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Part 2A of Form ADV: Firm Brochure
Item 1: Cover Page
February 10, 2026
Carey Wealth Management
2819 Crow Canyon Road, Suite 101
San Ramon, CA 94583
www.CareyConsultingWealthManagement.com
Firm Contact:
Jamie Carey
Chief Compliance Officer
This brochure provides information about the qualifications and business practices of Carey
Consulting Wealth Management, Inc. dba Carey Wealth Management. If you have any
questions about the contents of this brochure, please contact us by telephone at (925) 406-
4186 or email jamie@careywealthmanagement.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 Carey Wealth Management also
is available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD# 173885.
Please note that the use of the term “registered investment adviser” and description of Carey
Wealth Management and/or our associates as “registered” does not imply a certain level of
skill or training. You are encouraged to review this Brochure and Brochure Supplements for
our firm’s associates who advise you for more information on the qualifications of our firm
and our employees.
Item 2: Material Changes
Carey Wealth Management is required to make clients aware of information that has changed since
the last annual update to the Firm Brochure (“Brochure”) and that may be important to them. Clients
can then determine whether to review the brochure in its entirety or to contact us with questions
about the changes.
Since the last annual amendment filed on 02/05/2025, the following changes have been made:
• The firm no longer has a working relationship with ApwCapital, Inc.
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Item 3: Table of Contents
Item 1: Cover Page .................................................................................................................................................................. 1
Item 2: Material Changes ...................................................................................................................................................... 2
Item 3: Table of Contents ..................................................................................................................................................... 3
Item 4: Advisory Business.................................................................................................................................................... 4
Item 5: Fees & Compensation ............................................................................................................................................. 6
Item 6: Performance-Based Fees & Side-By-Side Management ........................................................................... 7
Item 7: Types of Clients & Account Requirements .................................................................................................... 7
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ................................................................... 7
Item 9: Disciplinary Information ...................................................................................................................................... 9
Item 10: Other Financial Industry Activities & Affiliations .................................................................................... 9
Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ............... 9
Item 12: Brokerage Practices ........................................................................................................................................... 10
Item 13: Review of Accounts or Financial Plans ....................................................................................................... 13
Item 14: Client Referrals & Other Compensation ..................................................................................................... 13
Item 15: Custody .................................................................................................................................................................... 14
Item 16: Investment Discretion ....................................................................................................................................... 14
Item 17: Voting Client Securities ..................................................................................................................................... 14
Item 18: Financial Information ........................................................................................................................................ 14
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Item 4: Advisory Business
We are dedicated to providing individuals and other types of clients with a wide array of investment
advisory services. Our firm is a corporation formed in the State of California in 2007. Our firm has
been in business as an investment adviser since 2015 and is wholly owned by Jamie C. Carey.
All material conflicts of interest are disclosed below regarding our firm, our representatives or our
employees, which could be reasonably expected to impair the rendering of unbiased and objective
advice. We disclose that lower fees for comparable services may be available from other sources.
Description of the Types of Advisory Services We Offer
Comprehensive Portfolio Management:
Our Comprehensive Portfolio Management service encompasses asset management as well as
providing financial consulting to clients. It is designed to assist clients in meeting their financial goals
through the use of financial investments. We conduct at least one, but sometimes more than one
meeting (in person if possible, otherwise via telephone conference) with clients in order to
understand their current financial situation, existing resources, financial goals, and tolerance for risk.
Based on what we learn, we propose an investment approach to the client. We may propose an
investment portfolio, consisting of exchange traded funds (“ETFs”), mutual funds, individual stocks
or bonds, or other securities. Upon the client’s agreement to the proposed investment plan, we work
with the client to establish or transfer investment accounts so that we can manage the client’s
portfolio. Once the relevant accounts are under our management, we review such accounts on a
regular basis and at least quarterly. We may periodically rebalance or adjust client accounts under
our management. If the client experiences any significant changes to his/her financial or personal
circumstances, the client must notify us so that we can consider such information in managing the
client’s investments.
