Overview

Assets Under Management: $202 million
Headquarters: LAKEWOOD, CO
High-Net-Worth Clients: 70
Average Client Assets: $1.8 million

Frequently Asked Questions

BAM WEALTH MANAGEMENT LLC charges 2.25% on all assets according to their SEC Form ADV filing. See complete fee breakdown ↓

Yes. As an SEC-registered investment advisor (CRD #330237), BAM WEALTH MANAGEMENT LLC is subject to fiduciary duty under federal law.

BAM WEALTH MANAGEMENT LLC is headquartered in LAKEWOOD, CO.

BAM WEALTH MANAGEMENT LLC serves 70 high-net-worth clients according to their SEC filing dated February 24, 2026. View client details ↓

According to their SEC Form ADV, BAM WEALTH MANAGEMENT LLC offers financial planning, portfolio management for individuals, selection of other advisors, and educational seminars and workshops. View all service details ↓

BAM WEALTH MANAGEMENT LLC manages $202 million in client assets according to their SEC filing dated February 24, 2026.

According to their SEC Form ADV, BAM WEALTH MANAGEMENT LLC serves high-net-worth individuals. View client details ↓

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection, Educational Seminars

Fee Structure

Primary Fee Schedule (FORM ADV PART 2A - BAM WEALTH MANAGEMENT LLC)

MinMaxMarginal Fee Rate
$0 and above 2.25%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $22,500 2.25%
$5 million $112,500 2.25%
$10 million $225,000 2.25%
$50 million $1,125,000 2.25%
$100 million $2,250,000 2.25%

Clients

Number of High-Net-Worth Clients: 70
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 60.92%
Average Client Assets: $1.8 million
Total Client Accounts: 839
Discretionary Accounts: 834
Non-Discretionary Accounts: 5
Minimum Account Size: Minimum not disclosed

Regulatory Filings

CRD Number: 330237
Filing ID: 2059007
Last Filing Date: 2026-02-24 16:37:05

Form ADV Documents

Primary Brochure: FORM ADV PART 2A - BAM WEALTH MANAGEMENT LLC (2026-02-24)

