Overview

Assets Under Management: $274 million
Headquarters: CLEARWATER, FL
High-Net-Worth Clients: 82
Average Client Assets: $2.7 million

Frequently Asked Questions

CHRONOS WEALTH MANAGEMENT, L.L.C. charges 1.50% on the first $0 million, 1.40% on the next $0 million, 1.25% on the next $1 million, 1.15% on the next $1 million according to their SEC Form ADV filing. See complete fee breakdown ↓

Yes. As an SEC-registered investment advisor (CRD #299782), CHRONOS WEALTH MANAGEMENT, L.L.C. is subject to fiduciary duty under federal law.

CHRONOS WEALTH MANAGEMENT, L.L.C. is headquartered in CLEARWATER, FL.

CHRONOS WEALTH MANAGEMENT, L.L.C. serves 82 high-net-worth clients according to their SEC filing dated February 19, 2026. View client details ↓

According to their SEC Form ADV, CHRONOS WEALTH MANAGEMENT, L.L.C. offers financial planning, portfolio management for individuals, portfolio management for institutional clients, and selection of other advisors. View all service details ↓

CHRONOS WEALTH MANAGEMENT, L.L.C. manages $274 million in client assets according to their SEC filing dated February 19, 2026.

According to their SEC Form ADV, CHRONOS WEALTH MANAGEMENT, L.L.C. serves high-net-worth individuals and institutional clients. View client details ↓

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Investment Advisor Selection

Fee Structure

Primary Fee Schedule (ADV PART 2A-CHRONOS WEALTH MANAGEMENT, L.L.C.)

MinMaxMarginal Fee Rate
$0 $250,000 1.50%
$250,001 $400,000 1.40%
$400,001 $550,000 1.25%
$550,001 $750,000 1.15%
$750,001 $3,500,000 1.00%
$3,500,001 $5,000,000 0.85%
$5,000,001 $7,500,000 0.75%
$7,500,001 and above 0.65%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $12,525 1.25%
$5 million $50,275 1.01%
$10 million $85,275 0.85%
$50 million $345,275 0.69%
$100 million $670,275 0.67%

Clients

Number of High-Net-Worth Clients: 82
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 79.37%
Average Client Assets: $2.7 million
Total Client Accounts: 530
Discretionary Accounts: 530
Minimum Account Size: None

Regulatory Filings

CRD Number: 299782
Filing ID: 2055507
Last Filing Date: 2026-02-19 18:03:57

Form ADV Documents

Primary Brochure: ADV PART 2A-CHRONOS WEALTH MANAGEMENT, L.L.C. (2026-02-19)