Financial Planning & Consulting:
We provide a variety of financial planning and consulting services to individuals, families and other
clients regarding the management of their financial resources based upon an analysis of the client’s
current situation, goals, and objectives. Generally, such financial planning services will involve
preparing a financial plan or rendering a financial consultation for clients based on the client’s
financial goals and objectives. This planning or consulting may encompass one or more of the
following areas: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning,
Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study, Corporate
Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit
Evaluation, Business and Personal Financial Planning.
Our written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients. For example,
recommendations may be made that the clients begin or revise investment programs, create or revise
wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or
establish education or charitable giving programs. It should also be noted that we refer clients to an
accountant, attorney or other specialist, as necessary for non-advisory related services. For written
financial planning engagements, we provide our clients with a written summary of their financial
situation, observations, and recommendations. For financial consulting engagements, we usually do
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not provide our clients with a written summary of our observations and recommendations as the
process is less formal than our planning service. Plans or consultations are typically completed within
six (6) months of the client signing a contract with us, assuming that all the information and
documents we request from the client are provided to us promptly. Implementation of the
recommendations will be at the discretion of the client.
We disclose to our financial planning clients that a conflict of interest exists between us and our
clients. The client is under no obligation to act upon the investment adviser’s recommendation. If the
client elects to act on our recommendations, the client is under no obligation to effect the transaction
through us.
Pension Consulting:
We provide pension consulting services to employer plan sponsors on a one-time or ongoing basis.
Generally, such pension consulting services consist of assisting employer plan sponsors in
establishing, monitoring and reviewing their company's participant-directed retirement plan. As the
needs of the plan sponsor dictate, areas of advising could include: investment options, plan structure
and participant education.
All pension consulting services shall be in compliance with the applicable state law(s) regulating
pension consulting services. This applies to client accounts that are pension or other employee
benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as
amended (“ERISA”). If the client accounts are part of a Plan, and we accept appointments to provide
our services to such accounts, we acknowledge that we are a fiduciary within the meaning of Section
3(21) of ERISA (but only with respect to the provision of services described in section 1 of the
Pension Consulting Agreement).
Tailoring of Advisory Services
We offer individualized investment advice to clients utilizing our Comprehensive Portfolio
Management service. Additionally, we offer general investment advice to clients utilizing our
Financial Planning & Consulting and Pension Consulting, services.
Each client has the opportunity to place reasonable restrictions on the types of investments to be held
in the portfolio. Restrictions on investments in certain securities or types of securities may not be
possible due to the level of difficulty this would entail in managing the account. Restrictions would
be limited to our Comprehensive Portfolio Management service. We do not manage assets through
our other services.
Participation in Wrap Fee Programs
Our firm offers and sponsors a wrap fee program, as further described in Part 2A, Appendix 1 (the
“Wrap Fee Program Brochure”). Our firm does not manage wrap fee accounts in a different fashion
than non-wrap fee accounts. All accounts are managed on an individualized basis according to the
client’s investment objectives, financial goals, risk tolerance, etc. Participation in our Wrap Fee
Program requires a minimum household asset balance of $1,000,000 for new clients.
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Regulatory Assets Under Management
As of December 31, 2025, our firm manages $215,303,000 on a discretionary basis and $7,515,000
on a non-discretionary basis.
Item 5: Fees & Compensation
How We Are Compensated for Our Advisory Services
Comprehensive Portfolio Management:
The maximum annual fee to be charged for this service is 1.25%. The fee assessed client account(s)
or portfolio will be detailed in an advisory agreement to be signed by the client. Our firm’s annualized
fees are billed on a pro-rata basis quarterly in advance based on the value of your account on the last
day of the previous quarter. Adjustments will be made for deposits and withdrawals during the
quarter. Unless otherwise agreed to in writing, our advisory fees will be assessed on cash and cash
equivalents. Fees are negotiable and will be deducted from your account. As part of this process, the
client is made aware of the following:
a) Your independent custodian sends statements at least quarterly to you showing the market
values for each security included in the Assets and all disbursements in your account
including the amount of the advisory fees paid to us;
b) You provide authorization permitting us to be directly paid by these terms. We send our
invoice directly to the custodian; and
c) It is the client’s responsibility to verify the calculation of advisory fees deducted from the
account.