View Document Text
Item 1 Cover Page BAM Wealth Management LLC 165 S. Union Blvd, Ste 675 Lakewood, CO 80228 (303) 531-5055 Form ADV Part 2A February 24, 2026 www.bamadvisorygroup.com This Brochure provides information about the qualifications and business practices of BAM Wealth Management LLC (“BAM”, “we”, “us” or the “Firm”). If you have any questions about the contents of this Brochure, please contact us (303) 531-5055. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about BAM is also available on the SEC’s website at www.adviserinfo.sec.gov. The Firm’s CRD number is 330237. Any reference to BAM as a “registered investment adviser” or as being “registered” does not imply a certain level of skill or training. BAM Wealth Management LLC Form ADV Part 2A 1 Item 2 - Material Changes BAM Wealth Management LLC is a newly founded registered investment advisor. This is the initial filing of the Disclosure Brochure. BAM Wealth Management LLC has the following material changes to report. Material changes relate to BAM Wealth Management LLC’s policies, practices or conflicts of interests. • The firm has updated its assets under management. (Item 4) The Firm encourages all current and prospective clients to read this Brochure carefully and, in its entirety, and to discuss any question you may have with us. At any time, the current Disclosure Brochure is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching the firm name or CRD number 330237. A copy of this Disclosure Brochure may be requested at any time, by contacting (303) 531-5055 or by email at kafraimi@bamadvisorygroup.com. BAM Wealth Management LLC Form ADV Part 2A 2 Item 3 – Table of Contents Item 1 – Cover Page Item 2 – Material Changes Item 3 – Table of Contents Item 4 – Advisory Business Item 5 – Fees and Compensation Item 6 – Performance Fees Item 7 – Types of Clients Item 8 – Methods of Analysis, Investment Strategies, Risk of Loss Item 9 – Disciplinary Information Item 10 – Other Financial Industry Activities and Affiliations Item 11 – Code of Ethics, Participation/Interest in Client Transactions, Personal Trading Item 12 – Brokerage Practices Item 13 – Review of Accounts Item 14 – Client Referrals and Other Compensation Item 15 – Custody Item 16 – Investment Discretion Item 17 – Voting Client Securities Item 18 – Financial Information 1 2 3 4 7 8 9 9 14 14 15 16 17 18 18 19 19 19 BAM Wealth Management LLC Form ADV Part 2A 3 Item 4 – Advisory Business Description of the Advisory Firm Founded in 2023, BAM Wealth Management LLC (hereinafter “we”, “us”, the “Firm” or “BAM”) is an investment advisory firm providing fee-based asset management services for clients, as well as comprehensive financial planning services. BAM is a Limited Liability Company organized in the State of Colorado. The primary owners of BAM are David Afraimi & Kristy Afraimi Advisory Services Offered The Firm provides Asset Management and Financial Planning Services through its Investment Adviser Representatives (“IARs”). for its clients, each of which is described below. IARs are generally employees of the Firm. All IARs are under the supervision of the Firm and the advisory services of the IAR are provided through the Firm. Clients collaborate with a BAM IAR to determine which services to employ to best help clients reach their financial goals. The Firm will maintain the direct contractual relationship with each client and obtain, through such agreements, the authority to engage independent third-party managers, as applicable. Asset Management Services The Firm’s principal service is fee-based investment advisory services (“Asset Management Services”). We manage investment portfolios on a discretionary basis consistent with clients’ investment objectives and guidelines. Prior to engaging BAM to provide Asset Management Services, the client is required to enter into a written agreement (titled a “Discretionary Investment Management Agreement” or “DIMA”) with the Firm setting forth the terms and conditions under which the firm shall render its services. The DIMA grants BAM discretionary authority to manage the client’s investments based on the individual needs, goals, objectives, investment time horizon, and risk tolerance of each client. The Firm will not assume any responsibility for the accuracy of information provided by the client, and we are not obligated to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. The Firm uses documents designed to ascertain client suitability which is analyzed by our IARs. Once the analysis is complete, the IAR develops an investment strategy with the prospective client that addresses specific investment criteria and allocation of the client’s assets. Asset management services include but are not limited to the development of an Investment Strategy; analysis and monitoring of Asset Allocation; Risk Tolerance evaluation; Personal Investment Policy for Model Portfolios; Asset Selection; and Regular Portfolio Monitoring. The IAR evaluates the current investments of each client, with respect to their risk tolerance levels and time horizon. We request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction when investing in model strategies. In certain circumstances, however, the clients’ accounts may be administered by the IAR on a non-discretionary basis. The Firm offers a discretionary management program that consists of models provided by various third party sub-advisory firm. BAM uses Unified Managed Accounts (“UMA”) when it is in a client’s best interest. This allows for multiple strategies to be managed and held within Investment Proposal consists of model asset allocation the same account. The recommendations based on the client's risk tolerance, time horizon, investment objectives and restrictions, tax status, and financial sophistication. The investment strategy may also include a recommendation that a percentage of the portfolio be allocated to an Indexed Annuity product consistent with the client's investment objectives. Indexed Annuities are considered insurance products and are not sold through BAM, but as indicated in Item 10, Other Financial BAM Wealth Management LLC Form ADV Part 2A 4 Industry Activities and Affiliations, certain BAM IARs are separately licensed insurance agents. The IAR does not have discretion over the purchase or sale of the insurance product. It is at the client's sole discretion to determine whether to include the Indexed Annuity product from the Investment Proposal within their investment portfolio. If the client chooses to include an Indexed Annuity product in his or her portfolio, the IAR, in his or her capacity as an insurance agent, will typically receive a sales commission directly from the insurance carrier which is separate from and in addition to the advisory fees charged by BAM. However, the assets invested in the Indexed Annuity will not be included as assets under management when determining the advisory fee charged to the client’s portfolio. The client's portfolio and its performance are monitored by the client's IAR. Clients should consider that the potential to receive additional compensation can create conflicts of interest. Please refer to Item 10, Other Financial Industry Activities and Affiliations for more information regarding these conflicts and how BAM seeks to address them. Investments managed by BAM are custodied at the brokerage firm ("Custodian") through which transactions are placed. Clients should be aware that IARs may make different recommendations with respect to the same securities and insurance products based upon each client’s suitability profile. Rebalancing of the asset allocation models will occur as necessary. Account