expire out of the
money resulting in minimal or no value, as well as the possibility of a leveraged loss of trading capital due
to the leveraged nature of stock options. Investing in securities involves a risk of loss that you, as a
client, should be prepared to bear.
C. Risks of Specific Securities Utilized
AFW's use of short sales, margin transactions, and options trading generally hold a greater risk of capital
loss. Clients should be aware that there is a material risk of loss using any investment strategy. The
investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not
guaranteed or insured by the FDIC or any other government agency.
Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money
investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be
of bond “fixed income” nature (lower risk) or stock “equity” nature (mentioned below).
An equity investment generally refers to buying shares of stocks in return for receiving a future payment
of dividends and/or capital gains if the value of the stock increases. The value of equity securities may
fluctuate in response to specific situations for each company, industry conditions, and the general
economic environments.
11
Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments
can vary. This type of investment can include corporate and government debt securities, leveraged loans,
high yield, and investment grade debt, and structured products, such as mortgage and other asset-backed
securities, although individual bonds may be the best-known type of fixed income security. In general,
the fixed income market is volatile, and fixed income securities carry interest rate risk. (As interest rates
rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term
securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default
risks for both issuers and counterparties. The risk of default on treasury inflation-protected/inflation-
linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a
potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income
securities also include the general risk of non-U.S. investing described below.
Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to
stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a
stock holding bankruptcy). Areas of concern include the lack of transparency in products and
increasing complexity, conflicts of interest, and the possibility of inadequate regulatory compliance.
Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical
metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by
the official sector which owns a significant portion of aggregate world holdings in gold and other
precious metals, (2) a significant increase in hedging activities by producers of gold or other precious
metals, (3) a significant change in the attitude of speculators and investors.
Risks Associated with Investing in Buffer ETFs: Buffer ETFs are also known as defined-outcome ETFs
since the ETF is designed to offer downside protection for a specified period of time. These ETFs are
modeled after options-based structured notes, but are generally cheaper, and offer more liquidity. Buffer
ETFs are designed to safeguard against market downturns by employing complex options strategies.
Buffer ETFs typically charge higher management fees that are considerably more than the index funds
whose performance they attempt to track. Additionally, because buffer funds own options, they do not
receive dividends from their equity holdings. Both factors result in the underperformance of the Buffer
ETF compared to the index they attempt to track. Clients should carefully read the prospectus for a buffer
ETF to fully understand the cost structures, risks, and features of these complex products.
Risks Associated with Investing in Inverse and Leveraged Funds: Leveraged mutual funds and ETFs
generally seek to deliver multiples of the daily performance of the index or benchmark that they track.
Inverse mutual funds and ETFs generally seek to deliver the opposite of the daily performance of the
index or benchmark that they track. Inverse funds often are marketed as a way for investors to profit
from, or at least hedge their exposure to, downward-moving markets. Some Inverse funds are both
inverse and leveraged, meaning that they seek a return that is a multiple of the inverse performance of
the underlying index. To accomplish their objectives, leveraged and inverse funds use a range of
investment strategies, including swaps, futures contracts, and other derivative instruments. Leveraged,
12
inverse, and leveraged inverse funds are more volatile and riskier than traditional funds due to their
exposure to leverage and derivatives, particularly total return swaps and futures. At times, we will
recommend leveraged and/or inversed funds, which may amplify gains and losses.
Most leveraged funds are typically designed to achieve their desired exposure on a daily (in a few cases,
monthly) basis, and reset their leverage daily. A "single day" is measured from the time the leveraged
fund calculates its net asset value ("NAV") to the time of the leveraged fund's next NAV calculation. The
return of the leveraged fund for periods longer than a single day will be the result of each day's returns
compounded over the period. Due to the effect of this mathematical compounding, their performance
over longer periods of time can differ significantly from the performance (or inverse performance) of
their underlying index or benchmark during the same period of time. For periods longer than a single
day, the leveraged fund will lose money when the level of the Index is flat, and the leveraged fund may
lose money even if the level of the Index rises. Longer holding periods, higher index volatility, and
greater leverage all exacerbate the impact of compounding on an investor's returns. During periods of
higher Index volatility, the volatility of the Index may affect the leveraged fund's return as much as or
more than the return of the Index itself. Therefore, holding leveraged, inverse, and leveraged inverse
funds for longer periods of time increases their risk due to the effects of compounding and the inherent
difficulty in market timing. Leveraged funds are riskier than similarly benchmarked funds that do not
use leverage. Non-traditional funds are highly volatile and not suitable for all investors. They provide
the potential for significant losses.