Financial Planning & Consulting:
We charge on an hourly or flat fee basis for financial planning and consulting services. The total
estimated fee, as well as the ultimate fee that we charge you, is based on the scope and complexity of
our engagement with you. Our hourly fee to be charged will not exceed $350. Flat fees generally range
from $1,500 to $10,000. We require a retainer of fifty-percent (50%) of the ultimate financial
planning or consulting fee with the remainder of the fee directly billed to you and due to us within
thirty (30) days of your financial plan being delivered or consultation rendered to you. In all cases,
we will not require a retainer exceeding $1,200 when services cannot be rendered within 6 (six)
months.
Pension Consulting:
Services are billed as a percentage of Plan assets under management. The total estimated fee, as well
as the ultimate fee charged, is based on the scope and complexity of our engagement with the client.
The maximum fee will not exceed 1.00% of Plan assets under management. The fee-paying
arrangements for this service will be determined on a case-by-case basis and will be detailed in the
signed Pension Consulting Agreement.
Other Types of Fees & Expenses
Non-Wrap fee Clients will incur transaction charges for trades executed in their accounts. These
transaction fees are separate from our fees and will be disclosed by the firm that the trades are
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executed through. Charles Schwab Co., Inc. (“Schwab”) does not charge transaction fees for U.S. listed
equities and exchange traded funds.
Also, clients will pay the following separately incurred expenses, which we do not receive any part
of: charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be
disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses).
Wrap fee clients will receive our Form ADV, Part 2A, Appendix 1 (the “Wrap Fee Program Brochure”).
Wrap fee clients will not incur transaction costs for trades. More information about this is disclosed
in our separate Wrap Fee Program Brochure.
Termination & Refunds
We charge our advisory fees quarterly in advance. In the event that you wish to terminate our
services, we will refund the unearned portion of our advisory fee to you. You need to contact us in
writing and state that you wish to terminate our services. Upon receipt of your letter of termination,
we will proceed to close out your account and process a pro-rata refund of unearned advisory fees.
For purposes of calculating refunds for Financial Planning and Consulting services, all work
performed by us up to the point of termination shall be calculated at our hourly fee currently in effect.
You will receive a pro-rata refund of unearned fees based on the time and effort expended by our
firm and Planner.
Item 6: Performance-Based Fees & Side-By-Side Management
We do not accept performance-based fees.
Item 7: Types of Clients & Account Requirements
We have the following types of clients:
Individuals and High Net Worth Individuals;
•
• Pension and Profit-Sharing Plans;
Our Wrap Fee Program generally requires a minimum household balance of $1,000,000 for
participation.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
We use the following methods of analysis in formulating our investment advice and/or managing
client assets:
• Cash Flow;
• Cyclical;
• Fundamental;
• Technical.
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Investment Strategies We Use
We use the following strategies in managing client accounts, provided that such strategies are
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizons, among other considerations:
Long-Term Purchases: When utilizing this strategy, we purchase securities with the idea of holding
them for a relatively long time (typically held for at least a year). A risk in a long-term purchase
strategy is that by holding the security for this length of time, we may not take advantages of short-
term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security
may decline sharply in value before we make the decision to sell. Typically we employ this sub-
strategy when we believe the securities to be well valued; and/or we want exposure to a particular
asset class over time, regardless of the current projection for this class.
Short-Term Purchases: When utilizing this strategy, we purchase securities with the idea of selling
them within a relatively short time (typically a year or less). We do this in an attempt to take
advantage of conditions that we believe will soon result in a price swing in the securities we purchase.
