CITRIN COOPERMAN WEALTH MANAGEMENT, LLC

Item 1 – Cover Page Firm Brochure (Part 2A of Form ADV) CITRIN COOPERMAN WEALTH MANAGEMENT, LLC 50 ROCKEFELLER CENTER, NEW YORK, NY 10020 Tel: (212) 697-1000 Fax: (347)-226-7591 November 30, 2025 This brochure provides information about the qualifications and business practices of Citrin Cooperman Wealth Management, LLC (“CCWM” or the “Firm”). If you have any questions about the contents of this brochure, please contact Michael Dooley at: (646) 979-6081, or by email at: mdooley@ccwmlp.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”), or by any state securities authority. Additional information about CCWM is also available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with the Firm who are registered or are required to be registered as investment adviser representatives.  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure Item 2 - Material Changes There have been no material changes to this Form ADV Part 2A Brochure since the last annual updating amendment on March 29, 2024. We will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. Currently, our Brochure may be requested by contacting Michael Dooley, Chief Compliance Officer (“CCO”) at (646) 979-6081or mdooley@ccwmlp.com, or by calling the Firm at the main number: 212-697-1000. Additional information about CCWM is also available via the SEC’s website www.adviserinfo.gov. The SEC’s website also provides information about any persons affiliated with the Firm who are registered or required to be registered as investment advisor representatives. 2  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure 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 ................................................................................................................................... 10 Item 6 - Performance-Based Fees and Side-by-Side Management ........................................................................... 13 Item 7 - Types of Clients ................................................................................................................................................. 13 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss .................................................................. 13 Item 9 - Disciplinary Information .................................................................................................................................. 19 Item 10 - Other Financial Industry Activities and Affiliations .................................................................................. 19 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..................... 19 Item 12 - Brokerage Practices ......................................................................................................................................... 21 Item 13 - Review of Accounts ........................................................................................................................................ 25 Item 14- Client Referrals and Other Compensation ................................................................................................... 26 Item 15 - Custody ............................................................................................................................................................. 26 Item 16 - Investment Discretion .................................................................................................................................... 28 Item 17 - Voting Client Securities .................................................................................................................................. 28 Item 18 - Financial Information ..................................................................................................................................... 29 3  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure Item 4 - Advisory Business CCWM is an SEC registered investment adviser with its principal place of business located in New York, NY, USA. The Firm was originally founded in 1997 as YMSR Advisors, Inc. On May 1, 2008 YMSR Advisors, Inc. merged into Citrin Cooperman Wealth Management, LP. In October 2021, Citrin Cooperman Wealth Management, LP redomesticated from Pennsylvania to Delaware and converted its form of entity from a limited partnership to a limited liability company. Principal Owners CCWM is 100% owned by Citrin Cooperman Advisors, LLC. That entity is principally owned indirectly by Blackstone Inc., CDPQ, GIC, and their respective subsidiaries and/or affiliates. Regulatory Assets Under Management As of December 31, 2024, CCWM managed $177,428,927 in assets on a discretionary basis and $1,448,681,943 on a non-discretionary basis. Types of Services I. Investment Management Services CCWM offers investment management services on a discretionary and/or non-discretionary basis to each of its clients, including both individuals and institutions (details on the types of clients CCWM serves are in Item 7-Types of Clients). CCWM will assist a client in determining their financial needs, goals, and objectives to develop their comprehensive financial plan and implement an investment strategy. The investment strategy will be consistent with a client’s goals, objectives, time horizon, risk tolerance, and targeted rate of return which are documented in an Investment Policy Statement (“IPS”) and reviewed periodically. CCWM will then implement the investment strategy by allocating portfolio assets into the appropriate mutual funds, ETFs, individual securities, separately managed accounts, private investments (including, but not limited to hedge funds, private equity funds, venture capital funds, and direct investments), and/or investment managers within each asset class to attain their predetermined targets. Clients are advised to promptly notify CCWM if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon CCWM’s management services so that we can consider such information in managing the client’s investments. Clients may impose reasonable restrictions or mandates on the management of their account if, in CCWM’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. As referenced above, CCWM offers to manage clients’ investment portfolios on a discretionary or non-discretionary basis, described as follows: 4  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure a. Discretionary. CCWM has the discretionary authority to manage client accounts by determining the amount and type of investments to be bought and sold and managers to be hired and terminated without receiving client confirmation for each transaction. In all cases, CCWM exercises this discretion in a manner consistent with the stated investment objectives for the particular client account. The Investment Committee (the “Investment Committee”), as defined below, determines the investment products and strategies for CCWM. Depending on the Investment Committee recommendation, CCWM will adopt an implementation plan that considers the goals of the Investment Committee decision, fairness to all clients, and practical issues (such as short-term redemption fees and tax liabilities). The Investment Committee is responsible for considering how and when to implement the investment product and strategy for each client and considers these factors, among others, when making those decisions: investment objective, policies, and strategy of the account; appropriateness of the investment to the account’s time horizon and risk objectives; existing levels of ownership of the investment and other similar investments; immediate availability of cash or buying power to fund the investment; and complexity of client portfolio (including whether the portfolio holds private investment vehicles or more liquid securities). As a result of customizing client portfolios based on the above considerations, the time frame for implementing the investment product and/or strategy selection may vary client by client which may result in different clients receiving favorable or disadvantageous execution. CCWM will monitor the implementation plan to ensure all investment decisions are implemented fairly and in accordance with the goals and objectives of the Investment Committee. b. Non-Discretionary. CCWM may not make investment decisions, including buying or selling securities, for the client without prior consultation with, and the consent of, the client. Clients understand that they may forego a particular transaction if CCWM cannot obtain that consent. In addition, certain clients, such as institutional clients, may only make investment decisions with the approval of oversight groups, such as Board of Directors, Board of Trustees, or investment committees. As such, depending on when these oversight groups have scheduled meetings and CCWM has access to such oversight boards, CCWM may not have an opportunity to make recommendations within the timeframe of the implementation plan. CCWM will make investment recommendations as soon as practicable, and may, if deemed necessary, request access to the oversight committee in between scheduled meetings. If such access is not available, however, CCWM may not be able to make recommendations and get consent in accordance with implementation plans available to other clients. Non-discretionary investment management services can negatively impact client accounts if CCWM is unable to contact clients during sudden negative market conditions. With respect to its non-discretionary asset management services, CCWM generally maintains ongoing responsibility to make recommendations, based upon the needs of the client, as to the specific investment products the account may purchase or sell. The final decision on investment product and strategy selection rests with the client in this arrangement and the client always maintains asset control. CCWM may place trades for clients under a limited power of attorney, as may be provided by the client. Certain of the alternative investments recommended by the Firm, which may include debt, equity, and/or pooled investment vehicles, exist in the form of private placement securities. As such, CCWM limits such recommendations to those clients which are deemed to be “accredited investors,” or “institutional investors” as defined under Rule 501 of the Securities Act of 1933. Prior to engaging CCWM to provide investment management services, the client is required to enter into a written investment management agreement with CCWM setting forth the terms and conditions of the engagement (the “Investment Management Agreement”). 5  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure A client may terminate CCWM’s Investment Management Agreement at any time by notifying CCWM in writing and paying the rate for the time spent on the engagement prior to notification of termination. If the client made an advance payment, CCWM’s fee shall be prorated through the date of termination. CCWM may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, CCWM’s fee shall be prorated through the date of termination. Neither CCWM nor the client may assign an Investment Management Agreement without the prior consent of the other party. Transactions that do not result in a change of actual control or management of CCWM shall not be considered an assignment. A copy of the written disclosure statement for CCWM, as set forth on Part 2A and 2B of Form ADV, shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Management Agreement. The client is under no obligation to act upon any of the recommendations made by CCWM under an Investment Management Agreement The client retains absolute discretion over all such implementation decisions in such instance and is free to accept or reject any of CCWM’s recommendations. Independent Managers CCWM generally recommends that most