rebalancing is accomplished by buying and selling shares of stocks, mutual funds, or exchange-traded funds to reach target allocations. Selection of Other Advisers The Firm has discretion to choose third-party investment advisers (depending on the contractual relationship, these third-party advisers may be referred to as “Sub-Advisers” or “Model Managers”) to manage all or a portion of the client's assets. Third-party advisers exercise the same degree of discretion as afforded to BAM by the client (see also Item 16). The terms of these relationships, including compensation, will be memorialized in each contract between BAM and each third-party adviser. Financial Planning Services BAM’s IARs offer comprehensive financial planning services for individuals, families, and businesses. Financial Planning services include data gathering and analysis, along with creating a financial plan with specific recommendations and implementation advice tailored to client needs. Depending on the individual client’s needs, specific areas of planning advice can include investment planning, Income Planning, Tax Planning insurance needs assessment and advice, retirement planning, cash flow management, debt consolidation, capital needs assessments, educational planning, estate planning, and business planning. The IAR may also, as requested, recommend changes to the client’s investment portfolio or plan in writing. Changes in the client’s financial condition, personal circumstances, goals, or general economic conditions may trigger changes in the plan. To the extent material changes have occurred to a client’s circumstances or goals, or to the extent a client requests a new strategy or project, thereby causing a significant change to the existing plan, the IAR will update the client’s Plan as needed. The client may contact the IAR as often as needed. Clients are also free to select any brokerage, insurance, or other product provider to purchase (or sell) the investments, insurance, or other products discussed with the IAR. All planning is based on information provided by the client. It is the client’s responsibility to be certain the Firm has current and accurate information to prepare the initial plan. It is the client’s responsibility to inform the IAR of material changes affecting the investments and planning strategies implemented. The client is under no obligation to act on the IAR’s financial planning recommendations. If the client elects to act on any of the recommendations made in a financial plan, the client is BAM Wealth Management LLC Form ADV Part 2A 5 under no obligation to effect such recommendations through BAM or through the IAR in his or her capacity as an insurance agent. Please refer to Item 10, Other Financial Industry Activities and Affiliations for more information. The Firm’s financial planning services or any products recommended within a financial plan are not necessarily at the lowest available cost. Educational Seminars/Workshops BAM provides periodic educational seminars and workshops. There is no fee for the educational seminars/workshops. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries 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 also have a fiduciary duty under the Investment Advisers Act of 1940 with respect to all client accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. Services Limited to Specific Types of Investments The Firm generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including traded REITs), equities, exchange-traded funds, options, corporate bonds, structured notes, treasury inflation protected/inflation linked bonds and non-U.S. securities, private equity, and private debt. We may use other securities as well to help diversify a portfolio when applicable. A. Client Tailored Services & Client Imposed Restrictions Specific client investment strategies and their implementation are dependent upon each client’s current financial situation (including, but not limited to income, tax levels, and risk tolerance levels). Clients may impose restrictions on investing in certain securities or types of securities in accordance with their values or beliefs. To implement such restrictions, the client must inform his or her IAR of the restrictions in writing. If, for any reason, we are unable to meet the client restrictions, the firm and/or IAR will notify the client. If the restrictions prevent the Firm from properly servicing the client account, or if the restrictions would require us to deviate from our standard suite of services, we reserve the right to end the relationship. B. Assets Under Management As of December 31, 2025, the firm has the following assets under management: BAM Wealth Management LLC Form ADV Part 2A 6 Discretionary Amounts: Non-discretionary Amounts: $197,802,163.00 $4,190,926.00 Total: $201,993,089.00 Item 5 - Fees and Compensation Fees paid to BAM are for the Firm’s Advisory Services. Our fees do not include, for example, charges the client may incur from independent third parties such as accountants and attorneys. The Firm charges fees based on the type of service to be provided. The fees charged by BAM for its Advisory Services will be documented in each client’s written agreement with the firm. In situations where our fees are deducted separately than from a third-party manager’s, it will be documented in BAM’s and/or the third-party manager’s client agreement. Although BAM believes its advisory fees are competitive, clients should be aware that lower fees for comparable services may be available from other sources. Asset Management Fees A. Fees are generally negotiable. The fee schedule will be signed in the Schedule A of the Client Discretionary Investment Management Agreement (“DIMA”). The RIA Fee includes (i) an initial analysis and periodic re-evaluation of the client’s investment objectives and needs, and discretionary allocation among portfolio managers, (ii) ongoing advisory services, including fees of portfolio managers/Sub-Advisers, and (iii) Access to the BAM Platform, including client portal, account aggregation, reporting statistics, and secure document storage vault. IARs may negotiate the fee with each BAM client for services provided, including those noted above in Item 4. Thus, fees may vary between clients and from other IARs providing similar services. The range of fees for various asset management services offered by BAM are typically between .25% - 2.25%. Fees for Asset Management Services are deducted from the client’s investment account. Any prepaid fee that is unearned is prorated and returned to the client. Clients should also be aware that absent transaction charges, total fees exceeding 2% per year are generally considered higher than those charged by other comparable services available to a client. BAM processes billing monthly in arrears, using the fair market value of the managed assets as determined on the last day of the applicable month. From time to time, the fee deducted from the client’s investment account as illustrated on the statement may differ from a manual calculation of the monthly fee based on the same account value. When calculated in arrears, BAM includes accrued interest in our billable value, but not accrued dividends; custodial statements use settlement date valuation instead of trade date valuation; the custodial statement does not include all transactions that occurred towards the end of the month such as pending trade settlements; and inflow and outflows of assets during the time period. More information about billing specifics is available on request. Clients are encouraged to closely review their custodial statements for accuracy. Clients are encouraged