Real Estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector,
which historically has experienced significant fluctuations and cycles in performance. Revenues and cash
flows may be adversely affected by: changes in local real estate market conditions due to changes in
national or local economic conditions or changes in local property market characteristics; competition
from other properties offering the same or similar services; changes in interest rates and in the state of
the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax
rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse
changes in zoning laws; the impact of present or future environmental legislation and compliance with
environmental laws.
Annuities are a retirement product for those who may have the ability to pay a premium now and want
to guarantee they receive certain monthly payments or a return on investment later in the future.
Annuities are contracts issued by a life insurance company designed to meet a requirement or other long-
term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term
investments, to meet retirement and other long-range goals. Variable annuities are not suitable for
meeting short-term goals because substantial taxes and insurance company charges may apply if you
withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do.
Private placements carry a substantial risk as they are subject to less regulation than publicly offered
securities, the market to resell these assets under applicable securities laws may be illiquid, due to
13
restrictions, and the liquidation may be taken at a substantial discount to the underlying value or result
in the entire loss of the value of such assets.
Options are contracts to purchase a security at a given price, risking that an option may expire out of the
money resulting in minimal or no value. An uncovered option is a type of options contract that is not
backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put
is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option
positions entail buying and selling multiple options on the same underlying security, but with different
strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option
transactions also involve risks including but not limited to economic risk, market risk, sector risk,
idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk, and interest rate risk.
Non-U.S. securities present certain risks such as currency fluctuation, political and economic change,
social unrest, changes in government regulation, differences in accounting, and the lesser degree of
accurate public information available.
Structured Notes: Below are some specific risks related to the structured notes recommended by our
firm:
• Complexity: Structured notes are complex financial instruments. Clients should understand the
reference asset(s) or index(es) and determine how the note’s payoff structure incorporates such
reference asset(s) or index(es) in calculating the note’s performance. This payoff calculation may
include leverage multiplied by the performance of the reference asset or index and protection from
losses should the reference asset or index produce negative returns, and/or fees. Structured notes
may have complicated payoff structures that can make it difficult for clients to accurately assess
their value, risk, and potential for growth through the term of the structured note. Determining the
performance of each note can be complex and this calculation can vary significantly from note to
note depending on the structure. Notes can be structured in a wide variety of ways. Payoff
structures can be leveraged, inverse, or inverse-leveraged, which may result in larger returns or
losses. Clients should carefully read the prospectus for a structured note to fully understand how
the payoff on a note will be calculated and discuss these issues with our firm.
•
• Market risk. Some structured notes provide for the repayment of principal at maturity, which is
often referred to as “principal protection.” This principal protection is subject to the credit risk of
the issuing financial institution. Many structured notes do not offer this feature. For structured
notes that do not offer principal protection, the performance of the linked asset or index may cause
clients to lose some, or all, of their principal. Depending on the nature of the linked asset or index,
the market risk of the structured note may include changes in equity or commodity prices, changes
in interest rates or foreign exchange rates, and/or market volatility.
Issuance price and note value: The price of a structured note at issuance will likely be higher than the
fair value of the structured note on the date of issuance. Issuers now generally disclose an estimated
value of the structured note on the cover page of the offering prospectus, allowing investors to
14
gauge the difference between the issuer’s estimated value of the note and the issuance price. The
estimated value of the notes is likely lower than the issuance price of the note to investors because
issuers include the costs for selling, structuring, and/or hedging the exposure on the note in the
initial price of their notes. After issuance, structured notes may not be re-sold on a daily basis and
thus may be difficult to value given their complexity.
• Liquidity: The ability to trade or sell structured notes in a secondary market is often very limited, as
structured notes (other than exchange-traded notes known as ETNs) are not listed for trading on
securities exchanges. As a result, the only potential buyer for a structured note may be the issuing
financial institution’s broker-dealer affiliate or the broker-dealer distributor of the structured note.
In addition, issuers often specifically disclaim their intention to repurchase or make markets in the
notes they issue. Clients should, therefore, be prepared to hold a structured note to its maturity
date or risk selling the note at a discount to its value at the time of sale.