non-discretionary investment management clients and only those discretionary investment management clients deemed appropriate, allocate investment assets among certain third-party money managers / investment programs (collectively, the “Independent Managers”) and private investment funds. CCWM’s trading activities are therefore extremely limited. The vast majority of account transactions are executed by Independent Managers and private investment fund managers that maintain day-to-day discretionary authority for the management of the allocated assets. Based upon these and other factors, there may be extended periods when CCWM determines that upon review, trades within a client’s portfolio are not prudent. Clients nonetheless remain subject to the fees described in Item 5 during periods of portfolio trading inactivity. When recommending an Independent Manager for a client, CCWM considers the client’s stated investment objectives as well as the Independent Manager’s reputation, performance, management style, investment strategies, past performance, and disclosures and/or research materials. CCWM will continue to provide ongoing monitoring and review of account performance and asset allocation as compared to account and overall portfolio investment objectives. The investment management fee charged by the Independent Manager is separate from, and in addition to, CCWM’s advisory fee. In addition to CCWM’s written disclosure brochure, the client also receives the written disclosure brochure of the designated Independent Managers. Certain Independent Managers may impose more restrictive account requirements and varying billing practices than CCWM. In such instances, CCWM may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers, all of which would be described in the client’s IMA. A client may also choose to implement CCWM’s recommendations through CCWM. In the event the client decides to implement investment recommendations through CCWM on a fee basis, CCWM 6  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure shall charge an annual investment management fee based upon a percentage of the market value of the assets being managed by CCWM. The investment management fee charged shall vary (generally between 0.25% and 1.50%) depending upon the market value of assets under management and the specific type of discretionary or non-discretionary investment management services to be rendered. The terms and conditions under which the client shall engage the Independent Managers shall be set forth in separate written agreements between the client, CCWM and the designated Independent Managers. CCWM shall continue to render non-discretionary investment management services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives, for which CCWM shall receive an annual advisory fee which, either fixed, hourly, or based upon a percentage of the market value of the assets being managed by the designated Independent Managers. The investment management fees charged by the designated Independent Managers are exclusive of, and in addition to, CCWM’s ongoing investment management fee. II. Financial Planning Services CCWM may provide its clients with a broad range of comprehensive financial planning and consulting services, addressing a multitude of investment and non-investment related matters which may include, but is not limited to, the following: • Asset protection strategies • Charitable giving • Philanthropic planning • Education funding • Insurance coverage • Risk management • Retirement planning • Tax strategies • Estate planning • Succession planning We will work with the client to gather financial, personal, and other relevant information and understand their goals, objectives, time horizon, risk tolerance, and targeted rate of return to develop a personalized plan specific to their particular situation. Our financial planning services may include a comprehensive review of the client’s entire financial situation or be focused on a particular area of need, such as the liquidation of a specific asset. Planning services are based on each client’s personal and financial situation disclosed by the client at that time. Clients are advised that certain financial assumptions about their situation may be made including but not limited to interest rates, inflation rates, expected rates of return on investments, and individual health and longevity. We will make every attempt to identify potential problem areas and factors that can significantly impact the plan when advising our clients and help them plan accordingly. However, we cannot offer any guarantees or promises that a client’s financial goals or objectives will be achieved as past performance is in no way an indication of future performance. We are available for future or recurring monitoring and updates for an additional fee. 7  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure Implementation of our planning recommendations is entirely at the client’s discretion. We are available to implement plan recommendations through our investment management services. In addition, clients may need the services of other professionals such as attorneys, insurance professionals and accountants, whose fees are not included in the CCWM Investment Planning Services fee. Prior to engaging CCWM to provide financial planning and/or consulting services, the client will be required to enter into an agreement with CCWM (the “Financial Planning Agreement”), setting forth the terms and conditions of the engagement, describing the scope of the services to be provided. A client may terminate CCWM’s Financial Planning Agreement at any time by notifying CCWM in writing and paying the rate for the time spent on the engagement prior to notification of termination. If the client made an advance payment, CCWM’s fee shall be prorated through the date of termination. CCWM may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, CCWM’s