to obtain and carefully review the contracts and disclosure documents of the third-party manager and/or program sponsor whose services they are considering, including Part 2A of Form ADV, so they fully understand the services being provided and fees being charged. Clients are also encouraged to compare programs or similar services offered by other investment advisers. Asset management fees are withdrawn directly from the client's accounts with the client’s written authorization on a monthly basis. For asset management fees incurred on accounts held outside of BAM, the client must complete an Outside Account Billing Agreement electing to deduct fees for Outside Accounts from specified accounts managed by BAM or by direct payment such as check. Generally, asset management fees are paid in arrears; Furthermore, BAM Wealth Management LLC Form ADV Part 2A 7 fees are negotiable with each of our clients until signed and agreed to in the final fee schedule attached as Schedule A of the Client DIMA. Negotiated Rate to Client As stated within Schedule A or other fee schedule of the Client DIMA, client rates may be negotiated between the Firm and the client. The negotiated rate is billed monthly in arrears for services rendered, as negotiated with the client. Fees for partial periods are prorated based on the number of days the account was serviced during the applicable period. Clients may terminate the agreement without penalty for a refund of unearned advisory fees within five business days of signing the Client DIMA. Thereafter, clients may terminate the DIMA generally with 30 days' written notice. Termination of this Agreement will not affect (i) the validity of any action previously taken by BAM and third-party investment advisers under the agreement; (ii) the liabilities or obligations of the parties with respect to transactions initiated before termination of the agreement; or (iii) client’s obligation to pay the negotiated rate (prorated through termination). The negotiated total rate fee arrangement creates a conflict of interest when a Sub-Adviser is utilized. BAM has a financial incentive to recommend a less expensive portfolio to a client, which may not be in the client’s best interest, thereby resulting in a higher percentage of fees collected are retained by BAM. BAM mitigates this conflict of interest in part by providing mandatory investment and suitability training to our IARs on at least an annual basis. BAM also semi-annually reviews and monitors a random sample of total rate method client’s portfolio managers and their performance. For more information about our review process of client accounts, please refer to Item 13 - Review of Accounts. In addition to the asset management fee, there may be transaction, commission, administrative, servicing, and other fees charged by the Custodian. IRA accounts may be charged custodial or other service fees. If your account is invested in mutual funds or ETF’s, the fund company may assess administrative charges against your investment in that fund. These fees are not charged by BAM, but rather by the product sponsor, brokerage firm, or custodian firm. In the normal course of effecting transactions, prices for certain trades made on behalf of your account may include mark-ups, mark-downs, and spread differentials. Client Responsibility for Third-Party Fees All fees paid to BAM for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds, exchange-traded funds, variable annuities, and other investment advisers, broker/dealers and custodians retained by clients, if any. Such fees and expenses are described in each mutual funds and variable annuity’s prospectus, each third- party investment adviser’s Form ADV Part 2A, Wrap Brochure or similar disclosure statement, and by any broker/dealer or custodian retained by a client. Furthermore, clients will incur brokerage commissions and other execution costs charged by the custodian or executing broker/dealer in connection with transactions for a client’s account. Clients should further understand that all custodial fees and any other charges, fees, and commissions incurred in connection with transactions for a client’s account will be paid out of the assets in the account. Please refer to Item 12 - Brokerage Practices for additional important information about the brokerage and transactional practices of BAM. Prepayment of Fees Asset Management Fees The Firm usually bills its investment management fees monthly in arrears based upon the fair market value of the managed assets as determined on the last day of the applicable month. Fees for partial periods are prorated based on the number of days the account was serviced. Item 6 - Performance Fees BAM Wealth Management LLC Form ADV Part 2A 8 We do not charge fees based on the performance of the portfolio. Item 7 - Types of Clients The Firm mainly provide advisory services to individuals and high-net-worth individuals. BAM also has other types of clients, including corporations and other businesses, non-profits, and some 401(k)s and other employer-sponsored retirement accounts. The Firm provides advisory services to other types of clients besides these. Item 8 - Methods of Analysis, Investment Strategies, Risk of Loss Investing in securities involves a significant risk of loss, including loss of principal. Clients should be aware that there may be a loss or depreciation to the value of the client’s account, which clients should be prepared to bear. There is no assurance that a positive return will be obtained in any managed investment account program. Neither BAM nor any selected third- party investment advisers guarantee the performance of the account, promise any specific level of performance, or promise that investment decisions, strategies or overall management of the account will be successful. BAM does not represent, guarantee or imply that the services or methods of analysis employed by the firm can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. Investment decisions are subject to various market, currency, economic, political, interest rate and business risks, and will not necessarily be profitable. A. Methods of Analysis and Investment Strategies Methods of Analysis The Firm’s methods of analysis include charting analysis, fundamental analysis, technical analysis, cyclical analysis, quantitative analysis and modern portfolio theory. Charting analysis involves the use of patterns in performance charts. We use this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Technical analysis involves the analysis of past market data, primarily price and volume. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. 