• Credit risk: Structured notes are unsecured debt obligations of the issuer, meaning that the issuer is
obligated to make payments on the notes as promised. These promises, including any principal
protection, are only as good as the financial health of the structured note issuer. If the structured
note issuer defaults on these obligations, investors may lose some, or all, of the principal amount
they invested in the structured notes as well as any other payments that may be due on the
structured notes.
• Environmental, Social, and Governance Investment Criteria Risk: If a portfolio is subject to certain
environmental, social, and governance (ESG) investment criteria it may avoid purchasing certain
securities for ESG reasons when it is otherwise economically advantageous to purchase those
securities or may sell certain securities for ESG reasons when it is otherwise economically
advantageous to hold those securities. In general, the application of the portfolio’s ESG investment
criteria may affect the portfolio’s exposure to certain issuers, industries, sectors, and geographic
areas, which may affect the financial performance of the portfolio, positively or negatively,
depending on whether these issuers, industries, sectors or geographic areas are in or out of favor. An
adviser can vary materially from other advisers with respect to its methodology for constructing ESG
portfolios or screens, including with respect to the factors and data that it collects and evaluates as
part of its process. As a result, an adviser’s ESG portfolio or screen may materially differ from or
contradict the conclusions reached by other ESG advisers concerning the same issuers. Further, ESG
criteria are dependent on data and are subject to the risk that such data reported by issuers or received
from third-party sources may be subjective, or it may be objective in principle but not verified or
reliable.
Past performance is not indicative of future results. Investing in securities involves a risk of loss that
you, as a client, should be prepared to bear.
15
Item 9: Disciplinary Information
A. Criminal or Civil Actions
There are no criminal or civil actions to report.
B. Administrative Proceedings
There are no administrative proceedings to report.
C. Self-regulatory Organization (SRO) Proceedings
There are no self-regulatory organization proceedings to report.
Item 10: Other Financial Industry Activities and Affiliations
A. Registration as a Broker/Dealer or Broker/Dealer Representative
As a registered representative of LPL, Raul Alfonso Isern accepts compensation for the sale of securities
in his capacities with LPL.
B. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a
Commodity Trading Advisor
Neither AFW nor its representatives are registered as or have pending applications to become either a
Futures Commission Merchant, Commodity Pool Operator, Commodity Trading Advisor, or an
associated person of the foregoing entities.
D. Registration Relationships Material to this Advisory Business and Possible Conflicts of
Interests
Raul Alfonso Isern is a registered representative of LPL and a licensed insurance agent and from time to
time, will offer clients advice or products from those activities. Clients should be aware that these services
pay a commission or other compensation and involve a conflict of interest, as commissionable products
conflict with the fiduciary duties of a registered investment adviser. AFW always acts in the best interest
of the client, including with respect to the sale of commissionable products to advisory clients. Clients are
in no way required to implement the plan through any representative of AFW in such individual’s
capacity as a registered representative.
16
Additionally, as licensed insurance agents, individuals associated with AFW, including Mr. Isern, will
earn commission-based compensation for selling insurance products, including insurance products they
sell to AFW clients. Insurance commissions paid to licensed individuals associated with AFW are
separate from and in addition to AFW’s advisory fees. The sale of insurance instruments and other
commissionable products offered by associated, licensed individuals are intended to complement our
advisory services. However, this practice presents a conflict of interest because individuals providing
investment advice on behalf of AFW who are insurance agents have an incentive to recommend
insurance products to you for the purpose of generating commissions rather than recommending them
based solely on your needs. We address this conflict of interest by recommending insurance products
only where we, in good faith, believe that it is appropriate for the client’s particular needs and
circumstances and only after a full presentation of the recommended insurance product to our client. In
addition, we explain the insurance underwriting process to our clients to illustrate how the insurer also
reviews the client’s application and disclosures prior to the issuance of a resulting insuring agreement.
Clients to whom AFW offers advisory services are informed that they are under no obligation to purchase
insurance services. Clients who choose to purchase insurance services are under no obligation to do so
through licensed individuals associated with AFW and may use any insurance firm and agent they
choose.
Where fixed annuities are sold, clients should also note that the annuity sales result in substantial up-
front commissions and ongoing trails based on the annuity’s total value. In addition, many annuities
contain surrender charges and/or restrictions on access to your funds. Payments and withdrawals can
have tax consequences. Optional lifetime income benefit riders are used to calculate lifetime payments
only and are not available for cash surrender or in a death benefit unless specified in the annuity contract.