Trading: When utilizing this strategy, we purchase securities with the idea of selling them very
quickly (typically within 30 days or less). We do this in an attempt to take advantage of our
predictions of brief price swings.
Sector Rotation: When utilizing this strategy, we shift investment assets from one sector of the
economy to another. The strategy is used as a way to diversify portfolio holdings over a period of
time and to attempt to profit from economic cycles as they relate to different sectors of the economy.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. While the stock
market may increase and your account(s) could enjoy a gain, it is also possible that the stock market
may decrease and your account(s) could suffer a loss. It is important that you understand the risks
associated with investing in the stock market, are appropriately diversified in your investments, and
ask us any questions you may have.
Description of Material, Significant or Unusual Risks
We generally invest client’s cash balances in money market funds, FDIC Insured Certificates of
Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, we
try to achieve the highest return on our client’s cash balances through relatively low-risk
conservative investments. In most cases, at least a partial cash balance will be maintained in a money
market account so that our firm may debit advisory fees for our services related to Asset Management
and Portfolio Monitoring, as applicable.
Artificial Intelligence and Machine Learning Risk. Certain service providers utilized by the Firm to
service client accounts have artificial intelligence components. The use of artificial intelligence and
machine learning includes increased risk of data inaccuracies and security vulnerabilities. Due to the
rapid advancement of machine learning technologies, future risks related to artificial intelligence are
unpredictable. As a measure to mitigate these risks to our clients, the Firm performs periodic due
diligence of our service providers for assurance that the service providers have appropriate controls
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in place to protect our clients’ information and to limit data inaccuracies when artificial intelligence
is used by the service provider.
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to the evaluation of our advisory business
or the integrity of our management.
Item 10: Other Financial Industry Activities & Affiliations
Representatives of our firm are licensed insurance agents/brokers. They may offer products and
receive normal and customary commissions as a result of these transactions. A conflict of interest
may arise as these commissionable insurance sales may create an incentive to recommend products
based on the compensation they may earn. These conflicts are mitigated by the fact that Mr. Carey
and our firm’s representatives have a fiduciary responsibility to place the best interest of the client
first and clients are not required to purchase any products through our firm’s representatives. Clients
have the option to purchase these products through another agent/broker of their choosing.
Jamie Carey, a representative of our firm, holds a Certified Public Accountant (“CPA”) license in Ohio.
Mr. Carey’s CPA license has been converted to a non-practicing public accountant and in such a
capacity, Mr. Carey may not provide income tax preparation or accounting services and does not have
signatory authority of any client checking accounts.
Item 11: Code of Ethics, Participation or Interest in Client
Transactions & Personal Trading
An investment adviser is considered a fiduciary and our firm has a fiduciary duty to all clients. As a
fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material
facts and to act solely in the best interest of each of our clients at all times. Our fiduciary duty is
considered the core underlying principle for our Code of Ethics which also includes Insider Trading and
Personal Securities Transactions Policies and Procedures. If a client or a potential client wishes to review
our Code of Ethics in its entirety, a copy will be provided upon request.
We recognize that the personal investment transactions of members and employees of our firm demand
the application of a high Code of Ethics and require that all such transactions be carried out in a way that
does not endanger the interest of any client. At the same time, we believe that if investment goals are
similar for clients and for members and employees of our firm, it is logical and even desirable that there
be common ownership of some securities. Therefore, in order to prevent conflicts of interest, we have
in place a set of procedures (including a pre-clearing procedure) with respect to transactions effected
by our members, officers and employees for their personal accounts1. In order to monitor compliance
with our personal trading policy, we have a quarterly securities transaction reporting system for all of
our associates. Upon employment or affiliation and at least annually thereafter, all supervised persons
will sign an acknowledgement that they have read, understand, and agree to comply with our Code of
Ethics.
1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse,
his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our
associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect
beneficial interest in.