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, each by carefully choosing the proportions of various assets. Quantitative Analysis is a technique that uses mathematical and statistical modeling, measurement, and research to understand behavior. Quantitative analysts represent a given reality in terms of numerical value. Quantitative analysis is applied to the measurement, performance evaluation, valuation of a financial instrument, and predicting real-world events such as changes in a country's gross domestic product (GDP). Investment Strategies The Firm utilizes a blend of model portfolios and boutique individual equity investment managers. The model portfolios consist mainly of ETFs, but some mutual funds are included when justified by their alpha performance (the excess returns earned on an investment above the benchmark return) or by their managers’ knowledge and expertise within their fund BAM Wealth Management LLC Form ADV Part 2A 9 objective or asset class. The model portfolios are broken down between risk-based asset allocation models and other more specifically targeted models for income or all equity exposure. The boutique individual investment managers are utilized for individual stock selection targeting a given asset class. Asset Allocation The Firm utilizes different third-party investment managers to provide their risk-based asset allocation models. Each manager provides risk-based models ranging from conservative to aggressive. Each manager has its own philosophy and process to construct their models, but they all have the goal of targeting a specific asset allocation and risk level. Third party managers primarily utilize ETFs in their models but may use mutual funds. These managers typically rebalance quarterly; however, some of the more tactical third-party managers will make minor shifts throughout the year while still staying within a 10 - 15% range of their broad equity and fixed income target asset allocations. Income Models The Firm utilizes risk-based income generation models that primarily consist of both equity and fixed income-based ETFs but may use Mutual Funds. BAM also utilizes other firms for their fixed income expertise, including a municipal ETF portfolio. Individual Investment Managers The Firm utilizes third-party investment managers for a variety of strategies. These include individual Equity and Fixed Income portfolios in specified asset classes. The managers provide portfolios of individual securities, and the Firm executes the trades on behalf of the client, according to the portfolio delivery instructions. The managers include Large cap, Small- Mid cap, Small cap, REITs, International and ESG. Other third-party investment manager strategies include: • Tax-optimized indexed equity separately managed accounts (SMAs) from standard indexes to blended benchmarks for custom exposure. These strategies may also incorporate values aligned investing and factor tilts. • Concentrated stock hedging solutions utilizing options which may reduce the risk of the underlying position. • Unified Managed Account (UMA) program for higher net worth clients that combines SMAs from multiple third-party managers which may include stocks, bonds, and other diversifying asset classes. • Private Equity Manager for high net worth/accredited investors. • Private credit offering for eligible clients investing directly in loans made to middle- market companies. • A non-traded US Government Income REIT that investsin institutional quality real estate with leases backed by the full faith and credit of the U.S. Government. • Structured Notes B. Material Risks Involved Charting analysis strategy involves using and comparing various charts to predict long and short-term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be assuming that past performance will be indicative of future performance. This may not be the case. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. BAM Wealth Management LLC Form ADV Part 2A 10 Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not account for new emerging patterns. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two-fold: (i) the markets do not always repeat cyclical patterns; and (ii) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Modern Portfolio Theory assumes that investors are risk adverse, 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. 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 inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Cybersecurity Risk: Investment advisers and their service providers may be prone to operational and information security risks resulting from cyber-attacks. Cyber-attacks include, among other behaviors, stealing or corrupting data maintained online or digitally (including, for example, through cyber- attacks known as “phishing” and “spear-phishing”), denial-of-service attacks on websites, the unauthorized release of confidential information and causing operational disruption. Cyber-attacks may interfere with the processing of transactions, cause the release of private information or confidential information of BAM, cause reputational damage, and subject BAM to regulatory fines, penalties or financial losses, reimbursement or other compensation costs, and/or additional compliance costs. While BAM has established a business continuity plan and systems designed to prevent such cyber-attacks, there are limitations in such plans including the possibility that certain risks have not been identified. Selection of Other Advisers: Although BAM will seek to select only money managers who will invest clients' assets with the highest level of integrity, BAM's selection process cannot ensure that money managers will perform as desired, and BAM will have no control over the day-to-day operations of any of its selected money managers. BAM would not necessarily be aware of certain activities at the underlying money manager level, including without limitation a money manager's engaging in unreported risks, investment “style drift,” regulatory breaches, or fraud. C. Risks Associated with Our Investment Strategies and Models The implementation and composition of our asset management programs, including those described above, is at the discretion of BAM and thus may not be what the client would want at that specific time. BAM may elect to replace a manager which could result in a manager that is slightly different than the previous manager. BAM will keep consistent the clients’ stated risk tolerance when electing a replacement model. We may use newly listed, low-asset, or low- volume investments in our portfolios. Investment advice and models provided by BAM may not be tax efficient. BAM does not BAM Wealth Management LLC Form ADV Part 2A 11 provide legal, accounting, or tax advice. Thus, clients should obtain independent tax, legal and accounting advice before implementing any advice offered by BAM. Comparing the performance of an account managed by BAM may be difficult as it is not easy to find a comparable benchmark, and unmanaged indices such as the S&P 500 cannot be managed and therefore are not suitable comparisons, either. Thus, it may not be possible for clients to truly gauge how their portfolio is performing relative to the market when receiving BAM’s services. It may take an indeterminate amount of time to allocate the account assets to achieve the chosen asset allocation, especially for small portfolios or if only subsequent deposits are to be used to reallocate account assets. The number of securities in the portfolio will vary by the model or strategy employed. If a client desires to achieve the chosen allocation as soon as possible, or has specific prohibitions or trading criteria, the client must inform BAM of their desire in writing; BAM is not always able to accommodate such requests. Clients must be willing to accept costs of short-term trading in BAM’s option-based asset management strategies and Models. Although BAM generally recommends clients purchase ETFs and mutual funds, at times we recommend clients purchase securities that involve greater risks related to liquidity, volatility, earnings, headlines, interest rate, and potential unfavorable fluctuations in underlying asset and/or index values. For example, international investments may be subject to economic or political instability, credit risk, and exchange-rate fluctuations. Also, we may recommend a client heavily weigh their portfolio in a single asset class or even a single security. Some investments in certain funds used by BAM may be denominated in foreign currencies. Changes in the relative values of foreign currencies (including the Euro) and the dollar, therefore, will affect the value of investments in portfolios with these funds. Funds used may purchase foreign currency futures contracts and options in order to hedge against changes in the level of foreign currency exchange rates, but there can be no assurance that the client’s portfolio will not be subject to significant fluctuations in foreign currency valuations. Private investments intended for accredited investors are considered non-traded and may be illiquid. These investment vehicles typically offer quarterly redemption windows equal to a stated percentage of outstanding NAV, but these redemption windows are subject to the discretion of the investment provider and client’s many not have access to their full investment when needed. D. Risks of Specific Securities Utilized 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 or stock “equity” nature. 