View Document Text
Chronos Wealth Management, L.L.C. Firm Brochure - Form ADV Part 2A Item 1: Cover Page This brochure provides information about the qualifications and business practices of Chronos Wealth Management, L.L.C. If you have any questions about the contents of this brochure, please contact us at (727) 446- 2306 or by email at: chronos@chronoswm.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 Chronos Wealth Management, L.L.C. is also available on the SEC’s website at www.adviserinfo.sec.gov. Chronos Wealth Management, L.L.C.’s CRD number is: 299782. 1432 Court Street Clearwater, FL 33756 (727) 446-2306 chronos@chronoswm.com https://www.Chronoswm.com Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 02/19/2026 i Item 2: Material Changes On 02/19/2026, we submitted our annual updating amendment for our fiscal year ending 12/31/2025. There have been no material changes in this brochure from the previous annual updating amendment of Chronos Wealth Management, LLC on 03/18/2025. Material changes relate to Chronos Wealth Management, LLC‘s policies, practices, or conflicts of interest. ii Item 3: Table of Contents Item 1: Cover Page .............................................................................................................................................................................1 Item 2: Material Changes ..................................................................................................................................................................2 Item 3: Table of Contents ..................................................................................................................................................................3 Item 4: Advisory Business .................................................................................................................................................................4 Item 5: Fees and Compensation .......................................................................................................................................................6 Item 6: Performance-Based Fees and Side-By-Side Management ..............................................................................................7 Item 7: Types of Clients .....................................................................................................................................................................8 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ........................................................................................8 Item 9: Disciplinary Information ................................................................................................................................................... 11 Item 10: Other Financial Industry Activities and Affiliations .................................................................................................. 11 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...................................... 12 Item 12: Brokerage Practices ........................................................................................................................................................... 13 Item 13: Review of Accounts .......................................................................................................................................................... 15 Item 14: Client Referrals and Other Compensation .................................................................................................................... 15 Item 15: Custody ............................................................................................................................................................................... 16 Item 16: Investment Discretion ...................................................................................................................................................... 16 Item 17: Voting Client Securities (Proxy Voting) ........................................................................................................................ 16 Item 18: Financial Information ....................................................................................................................................................... 16 iii Item 4: Advisory Business A. Description of the Advisory Firm Chronos Wealth Management, L.L.C. (hereinafter “CWM”) is a Limited Liability Company located in the state of Florida and organized in the State of Delaware. The firm was formed in September 2017, and the principal owner is William Wallace Chamberlain. The firm's Chief Compliance Officer is Nicole Renee Chamberlain. B. Types of Advisory Services Portfolio Management Services CWM offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. CWM creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring • • • CWM evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. CWM will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. CWM seeks to provide investment decisions that are made in accordance with the fiduciary duties owed to its accounts and without consideration of CWM’s economic, investment, or other financial interests. To meet its fiduciary obligations, CWM attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, CWM’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is CWM’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; education planning; and debt/credit planning. 4 Selection of Other Advisers CWM may direct clients to third-party investment advisers. Before selecting other advisers for clients, CWM will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where CWM is recommending the adviser to clients. Services Limited to Specific Types of Investments CWM generally limits its investment advice to mutual funds, fixed income securities, insurance products, including annuities, equities, hedge funds, private equity funds, ETFs, and non-US. securities, although CWM primarily recommends U.S. domestic large-cap equities. CWM may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions CWM will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements, as well as a plan that will be executed by CWM on behalf of the client. CWM may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions on investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent CWM from properly servicing the client account, or if the restrictions would require CWM to deviate from its standard suite of services, CWM reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. CWM does not participate in wrap fee programs. E. Assets Under Management CWM has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 274,039,062.00 $0.00 12/31/2025 5 Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees $0 - $250,000 1.50% $250.001 - $400,000 1.40% $400,001 - $550,000 1.25% $550,001 - $750,000 1.15% $750,001 - $3,500,000 1.00% $3,500,001 - $5,000,000 0.85% $5,000,001 - $7,500,000 0.75% $7,500,001+ 0.65% The advisory fee is calculated using the value of the assets in the Account on the last business day of the prior billing period. These fees are generally negotiable, and the final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of CWM's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately upon written notice. Financial Planning Fees Financial planning is provided as a part of the firm’s investment advisory services and not as a stand-alone service for a fee. Selection of Other Advisers Fees CWM may direct clients to third-party investment advisers. CWM will be compensated via a fee share from the advisers to whom it directs those clients. The fees shared are negotiable and will not exceed any limit imposed by any regulatory agency. The notice of termination requirement and payment of fees for third-party investment advisers will depend on the specific third-party adviser selected. The total fee for a third-party investment will not exceed 1.0% and is non- negotiable. The advisory fee is calculated using the value of the assets in the Account on the last business day of the prior billing period. The fee breakdown is 0.60% to the manager and 0.40% to Chronos Wealth Management (0.60%+0.40%=1.0% total fee). 6 B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with the client's written authorization on a quarterly basis. Fees are paid in advance. Payment of Selection of Other Advisers' Fees Fees are paid quarterly in advance. Other Advisers' Fees are withdrawn by selected third-party managers directly from client accounts. CWM then receives its portion of the fees from selected third-party managers; CWM does not directly deduct the advisory fees. C. Client Responsibility for Third-Party Fees Clients are responsible for the payment of all third-party fees (i.e., custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by CWM. Please see Item 12 of this brochure regarding broker- dealer/custodian. D. Prepayment of Fees CWM collects fees in advance. Refunds for fees paid in advance but not yet earned will be refunded on a prorated basis and returned within twenty-one days to the client via check or return deposit back into the client’s account. For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee rate by 365.) E. Outside Compensation for the Sale of Securities to Clients Neither CWM nor its supervised persons accept any compensation for the sale of investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management CWM does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. 7 Item 7: Types of Clients CWM generally provides advisory services to the following types of clients: Individuals High-Net-Worth Individuals Pension and Profit-Sharing Plans Corporations or Business Entities ❖ ❖ ❖ ❖ There is no account minimum for any of CWM’s services. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis CWM’s methods of analysis include Charting analysis, Fundamental analysis, Quantitative analysis, and Technical analysis. Charting analysis involves the use of patterns in performance charts. CWM uses 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. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations, such as the character of management or the state of employee morale, the value of assets, the cost of capital, historical projections of sales, and so on. Technical analysis involves the analysis of past market data, primarily price and volume. Investment Strategies CWM uses long-term trading and the selection of other advisers. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 8 B. Material Risks Involved Methods of Analysis 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 cross-check data. Using charting analysis without other methods of analysis would be making the assumption 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. Quantitative analysis Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. 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 take into account new patterns that emerge over time. Investment Strategies 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. Selection of Other Advisers: Although CWM will seek to select only money managers who will invest clients' assets with the highest level of integrity, CWM's selection process cannot ensure that money managers will perform as desired, and CWM will have no control over the day-to- day operations of any of its selected money managers. CWM 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”, or even regulator breach or fraud. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 9 C. Risks of Specific Securities Utilized Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss, and thus, you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of a bond “fixed income” nature (lower risk) or a stock “equity” nature. Equity investment generally refers to buying shares of stock 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 environment. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt, and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best-known type of fixed income security. In general, the fixed income market is volatile, and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on Treasury inflation-protected/inflation-linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest, and the possibility of inadequate regulatory compliance. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirements or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. 10 Hedge funds often engage in leveraging and other speculative investment practices that may increase the risk of loss; can be highly illiquid; are not required to provide periodic pricing or valuation information to investors; May involve complex tax structures and delays in distributing important tax information; are not subject to the same regulatory requirements as mutual funds; and often charge high fees. In addition, hedge funds may invest in risky securities and engage in risky strategies. Private equity funds carry certain risks. Capital calls will be made on short notice, and the failure to meet capital calls can result in significant adverse consequences, including but not limited to a total loss of investment. 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 a lesser degree of accurate public information available. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither CWM nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. 11 B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither CWM nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, Commodity Trading Advisor, or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests From time to time, individuals associated with CWM, including owners and officers, who are independent, licensed insurance agents, may offer clients insurance advice or products to clients in need of such services or products. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. CWM always acts in the best interest of the client, including the sale of commissionable products to advisory clients. Clients are in no way required to utilize the services of any representative of CWM in connection with such individual's activities outside of CWM. William Wallace Chamberlain is a Member of Deneb Holdings Inc, LLC, which holds real estate and other assets purchased by William Wallace Chamberlain. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections CWM may direct clients to third-party investment advisers. CWM will be compensated via a fee share from the advisers to whom it directs those clients. The fees shared will not exceed any limit imposed by any regulatory agency. This creates a conflict of interest in that CWM has an incentive to direct clients to third-party investment advisers that provide CWM with a larger fee split. CWM will always act in the best interests of the client, including when determining which third- party investment adviser to recommend to clients. CWM will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where CWM is recommending the adviser to clients. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics CWM has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited 12 Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. CWM's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests CWM does not recommend that clients buy or sell any security in which a related person to CWM or CWM has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of CWM may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of CWM to buy or sell the same securities before or after recommending the same securities to clients, resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. CWM will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of CWM may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of CWM to buy or sell securities before or after recommending securities to clients, resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, CWM will never engage in trading that operates to the client’s disadvantage if representatives of CWM buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on CWM’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and CWM 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 CWM's research efforts. CWM will never 13 charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. CWM will require clients to use Raymond James & Associates, Inc., member New York Stock Exchange/SIPC, as the broker-dealer/custodian. 1. Research and Other Soft-Dollar Benefits While CWM has no formal soft dollars program in which soft dollars are used to pay for third- party services, CWM may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). CWM may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and CWM does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. CWM benefits by not having to produce or pay for the research, products, or services, and CWM will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that CWM’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals CWM receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use CWM will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. B. Aggregating (Block) Trading for Multiple Client Accounts If CWM 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. In such a case, CWM would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. CWM would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). 14 Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews CWM monitors client account holdings on a continuous basis and conducts internal reviews regularly. Accounts are reviewed by Nicole Chamberlain, Chief Compliance Officer, and/or the investment adviser representative assigned to the account. CWM recommends formal account reviews with clients at least annually. Account reviews with clients may be conducted in person or by phone. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Additional reviews may be triggered by material market, economic, or political events, or by changes in the client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client of CWM's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and the calculation of fees. This written report will come from the custodian. 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) CWM does not receive any economic benefit, directly or indirectly, from any third party for advice rendered to CWM's clients. B. Compensation to Non – Advisory Personnel for Client Referrals CWM does not directly or indirectly compensate any person who is not advisory personnel for client referrals. 15 Item 15: Custody When advisory fees are deducted directly from client accounts at the client's custodian, CWM will be deemed to have limited custody of the client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Custody is also disclosed in Form ADV because CWM has the authority to transfer money from client account(s), which constitutes a standing letter of authorization (SLOA). Accordingly, CWM will follow the safeguards specified by the SEC rather than undergo an annual audit. Item 16: Investment Discretion CWM provides discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, CWM generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, CWM’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to CWM. Item 17: Voting Client Securities (Proxy Voting) CWM will not ask for, nor accept, voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet CWM neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. 16 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients CWM does not have any financial conditions or impairments that would prevent us from meeting our contractual commitments to our clients. C. Bankruptcy Petitions in Previous Ten Years CWM has never been the subject of a bankruptcy petition. 17