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Neither our firm nor a related person recommends to clients, or buys or sells for client accounts,
securities in which our firm or a related person has a material financial interest. Related persons of
our firm may buy or sell securities and other investments that are also recommended to clients. In
order to minimize this conflict of interest, our related persons will place client interests ahead of their
own interests and adhere to our firm’s Code of Ethics. Further, our related persons will refrain from
buying or selling the same securities prior to buying or selling for our clients in the same day. If related
persons’ accounts are included in a block trade, our related persons’ accounts will be traded in the same
manner every time.
Our firm and supervised persons must conduct business in an honest, ethical, and fair manner and avoid
all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all
clients. This disclosure is provided to give all clients a summary of our Code of Ethics.
Item 12: Brokerage Practices
Custodian & Brokers Used
Our firm does not maintain custody of client assets (although our firm may be deemed to have
custody of client assets if give the authority to withdraw assets from client accounts. See Item 15
Custody, below). Client assets must be maintained in an account at a “qualified custodian,” generally
a broker-dealer or bank. Our firm recommends that clients use the Schwab Advisor Services division
of Charles Schwab & Co. Inc. (“Schwab”), a FINRA-registered broker-dealer, member SIPC, as the
qualified custodian. Our firm is independently owned and operated, and not affiliated with Schwab.
Schwab will hold client assets in a brokerage account and buy and sell securities when instructed.
While our firm recommends that clients use Schwab as custodian/broker, clients will decide whether
to do so and open an account with Schwab by entering into an account agreement directly with them.
Our firm does not open the account. Even though the account is maintained at Schwab, our firm can
still use other brokers to execute trades, as described in the next paragraph.
How Brokers/Custodians Are Selected
Our firm seeks to recommend a custodian/broker who will hold client assets and execute
transactions on terms that are overall most advantageous when compared to other available
providers and their services. A wide range of factors are considered, including, but not limited to:
•
•
•
combination of transaction execution services along with asset custody services (generally
without a separate fee for custody)
capability to execute, clear and settle trades (buy and sell securities for client accounts)
capabilities to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
• breadth of investment products made available (stocks, bonds, mutual funds, exchange
traded funds (ETFs), etc.)
• availability of investment research and tools that assist in making investment decisions
•
quality of services
competitiveness of the price of those services (commission rates, margin interest rates, other
fees, etc.) and willingness to negotiate them
reputation, financial strength and stability of the provider
•
• prior service to our firm and our other clients
• availability of other products and services that benefit our firm, as discussed below (see
“Products & Services Available from Schwab”)
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Custody & Brokerage Costs
Schwab generally does not charge a separate for custody services, but is compensated by charging
commissions or other fees to clients on trades that are executed or that settle into the Schwab
account. In addition to commissions, Schwab charges a flat dollar amount as a “prime broker” or
“trade away” fee for each trade that our firm has executed by a different broker-dealer but where the
securities bought or the funds from the securities sold are deposited (settled) into a Schwab account.
These fees are in addition to the commissions or other compensation paid to the executing broker-
dealer. Because of this, in order to minimize client trading costs, our firm has Schwab execute most
trades for the accounts.
Products & Services Available from Schwab
Schwab Advisor Services is Schwab’s business serving independent investment advisory firms like
our firm. They provide our firm and clients with access to its institutional brokerage – trading,
custody, reporting and related services – many of which are not typically available to Schwab retail
customers. Schwab also makes available various support services. Some of those services help
manage or administer our client accounts while others help manage and grow our business. Schwab’s
support services are generally available on an unsolicited basis (our firm does not have to request
them) and at no charge to our firm. The availability of Schwab’s products and services is not based
on the provision of particular investment advice, such as purchasing particular securities for clients.
Here is a more detailed description of Schwab’s support services:
Services that Benefit Clients
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 our firm might not otherwise have access or that would
require a significantly higher minimum initial investment by firm clients. Schwab’s services
described in this paragraph generally benefit clients and their accounts.