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. 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 most well-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 BAM Wealth Management LLC Form ADV Part 2A 12 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; however, they carry a potential risk of losing share price value. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Fund (“ETF”): An ETF is an investment fund traded on 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, etc.) specifically may be negatively impacted by several unique factors, among them (i) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (ii) a significant increase in hedging activities by producers of gold or other precious metals, (iii) a significant change in the attitude of speculators and investors. Information on a specific ETF risk and its policies regarding the above topics can be found in its prospectus and Statement of Additional Information. Clients should review the prospectus before investing. Unit Investment Trust (“UIT”): A UIT is a product where a financial company buys or holds a group of securities, such as stocks or bonds, and makes them available to investors as redeemable units. UITs raise money typically in a one-time public offering, with each unit representing ownership and a proportional right to income and capital gains generated by the fund’s investments, typically either stocks or bonds. The performance of a UIT’s underlying investments, minus fund fees, determines the trust’s investment return. UITs have a stated expiration date based on what investments are held in their portfolio; when the portfolio terminates, investors get their share of the UIT's net assets. The UIT will inherit all the risks associated with the securities in which it invests, such as credit, business, and market risk. Additionally, because UITs are not redeemable until the end of their respective terms, they are also susceptible to liquidity risk. 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; 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 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 requirements or other long-term goals. 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. We do not sell fixed or equity-indexed annuities. As described in Item 10, most of BAM’s IARs are licensed insurance agents and may recommend or include annuities as part of the client’s investment strategy. 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. Digital Assets represent an emerging asset class that has not been fully defined. There BAM Wealth Management LLC Form ADV Part 2A 13 remains an overwhelming lack of clarity regarding the regulatory framework that will ultimately govern this investing sector. Additionally, a considerable list of risk factors carries their own range of probability and impact possibilities. Those risks include but are not limited to valuation risk; liquidity risk; volatility risks; technology risk; and legal, tax, and regulatory risk. Importantly, unless a Digital Assets is traded on an exchange, they are not backed by a central bank or a national, supra-national or quasi-national organization, any hard assets, human capital, or other form of credit. Structured Notes. We offer our clients structured notes strategies. These strategies are generally designed to provide clients with an alternative risk/reward payoff compared to owning the same asset directly. The structured notes objectives are to offer capital appreciation to equity indices and varying levels of downside protection to the index. They may also be used to provide income or principal protection. Past performance is not indicative of future results. Investing in securities involves a risk that you, as a client, should be prepared to bear. Item 9 - Disciplinary Information Firms are required to report any legal or disciplinary events that are material to a client’s evaluation of our advisory business and the integrity of our management. There are no required disclosures in relation to BAM and its management team. Disclosure information specific to your investment adviser representative (if applicable) can be found on their supplemental ADV 2B or at www.adviserinfo.sec.gov. Item 10 - Other Financial Industry Activities and Affiliations IARs of BAM may also be agents of a non-affiliated insurance agency, engaging in the business of selling life, health, long-term care, disability, and annuity insurance products as well as securities. In their role as insurance agents, IARs may receive separate compensation in the form of commissions for the sale of insurance products. BAM does not provide accounting, tax, or legal advice. A. Providing Financial Services on Behalf of a Broker-Dealer The Firm is not registered as, nor does have a pending application to become a broker-dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Adviser Neither BAM nor its IARs are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Adviser or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Resulting Conflicts of Interests Certain IARs of BAM are separately licensed as life insurance agents with insurance agencies unaffiliated with the Firm. In their separate capacities as licensed insurance agents, IARs are able to implement insurance and/or annuity recommendations for advisory clients for which they will receive commission-based compensation that is separate from and in addition to advisory fees charged to the client by BAM. The determination of whether to recommend an insurance product to be included within a client’s financial portfolio is at the discretion of the IAR. Clients should be aware that the potential for the IAR to receive additional compensation BAM Wealth Management LLC Form ADV Part 2A 14 creates a conflict of interest that can impair the IAR’s objectivity when making advisory recommendations. This is because it creates an incentive to recommend that the client purchase annuities or other insurance products in order that the IAR may receive additional compensation rather than because it is in a client’s best interest. In addition, certain annuity products pay an upfront, lump sum commission. The immediacy of this compensation structure can create further incentive for the IAR to recommend certain annuity products over other products, or to recommend such products rather than recommending that these assets be included in and managed as part of the client’s Asset Management Services portfolio. Clients of BAM are not obligated to utilize the insurance services provided by their BAM IAR in his or her separate capacity as an insurance agent. The inclusion of a fixed indexed annuity is left to the discretion of the client and can be enabled as an option within the portfolio by way of a proprietary algorithm that determines an advantageous dollar amount for each individual