In some annuity products, fees can apply when using an income rider. Annuity guarantees are based on
the financial strength and claims-paying ability of the issuing insurance company. We urge our clients
to read all insurance contract disclosures carefully before making a purchase decision. Rates and returns
mentioned on any program presented are subject to change without notice. Insurance products are
subject to fees and additional expenses.
Raul Alfonso Isern is a Board Member of the Plaza San Remo Property Owner's Association.
E. Selection of Other Advisers or Managers and How This Adviser is Compensated for
Those Selections
AFW may direct clients to third-party investment advisers. AFW will always act in the best interests of
the client, including when determining which third-party investment adviser to recommend to clients.
AFW will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states
where AFW is recommending the adviser to clients.
AFW receives compensation as a result of a client’s participation in an LPL program. Depending on,
among other things, the type and size of the account, the type of securities held in the account, changes
17
in its value over time, the ability to negotiate fees or commissions, the historical or expected size or the
number of transactions, and the number and range of supplementary advisory and client-related services
provided to the client, the amount of this compensation may be more or less than what the AFW would
receive if the client participated in other programs, whether through LPL or another sponsor or paid
separately for investment advice, brokerage, and other services.
Clients should consider the level and complexity of the advisory services to be provided when
negotiating the account fee (or AFW’s portion of the account fee, as applicable) with AFW. With regard
to accounts utilizing third-party portfolio managers under aggregate, all-in-one account fee structures,
the portion of the account fee retained by AFW varies depending on the portfolio strategist fee associated
with a portfolio.
Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading Advisory Business
A. Code of Ethics
AFW has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider
Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of
Interest, Gifts, and Entertainment, Confidentiality, Service on a Board of Directors, Compliance
Procedures, Compliance with Laws and Regulations, Procedures, and Reporting, Certification of
Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping,
Annual Review, and Sanctions. AFW's Code of Ethics is available free upon request to any client or
prospective client.
B. Recommendations Involving Material Financial Interests
AFW does not recommend that clients buy or sell any security in which a related person to AFW or AFW
has a material financial interest.
C. Investing Personal Money in the Same Securities as Clients
From time to time, representatives of AFW may buy or sell securities for themselves that they also
recommend to clients. This may provide an opportunity for representatives of AFW to buy or sell the
same securities before or after recommending the same securities to clients resulting in representatives
profiting off the recommendations they provide to clients. Such transactions may create a conflict of
interest. AFW will always document any transactions that could be construed as conflicts of interest and
will never engage in trading that operates to the client’s disadvantage when similar securities are being
bought or sold.
18
D. Trading Securities At/Around the Same Time as Clients’ Securities
From time to time, representatives of AFW may buy or sell securities for themselves at or around the
same time as clients. This may provide an opportunity for representatives of AFW to buy or sell securities
before or after recommending securities to clients resulting in representatives profiting off the
recommendations they provide to clients. Such transactions may create a conflict of interest; however,
AFW will never engage in trading that operates to the client’s disadvantage if representatives of AFW
buy or sell securities at or around the same time as clients.
Item 12: Brokerage Practices
A. Factors Used to Select Custodians and/or Broker/Dealers
Custodians/broker-dealers will be chosen based on AFW’s duty to seek “best execution,” which is the
obligation to seek execution of securities transactions for a client on the most favorable terms for the client
under the circumstances. Clients will not necessarily pay the lowest commission or commission
equivalent, and AFW may also consider the market expertise and research access provided by the broker-
dealer/custodian, including but not limited to access to written research, oral communication with
analysts, admittance to research conferences and other resources provided by the brokers that may aid in
AFW's research efforts. AFW will never charge a premium or commission on transactions, beyond the
actual cost imposed by the broker-dealer/custodian.
Currently, we recommend the brokerage and custodial services of unaffiliated qualified custodians. We
believe that recommended broker-dealers/custodians provide quality execution services for you at
competitive prices. Price is not the sole factor we consider in evaluating best execution. We also consider
the quality of the brokerage services provided by recommended broker-dealers/custodians, including
the value of research provided, the company’s reputation, execution capabilities, commission rates, and
responsiveness to our clients and our firm. In recognition of the value of research services and additional
brokerage products and services recommended broker-dealers/custodians provide, you may pay higher
commissions and/or trading costs than those that may be available elsewhere.