Services that May Not Directly Benefit Clients
Schwab also makes available other products and services that benefit our firm but may not directly
benefit clients or their accounts. These products and services assist in managing and administering
our client accounts. They include investment research, both Schwab’s and that of third parties. This
research may be used to service all or some substantial number of client accounts, including accounts
not maintained at Schwab. In addition to investment research, Schwab also makes available software
and other technology that:
• provides access to client account data (such as duplicate trade confirmations and account
statements);
facilitates trade execution and allocate aggregated trade orders for multiple client accounts;
facilitates payment of our fees from our clients’ accounts; and
•
• provides pricing and other market data;
•
• assists with back-office functions, recordkeeping and client reporting.
Services that Generally Benefit Only Our Firm
Schwab also offers other services intended to help manage and further develop our business
enterprise. These services include:
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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, Schwab will arrange for third-party
vendors to provide the services to our firm. Schwab may also discount or waive fees for some of these
services or pay all or a part of a third party’s fees. Schwab may also provide our firm with other
benefits, such as occasional business entertainment for our personnel.
Irrespective of direct or indirect benefits to our client through Schwab, our firm strives to enhance
the client experience, help clients reach their goals and put client interests before that of our firm or
associated persons.
Our Interest in Schwab’s Services.
The availability of these services from Schwab benefits our firm because our firm does not have to
produce or purchase them. Our firm does not have to pay for these services, and they are not
contingent upon committing any specific amount of business to Schwab in trading commissions or
assets in custody.
In light of our arrangements with Schwab, a conflict of interest exists as our firm may have incentive
to require that clients maintain their accounts with Schwab based on our interest in receiving
Schwab’s services that benefit our firm rather than based on client interest in receiving the best value
in custody services and the most favorable execution of transactions. As part of our fiduciary duty to
our clients, our firm will endeavor at all times to put the interests of our clients first. Clients should
be aware, however, that the receipt of economic benefits by our firm or our related persons creates
a potential conflict of interest and may indirectly influence our firm’s choice of Schwab as a custodial
recommendation. Our firm examined this potential conflict of interest when our firm chose to
recommend Schwab and have determined that the recommendation is in the best interest of our firm’s
clients and satisfies our fiduciary obligations, including our duty to seek best execution.
In seeking best execution, the determinative factor is not the lowest possible cost, but whether the
transaction represents the best qualitative execution, taking into consideration the full range of a
broker-dealer’s services, including the value of research provided, execution capability, commission
rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients,
our firm may not necessarily obtain the lowest possible commission rates for specific client account
transactions. Our firm believes that the selection of Schwab as a custodian and broker is the best
interest of our clients. It is primarily supported by the scope, quality and price of Schwab’s services,
and not Schwab’s services that only benefit our firm.
Special Considerations for ERISA Clients:
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account
through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such
direction is permitted provided that the goods and services provided are reasonable expenses of the
plan incurred in the ordinary course of its business for which it otherwise would be obligated and
empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services
purchased are not for the exclusive benefit of the plan. Consequently, we will request that plan
sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will
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be for the exclusive benefit of the plan.
Aggregation of Purchase or Sale
We perform investment management services for various clients. There are occasions on which
portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same
security for numerous accounts served by our firm, which involve accounts with similar investment
objectives. Although such concurrent authorizations potentially could be either advantageous or
disadvantageous to any one or more particular accounts, they are affected only when we believe that to
do so will be in the best interest of the effected accounts. When such concurrent authorizations occur,
the objective is to allocate the executions in a manner which is deemed equitable to the accounts
involved. In any given situation, we attempt to allocate trade executions in the most equitable manner
possible, taking into consideration client objectives, current asset allocation and availability of funds
using price averaging, proration and consistently non-arbitrary methods of allocation.
Item 13: Review of Accounts or Financial Plans
We review accounts on at least a quarterly basis for our clients subscribing to our Comprehensive
Portfolio Management service. The nature of these reviews is to learn whether clients’ accounts are
in line with their investment objectives, appropriately positioned based on market conditions, and
investment policies, if applicable. We do not provide written reports to clients unless asked to do so.