fee shall be prorated through the date of termination. Neither CCWM nor the client may assign a Financial Planning Agreement without the prior consent of the other party. Transactions that do not result in a change of actual control or management of CCWM shall not be considered an assignment. A copy of the written disclosure statement for CCWM, as set forth on Part 2A and 2B of Form ADV, shall be provided to each client prior to, or contemporaneously with, the execution of the Financial Planning Agreement. The client is under no obligation to act upon any of the recommendations made by CCWM under a Financial Planning Agreement. The client retains absolute discretion over all such implementation decisions in such instance and is free to accept or reject any of CCWM’s recommendations. III. Financial Consulting Services CCWM also provides consolidated investment reporting services, which amalgamates client accounts from various custodians, including alternatives to show overall performance allocation and other pertinent metrics utilizing the firm’s technology. Prior to engaging CCWM to provide consolidated reporting services, the client will be required to enter into an agreement with CCWM (the “Financial Consulting Agreement”), setting forth the terms and conditions of the engagement, describing the scope of the services to be provided. A client may terminate CCWM’s Financial Consulting Agreement, at any time by notifying CCWM in writing and paying the rate for the time spent on the engagement prior to notification of termination. If the client made an advance payment, CCWM’s fee shall be prorated through the date of termination. CCWM may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, CCWM’s fee shall be prorated through the date of termination. Neither CCWM nor the client may assign a Financial Consulting Agreement without the prior consent of the other party. Transactions that do not result in a change of actual control or management of CCWM shall not be considered an assignment. 8  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure A copy of the written disclosure statement for CCWM, as set forth on Part 2A and 2B of Form ADV, shall be provided to each client prior to, or contemporaneously with, the execution of the Financial Consulting Agreement. The client is under no obligation to act upon any of the recommendations made by CCWM under a Financial Consulting Agreement. The client retains absolute discretion over all such implementation decisions in such instance and is free to accept or reject any of CCWM’s recommendations. Miscellaneous ERISA / IRC Fiduciary Acknowledgment. When CCWM provides investment advice to a client about the client’s retirement plan account or individual retirement account, it does so as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Because the way CCWM makes money creates some conflicts with client interests, CCWM operates under a special rule that requires it to act in the client’s best interest and not put its interests ahead of the client’s. Under this special rule’s provisions, CCWM must: meet a professional standard of care when making investment recommendations (give prudent advice); never put its financial interests ahead of the client’s when making recommendations (give loyal advice); avoid misleading statements about conflicts of interest, fees, and investments; follow policies and procedures designed to ensure that CCWM gives advice that is in the client’s best interest; charge no more than is reasonable for CCWM’s services; and give the client basic information about conflicts of interest. Retirement Plan Rollovers – No Obligation / Conflict of Interest. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If CCWM recommends that a client roll over their retirement plan assets into an account to be managed by CCWM, such a recommendation presents a conflict of interest if CCWM will earn a new (or increase its current) advisory fee as a result of the rollover. Clients are not obligated to roll over retirement plan assets to an account managed by CCWM. Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. Except for stand-alone financial planning engagements, CCWM will provide general financial planning and related consulting services under its advisory fee set forth at Item 5 below. CCWM strongly recommends that clients address financial planning and related issues with CCWM on an ongoing basis, especially because CCWM’s fee will remain as set forth in Item 5 below regardless of whether the client engages CCWM in that capacity. Unless specifically agreed in writing, neither CCWM nor its representatives are responsible to implement any financial plans or financial planning advice, provide ongoing financial planning services, or provide ongoing monitoring of financial plans or financial planning advice. Clients are solely responsible to revisit the financial plan or financial planning advice with CCWM, if desired. CCWM’s financial planning and consulting services are completed upon communicating its recommendations to the client, upon delivery of the written financial plan, or upon termination of the applicable agreement. CCWM does not serve as an attorney, accountant, or insurance agent, and no portion of our services should be construed as same. 9  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure Accordingly, CCWM does not prepare legal documents, prepare tax returns, or sell insurance products. To the extent requested by a client, CCWM may recommend the services of other professionals for non-investment implementation purpose (i.e., attorneys, accountants, insurance, etc.), including CCWM’s affiliated CPA firm, which presents a conflict of interest. Clients are not obligated to engage the services of any recommended professionals who are responsible for the quality and competency of the services they provide. Client Obligations. When performing