client. The Firm’s clients are not obligated in any manner to use the selection of any insurance product allocation. D. Addressing Conflicts of Interest Related to Brokerage and Insurance Activities of IARs BAM endeavors at all times to put the interest of clients first as part of its fiduciary duty. As such, the Firm takes the following steps to address these conflicts: • BAM seeks to provide full and fair disclosure regarding the material conflicts of interest, including the potential for IARs to earn compensation from advisory clients in addition to BAM’s advisory fees; • BAM discloses to clients that they are not obligated to purchase recommended investment or insurance products from BAM’s IARs; • BAM seeks to collect, maintains and documents accurate and relevant client background information, including the client’s financial goals, objectives and risk tolerance upon which recommendations are based; • BAM requires that employees seek prior approval of any outside employment activity so that BAM may ensure that any conflicts of interests arising as a result of such activities are properly addressed and, as applicable, disclosed; and • BAM periodically monitors these outside employment activities to verify that any conflicts of interest continue to be properly addressed by BAM; See Item 5 above regarding selection of other advisers or managers and the conflicts of interest. Item 11 - Code of Ethics, Participation/Interest in Client Transactions, Personal Trading In accordance with SEC Rule 204a-1 of the Investment Advisers Act of 1940, the Firm maintains and enforces a Code of Ethics (“Code”) that includes but is not limited to oversight of Gifts and Entertainment, Anti-Bribery Policy and Procedures, Political Contributions, Reporting of Employee Holdings and Transactions, Preclearance of Trades, Outside Business Activities and Insider Trading. The Code contains requirements regarding compliance with all Laws, Rules and Regulations, and it contains provisions for reporting violations of the Code to the Firm’s CCO. All BAM employees and IARs are expected to be honest and ethical, make full and accurate disclosures, remain in compliance with all applicable rules and regulations, and be accountable for what they do. The Firm and our IARs act as fiduciaries for our clients. We have a fundamental obligation to act in the best interests of our clients and to provide investment advice in the clients’ best interest. We owe our clients a duty of undivided loyalty and utmost good faith. The Firm should not engage in any activity in conflict with the interest of any client, and we should take steps BAM Wealth Management LLC Form ADV Part 2A 15 reasonably necessary to fulfill these obligations. The Firm and its IARs employ reasonable care to avoid misleading our clients and provide full and fair disclosure of all material facts to our current, former and prospective clients. Generally, facts are “material” if a reasonable investor would consider them to be important. They must disclose and mitigate all conflicts of interest that might incline them – consciously or unconsciously – to render advice that is not disinterested. If they do not avoid a conflict of interest that could impact the impartiality of their advice, they must make full and frank disclosure of the conflict. The Firm and its IARs cannot use our clients’ assets for our own benefit or the benefit of other clients. Departure from this fiduciary standard may constitute “fraud” under the Investment Advisers Act. Investing Personal Money in the Same Securities as Clients From time to time, an IAR may buy or sell securities for themselves that they also recommend to BAM clients. This may provide an opportunity for the IAR to buy or sell the securities before or after recommending the same securities to clients. This results in an IARs profiting from the recommendations they provide to clients. Such transactions create a conflict of interest. The Firm conducts best execution, trade allocation and trade confirmation audits to ensure IARs do not engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. The Firm utilizes block trading, when possible, to mitigate this conflict. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, an IAR may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for the IAR to buy or sell securities before or after recommending securities to clients. This results in the IARs profiting from the recommendations they provide to clients. Such transactions create a conflict of interest; however, the Firm will never engage in trading that operates to the client’s disadvantage. If an IAR buys or sells securities at or around the same time as clients, the Firm utilizes block trading, when possible, to mitigate this conflict. To review a copy of the Firm’s Code of Ethics, please make a written request to Firm’s CCO, Kristy Afraimi at kafraimi@bamadvisorygroup.com Item 12 - Brokerage Practices A. Factors Used to Select Custodians and/or Broker-Dealers Custodians/broker-dealers will be recommended based on the Firm’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms under the circumstances. This means the clients will not necessarily pay the lowest commission or commission equivalent, and we 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 our research efforts. We will never charge a premium or commission on transactions beyond the actual cost imposed by the broker-dealer/custodian. The Firm requires clients use Charles Schwab & Co., Inc. investment advisor/fund manager. Reasonable Research and Other Soft-Dollar Benefits The Firm does not currently have any formal soft-dollar arrangements. The Firm and/or our IARs may be invited to conferences, summits, and other events (whether in-person or virtual) travel, meals, and hosted by an accommodation expenses may be offered by the investment advisor/fund manager to encourage attendance at these events. BAM will review in advance all expenses or BAM Wealth Management LLC Form ADV Part 2A 16 reimbursements furnished by the investment advisor/fund manager to verify that there is not an impermissible conflict of interest that would otherwise unduly influence the attendee or prospective attendee to use the services of the Investment advisor/fund manager to detriment of clients’ best interest. Brokerage for Client Referrals We receive no referrals from a broker-dealer in exchange for using that broker-dealer. Clients Directing Which Broker-Dealer/Custodian to Use We require clients to use a specific custodian to execute transactions. Not all advisers require clients to use a particular custodian. B. Aggregating (Block) Trading for Multiple Client Accounts If the Firm buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. It should be noted that there can be multiple blocks for the same securities in a day. The average and allocation may not be among all blocks in a day. Each client that participates in the aggregated block order will participate at the average share price for all Firm transactions in that security with the particular custodian on a given business day, with transaction costs shared pro rata based on each client's participation in the transaction subject to rounding for odd lots that would be deemed too small for an account ("de minimis allocations"), and other objective criteria. We would determine the appropriate number of shares and select the appropriate brokers consistent with our duty to seek best execution, except for those accounts with specific brokerage direction (if any). When the total final execution amount of a trade is materially less than an amount of the requested order, certain accounts may be removed entirely from the