Verbal reports to clients take place on at least an annual basis when we contact clients who subscribe
to our Comprehensive Portfolio Management service.
Only our Chief Compliance Officer, Jamie Carey, will conduct reviews. We may review client accounts
more frequently than described above. Among the factors which may trigger an off-cycle review are
major market or economic events, the client’s life events, requests by the client, etc.
Pension Consulting clients receive reviews of their pension plans for the duration of the pension
consulting service. We also provide ongoing services to Pension Consulting clients where we meet
with such clients upon their request to discuss updates to their plans, changes in their circumstances,
etc. Pension Consulting clients do not receive written or verbal updated reports regarding their
pension plans unless they choose to contract with us for ongoing Pension Consulting services.
Financial Planning clients do not receive reviews of their written plans unless they take action to
schedule a financial consultation with us. We do not provide ongoing services to financial planning
clients, but are willing to meet with such clients upon their request to discuss updates to their plans,
changes in their circumstances, etc. Financial Planning clients do not receive written or verbal
updated reports regarding their financial plans unless they separately contract with us for a post-
financial plan meeting or update to their initial written financial plan.
Item 14: Client Referrals & Other Compensation
Our firm receives economic benefit from Schwab in the form of the support products and services
made available to our firm and other independent investment advisors that have their clients
maintain accounts at Schwab. These products and services, how they benefit our firm, and the related
conflicts of interest are described above (see Item 12 – Brokerage Practices). The availability of
Schwab’s products and services is not based on our firm giving particular investment advice, such as
buying particular securities for our clients.
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Referral Fees
In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not provide
cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or
endorsements (which include client referrals).
Item 15: Custody
Our firm has custody of client funds or securities, as CWM has the ability to deduct advisory fees
directly from the client custodial accounts. All of our clients receive account statements directly from
their qualified custodian(s) at least quarterly upon opening of an account. If our firm decides to send
its own account statements to clients, such statements will include a legend that recommends the
client compare the account statements received from the qualified custodian with those received
from our firm. Clients are encouraged to raise any questions with us about the custody, safety or
security of their assets and our custodial recommendations.
Standing Letters of Authorization
Some clients may execute limited powers of attorney or other standing letters of authorization that
permit the firm to transfer money from their account with the client’s independent qualified
Custodian to third-parties. This authorization to direct the Custodian may be deemed to cause our
firm to exercise limited custody over your funds or securities and for regulatory reporting
purposes, we are required to keep track of the number of clients and accounts for which we may
have this ability. We do not have physical custody of any of your funds and/or securities. Your
funds and securities will be held with a bank, broker-dealer, or other independent, qualified
custodian. You will receive account statements from the independent, qualified custodian(s)
holding your funds and securities at least quarterly. The account statements from your custodian(s)
will indicate any transfers that may have taken place within your account(s) each billing period.
You should carefully review account statements for accuracy.
Item 16: Investment Discretion
Clients have the option of providing our firm with investment discretion on their behalf, pursuant to
an executed investment advisory client agreement. By granting investment discretion, we are
authorized to execute securities transactions, which securities are bought and sold, and the total
amount to be bought and sold. Limitations may be imposed by the client in the form of specific
constraints on any of these areas of discretion with our firm’s written acknowledgement.
Item 17: Voting Client Securities
We do not accept proxy authority to vote client securities. Clients will receive proxies or other
solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our
firm, we will forward them on to you and ask the party who sent them to mail them directly to you in
the future. Clients may call, write or email us to discuss questions they may have about particular
proxy votes or other solicitations.
Item 18: Financial Information
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Carey Wealth Management
We are not required to provide financial information in this Brochure because we do not require the
prepayment of more than $1,200 in fees and six or more months in advance, we do not take custody
of client funds or securities and we do not have a financial condition or commitment that impairs our
ability to meet contractual and fiduciary obligations to clients.
Our firm has never been the subject of a bankruptcy proceeding.
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Carey Wealth Management