At this time, we primarily recommend the services of LPL Financial LLC (LPL) and Charles Schwab &
Co., Inc. (Schwab), both FINRA-registered broker-dealers and members SIPC.
Brokerage and Custodial Services Offered by LPL
AFW recommends that you establish brokerage accounts with LPL, a registered broker-dealer and
member SIPC, to maintain custody of assets and to effect trades. Factors, which AFW considers in
recommending LPL to clients, include their respective financial strength, reputation, execution, pricing,
research, and service. LPL enables AFW to obtain many mutual funds without transaction charges and
19
other securities at nominal transaction charges. The commissions and/or transaction fees charged by
LPL may be higher or lower than those other Financial Institutions may charge.
LPL provides AFW with access to its institutional trading and custody services, which are typically not
available to retail investors. LPL services include brokerage, custody, research, and access to mutual
funds and other investments that are otherwise generally available only to institutional investors or that
would require a significantly higher minimum initial investment.
For AFW’s client accounts maintained in custody, LPL charges account holders transaction-related fees
for securities trades. LPL provides AFW assistance in managing and administering clients’ accounts.
These include access to client account data, facilitating trade execution, providing research, facilitating
payment of AFW management fees from its clients’ accounts, recordkeeping, and client reporting. LPL
also makes available to AFW other services intended to help AFW manage and further develop its
business enterprise. These services may include consulting, publications, and conferences on practice
management, information technology, business succession, regulatory compliance, and marketing.
In choosing a broker-dealer or negotiating commission rates, we are not obligated to seek competitive
bids or the lowest commission cost to you; but we determine that the commission rate charged is
reasonable based on the quality of custodial services available to our clients. As a fiduciary, AFW
endeavors to act in your best interest.
The commissions paid by AFW’s clients comply with AFW’s duty to obtain “best execution.” Clients
may pay commissions that are higher than another qualified Financial Institution might charge to effect
the same transaction where AFW determines that the commissions are 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 Financial Institution’s services, including among others, the value of
research provided, execution capability, commission rates, and responsiveness. AFW seeks competitive
rates but may not necessarily obtain the lowest possible commission rates for client transactions.
Schwab Advisor Services
AFW has an institutional custodial relationship with Charles Schwab & Co., Inc. (Schwab), a FINRA-
registered broker-dealer, member SIPC. Schwab Advisor Services (formerly called Schwab Institutional)
is Schwab’s business serving independent investment advisory firms like ours. We are independently
owned and operated and not affiliated with Schwab. Schwab will hold your assets in a brokerage account
and will buy and sell securities in your account(s) upon our instructions. While we recommend that you
use Schwab as custodian/broker, you will decide whether to do so and you will open your account with
Schwab by entering into an account agreement directly with them. We do not open the account for you.
20
Schwab generally does not charge you separately for custody services but is compensated by charging
commissions or other fees on trades that it executes or that settle into your Schwab account. In addition
to commissions, Schwab charges a flat dollar amount as a “prime broker” or “trade away” fee for each
trade that we have executed by a different broker-dealer but where the securities bought or the funds
from the securities sold are deposited (settled) into your Schwab account.
Below is a 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 us other products and services
that benefit us but may not directly benefit you or your account. These products and services assist us 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:
• provide access to client account data (such as duplicate trade confirmations and account
statements);
facilitate trade execution and allocate aggregated trade orders for multiple client accounts;
facilitate payment of our fees from our clients’ accounts; and
•
• provide pricing and other market data;
•
• assist with back-office functions, recordkeeping, and client reporting.
Services that Generally Benefit Only Us: Schwab also offers other services intended to help us manage and
further develop our business enterprise. These services include:
technology, compliance, legal, and business consulting;
• educational conferences and events;
•
• publications and conferences on practice management and business succession; and
• access to employee benefits providers, human capital consultants, and insurance providers.
Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors
to provide the services to us. Schwab may also discount or waive its fees for some of these services or
pay all or a part of a third party’s fees. Schwab may also provide us with other benefits such as occasional
business entertainment for our personnel.
21
1. Research and Other Soft-Dollar Benefits
While AFW has no formal soft dollar program in which soft dollars are used to pay for third-party
services, AFW may receive research, products, or other services from custodians and broker-dealers in
connection with client securities transactions (“soft dollar benefits”). As described above and below in
Item 14, AFW will receive other economic benefits from recommended custodians in the form of access
to its institutional brokerage, trading, custody, reporting, and related support services, many of which
are not typically available to retail customers. Some of those services help us manage or administer our
clients’ accounts while others help us manage and grow our business. Schwab’s support services are
generally available on an unsolicited basis (we don’t have to request them) and at no charge to us.