list of participants and the amount of the allocation can be adjusted to avoid inefficient results. Accounts that do not receive an allocation with respect to a particular security will be considered first when the next partial fill occurs. Notwithstanding the foregoing, the order may be allocated on a basis different from that specified if all client accounts receive fair and equitable treatment. We consider a client’s choice to custody its account at a specific broker-dealer as being instruction to direct transactions in that client’s account through that broker-dealer, unless the client notifies us otherwise. Potential Trading Conflicts Smaller accounts are difficult to properly diversify and thus they may not get the same benefit as larger accounts or have greater divergence of their results from the intended portfolio allocation. Due to their smaller size, they may also incur a higher percentage of pro rata transaction costs. Item 13 - Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews Client accounts managed by the Firm are reviewed by the IAR servicing the account on a periodic and ongoing basis (no less than annually) with regard to the client’s respective investment policies and risk tolerance levels. The Firm’s CCO reviews a sample of client accounts on a semi-annual basis. These reviews focus on ensuring that a selected portfolio is consistent with the client’s investment objectives, time horizon, risk tolerance, investment experience, and other determinants of client suitability. When reviewing a client account where a conflict of interest exists (e.g., accounts where the “Total Rate Method” is employed as described in Item 5), special emphasis will be placed on assessing whether the IAR has invested the client’s assets in the most appropriate portfolio(s). BAM Wealth Management LLC Form ADV Part 2A 17 In the event the Firm determines that the IAR has placed his or her interests ahead of the client’s (e.g., investing the client in a portfolio that impermissibly results in higher compensation BAM Wealth Management LLC Form ADV Part 2A 18 for the IAR), we will, at a minimum, instruct the IAR to reinvest the client’s assets in an allocation that eliminates the conflict of interest. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Non-periodic reviews performed by the IAR may be triggered by, but is not limited to, material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, liquidation of a significant portion of the portfolio, physical move, or inheritance). The client should notify the Firm or their IAR if changes occur in their personal financial situation that might adversely affect the investment plan. Routine conversations between the Firm and the IAR may also trigger a non-periodic review of a client accounts. C. Content and Frequency of Regular Reports Provided to Clients Each client of the Firm’s advisory services will receive a quarterly report detailing the client’s account, including assets held, asset value, and fees. This written report will come from the custodian. Additionally, IARs will engage in meetings with the clients, either by phone or in- person, which are held at least annually to review the account and client's financial goals. 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) As described in Item 10 – Other Financial Industry Activities and Affiliations above, Principals and IARs of the Firm may receive compensation from other non-affiliates. Such compensation shall only be received in conjunction with those services provided to such non-affiliates. Specifically the Firm may receive expense reimbursement for travel and/or marketing expenses from investment product sponsors. independently provided programs generally provide for The Firm refers some clients to certain employer-sponsored plan design and administrative firms. These the design, implementation, compliance and annual review of defined contribution and/or defined benefit plans for individuals and groups. We may provide investment advice and/or financial planning to the plan sponsor and/or plan participants. The Firm does not receive any payment for these referrals. B. Compensation to Non – Advisory Personnel for Client Referrals The Firm does not currently have any agreements in place to provide compensation to non- advisory personnel for client referrals. Item 15 – Custody It is not the Firm’s intent to take physical possession of or custody clients’ assets. However, we are deemed to have custody by virtue of two situations: 1. The Firm’s ability to deduct asset management fees directly from clients’ accounts. 2. The Firm’s authority to transfer client assets based on agreements established between some clients and the custodian. We instruct clients to maintain their assets with qualified custodians which send statements directly to clients at a minimum of a quarterly basis. We urge clients to compare the account statements from the qualified custodian to any report provided by BAM and notify us and the custodian if you believe there is any error. BAM Wealth Management LLC Form ADV Part 2A 19 The Firm does manage assets for some variable annuity accounts that are custodied with insurance companies. Item 16 - Investment Discretion The Firm and its IARs have discretion over the selection and number of securities to be bought or sold in client accounts without obtaining prior consent or approval from the client (although some clients elect a non-discretionary basis whereby the client either approves each trade prior to the IAR placing the trade, or the client executes trades on their own behalf). The granting of discretionary authority will be evidenced by the client’s execution of a Discretionary Investment Management Agreement, containing all applicable limitations to such authority. Discretionary trades executed by the Firm will be in accordance with each client’s investment objectives and goals. A client may request restrictions, limitations, or other requirements with respect to their investment accounts. The Firm can accept or deny the request, as it may impede our ability to efficiently manage the assets and provide services to the client. Any restrictions requested by the client and accepted by the Firm are documented in the DIMA which is signed by the client. The Firm may also use discretion in the methods used to effectuate trades for clients. See Item 12 – Brokerage Practices of this Brochure for more detail. A client may also elect to not have all their personal brokerage accounts, held at a Custodian, be managed by BAM but recognize the value of BAM’s centralized platform reporting abilities for Account Information. These reporting only accounts should be identified in BAM’s non- managed account agreement. BAM does not manage or provide investment recommendations and are not responsible for the investments in accounts identified as reporting only assets. If a client elects financial planning services, BAM may provide recommendations related to the assets that you identified but will not be responsible for the management and discretion of assets unless directed by the client to do so. The Firm does not advise or take any action on behalf of clients in any legal proceedings, including bankruptcies or class actions, involving securities held or formerly held in client accounts or the issuers of those securities. Item 17 - Voting Client Securities It is The Firm’s policy that we do not vote proxies for clients. Item 18 - Financial Information The Firm has no financial condition that impairs our ability to meet contractual commitments to clients. The Firm has not been the subject of a bankruptcy petition. BAM Wealth Management LLC Form ADV Part 2A 20