Therefore, we have an incentive to recommend LPL or Schwab over other custodians based on the
economic benefits available to us through our relationships with LPL and Schwab.
2. Brokerage for Client Referrals
AFW receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer
or third party.
3. Clients Directing Which Broker/Dealer/Custodian to Use
Neither we nor any of our firm’s related persons have discretionary authority in determining 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. AFW recommends clients use LPL and/or Charles Schwab &
Co., Inc. Associated persons of our firm, who are registered representatives of LPL, are subject to FINRA conduct
rules, which restrict such registered individuals from conducting securities transactions away from LPL unless LPL
provides the representative with written authorization. Therefore, clients are advised that such persons may be
limited to conducting certain securities transactions through LPL or another broker-dealer/custodian approved by
LPL. Not all Advisers require their clients to direct brokerage to a specific broker-dealer/custodian. AFW has chosen
LPL and Schwab based on several factors, including quality of service, fees, reputation, accountability, and security
of assets.
B. Aggregating (Block) Trading for Multiple Client Accounts
AFW does not aggregate or bunch the securities to be purchased or sold for multiple clients. This may
result in less favorable prices, particularly for illiquid securities or during volatile market conditions.
22
Item 13: Reviews of Accounts
A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews
All client portfolio management accounts are monitored on a regular and continuous basis by Raul Isern
with regard to clients’ respective investment objectives and risk tolerance levels. AFW recommends
account reviews with clients at least annually or as needed when there are changes in the client’s needs
or circumstances.
B. Factors That Will Trigger a Non-Periodic Review of Client Accounts
Reviews may be triggered by material market, economic or political events, or by changes in the client's
financial situation (such as retirement, termination of employment, physical move, or inheritance).
C. Content and Frequency of Regular Reports Provided to Clients
Client accounts held at LPL will receive a quarterly report detailing the client’s account, including assets
held, asset value, and calculation of fees. This written report will come from LPL. Advent Custodial Data
Network via Black Diamond software is used for client accounts held at Charles Schwab & Co., Inc.
Item 14: Client Referrals and Other Compensation
A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales
Awards or Other Prizes
AFW has brokerage and clearing arrangements with LPL and Schwab, and we may receive additional
benefits from these firms in the form of electronic delivery of client information, electronic trading
platforms, institutional trading support, proprietary and/or third-party research, continuing education,
practice management advice, and other services provided by custodians for the benefit of investment
advisory clients. Please refer to item 12 above for more information about the receipt of additional
benefits from broker-dealers/account custodians.
Additionally, AFW and employees may receive additional compensation from product sponsors.
However, such compensation will not be tied to the sales of any products. Compensation could include
such items as gifts of a de minimis value; an occasional dinner or ticket to a sporting event;
reimbursement in connection with educational meetings with an associated person of AFW, client
workshops, or events; or marketing events or advertising initiatives, including services for identifying
prospective clients. Product sponsors may also pay for or reimburse AFW for the costs associated with
AFW employees and investment adviser representatives attending various education or training events,
as well as conferences and events sponsored by or in conjunction with AFW.
23
B. Compensation to Non-Advisory Personnel for Client Referrals
AFW may enter into written arrangements with third parties to act as promoters for AFW's investment
management services. Promoter relationships will be fully disclosed to each client to the extent required
by applicable law. AFW will ensure each promoter is properly registered in jurisdictions where required.
Item 15: Custody
AFW does not have physical custody of any Client funds and/or securities. Client funds and securities
will be held with a bank, broker-dealer, or other independent, qualified custodian. As paying agent for
AFW, the Client’s independent custodian will directly debit the Client’s account(s) for the payment of
advisory fees. Where AFW calculates the fee and directs the account custodian to debit the fee, AFW is
deemed to have custody of client funds or securities solely because of the fee deduction authority granted
by the client in the investment advisory agreement and in certain situations where we accept standing
letters of authorization from you to transfer assets to third parties. Accordingly, AFW maintains
safeguards in accordance with regulatory requirements regarding the custody of Client assets. Where
the account custodian, program sponsor, or Independent Manager calculates and deducts the fee, we are
not deemed to have custody.
In any case, the Client will receive account statements from the independent, qualified custodian(s)
holding the Client’s funds and securities at least quarterly. The account statements from the custodian(s)
will indicate any deductions from the Client’s account(s), including the amount of advisory fees
deducted from the account(s) each billing period. Clients should carefully review account statements for
accuracy. Clients should contact us directly at the telephone number on the cover page of this brochure
with any questions regarding their account statement(s).
Item 16: Investment Discretion
AFW provides discretionary and non-discretionary investment advisory services to clients. The
Investment Advisory Contract established with each client sets forth the discretionary authority for
trading. Where investment discretion has been granted, AFW manages the client’s account and makes
investment decisions without consultation with the client as to when the securities are to be bought or
sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell,
or the price per share.
If you enter into non-discretionary arrangements with our firm, we will obtain your approval prior to
the execution of any transactions for your account(s). You have an unrestricted right to decline to
implement any advice provided by our firm on a non-discretionary basis.
24
Item 17: Voting Client Securities (Proxy Voting)
AFW will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly
from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of
the security.
Item 18: Financial Information
A. Balance Sheet
AFW neither requires nor solicits prepayment of more than $500 in fees per client, six months or more in
advance. Therefore, AFW is not required to include a balance sheet with this brochure.
B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual
Commitments to Clients
Neither AFW nor its management has any financial condition that is likely to reasonably impair AFW’s
ability to meet contractual commitments to clients.
C. Bankruptcy Petitions in the Previous Ten Years
AFW has not been the subject of a bankruptcy petition in the last ten years.
25
PRIVACY NOTICE
This notice is being provided to you in accordance with the Securities and Exchange Commission’s rule
regarding the privacy of consumer financial information (“Regulation S-P”). Please take the time to read
and understand the privacy policies and procedures that we have implemented to safeguard your
nonpublic personal information.
INFORMATION WE COLLECT
Atlantic Family Wealth, LLC (AFW) must collect certain personally identifiable financial information
about its customers to provide financial services and products. The personally identifiable financial
information that we gather during the normal course of doing business with you may include:
information we receive from you on applications or other forms;
information about your transactions with us, our affiliates, or others;
information we receive from a consumer reporting agency.
•
•
•
INFORMATION WE DISCLOSE
We do not disclose any nonpublic personal information about our customers or former customers to
anyone, except as permitted or required by law, or as necessary to provide services to you. In accordance
with Section 248.13 of Regulation S-P, we may disclose all of the information we collect, as described
above, to certain nonaffiliated third parties such as our attorneys, accountants, auditors, and persons or
entities that are assessing our compliance with industry standards. We enter into contractual agreements
with all nonaffiliated third parties that prohibit such third parties from disclosing or using the
information other than to carry out the purposes for which we disclose the information.
Regulation S-AM: Under Regulation S-AM, we are prohibited from using eligibility information that we
receive from an affiliate to make a marketing solicitation unless: (1) the potential marketing use of that
information has been clearly, conspicuously, and concisely disclosed to the consumer; (2) the consumer
has been provided a reasonable opportunity and a simple method to opt out of receiving the marketing
solicitations; and (3) the consumer has not opted out. We do not receive information regarding marketing
eligibility from affiliates to make solicitations.
Regulation S-ID: Regulation S-ID requires our firm to have an Identity Theft Protection Program (ITPP)
that controls reasonably foreseeable risks to customers or to the safety and soundness of our firm from
identity theft. We have developed an ITPP to adequately identify and detect potential red flags to prevent
and mitigate identity theft.
26
CONFIDENTIALITY AND SECURITY
We restrict access to nonpublic personal information about you to those Employees who need to know
that information to provide financial products or services to you. We maintain physical, electronic, and
procedural safeguards that comply with federal standards to guard your nonpublic personal
information.
ACCURACY
AFW strives to maintain accurate personal information in our client files at all times. However, as
personal situations, facts, and data change over time; we encourage our clients to provide feedback and
updated information to help us meet our goals.
CLOSED OR INACTIVE ACCOUNTS
If you decide to close your account(s) or become an inactive customer, our Privacy Policy will continue
to apply to you.
CHANGES TO OUR PRIVACY POLICY
If we make any substantial changes in the way we use or disseminate confidential information, we
will notify you. If you have any questions concerning this Privacy Policy, please call us at (305)
222-0977 or email us at raul.isern@lpl.com.
v.03/2024
27