its services, CCWM is not required to verify any information received from the client or from the client’s designated professionals and is expressly authorized to rely on that information. Clients are responsible to promptly notify CCWM if there is ever any change in their financial situation or investment objectives for the purpose of reviewing or amending CCWM’s services or previous recommendations. Item 5 - Fees and Compensation CCWM charges for its services on a fully disclosed basis per the terms and conditions of an Investment Management Agreement, Financial Planning Agreement, or Financial Consulting Agreement, in one of the following manners: Investment Management Agreement Fixed Annual Fee. In such fee arrangements, CCWM will consider various objective and subjective factors including but not limited to, the amount of assets to be managed, the scope and complexity of the engagement, anticipated meetings, and consulting services to be rendered. This annual fee is payable in either four equal quarterly installments or twelve equal monthly installments, in arrears or in advance. Each year the annual fee is reviewed, and if adjusted, such adjustment is confirmed, in writing. The terms of the engagement shall be confirmed in an Investment Management Agreement between CCWM and the client. The majority of CCWM’s legacy clients engage CCWM on a fixed annual fee basis. Assets Under Management. In such fee arrangements, the client pays CCWM a fee based upon a percentage of the assets under CCWM’s management (i.e. individual securities, mutual funds, exchange traded funds, Independent Managers, alternative investments, etc.) per the following fee schedule: Discretionary First $1 million – 150 basis points Next $2 million – 125 basis points Next $2 million – 100 basis points Next $5 million – 85 basis points Over $10 million - 75 basis points Non-Discretionary Traditional Fixed Income (Treasury, Sovereign, Agency, Municipal, and IG Corporate Bonds) All amounts - 25 basis points 10  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure All Non-Traditional Fixed Income Assets Excluded from Above First $10 million – 75 basis points Next $15 million – 50 basis points Next $25 million – 40 basis points 30 basis points Thereafter – The AUM fee, described in each client’s Investment Management Agreement, is payable either: 1. on a quarterly basis, in arrears, adjusted for cash flow, based upon the market value (including accrued earnings) of the accounts on the last day of the previous quarter; or 2. on a quarterly basis, in advance. No increase in the annual fee percentage is effective without prior written notification to the client. The values used to calculate investment management fees based on the market value of client assets may differ from the values shown on the applicable client’s custodial statement due to various account activities such as unsettled trades. accrued interest, and accrued dividends, which may not be reflected on that client’s custodial statement as of the valuation date. The terms of the engagement shall be confirmed in an Investment Management Agreement between CCWM and the client. Although CCWM will allocate client assets consistent with the client’s designated investment objective, the fact that CCWM earns a higher fee for management of securities other than traditional fixed income for non-discretionary clients as referenced in the above fee schedule, CCWM has a conflict of interest since it will present an economic incentive to allocate more assets to those types of securities from which it will earn a higher advisory fee. Cash Positions. Unless CCWM expressly agrees to the contrary, account assets consisting of cash and cash equivalent positions are included in the value of an account’s assets for purposes of calculating CCWM’s advisory fee. Alternative Investment / Private Fund Valuation. Interests of private investment partnerships, separate accounts, or other private investment structures will generally be valued at the most recent net asset value supplied by the investment manager to the respective investment vehicle. However, for valuation and client billing purposes, that amount may be adjusted to the client’s favor to account for capital calls, management fees, distributions, or partnership expenses. As result of the valuation process, the current value of a client’s private investment holding could be significantly more or less than the value reflected in the report. Unless otherwise agreed upon, the client’s advisory fee shall be based upon the value reflected in the report. Investment management fees are negotiable and may be partially or completely waived at CCWM’s discretion. Our ability to negotiate the fee may result in some clients paying more for the same investment management services than other clients receiving the same services. Financial Planning Agreement We offer financial planning services on both a fixed fee and hourly fee basis. Fees are negotiable based upon the complexity of the services requested. The fees charged will be detailed in the client’s signed Financial Planning Agreement. 11  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure Fixed Fees. CCWM’s planning services generally range between $2,000 and $25,000. The fixed fee charge is based on a number of factors, including the scope, nature, and complexity of the services, in addition to the assets involved. The fixed fee will be governed by the Financial Planning Agreement with the client. Fixed fees are payable upon presentation of an invoice which will be generated upon completion and delivery of the financial plan. Hourly Fees. Hourly fees range from $450 to $1,000 per hour and are based on the complexity of the work and the experience and training of the Firm’s personnel involved. The hourly fee is determined on a case-by-case basis, and the amount of such fees will be governed by the Financial Planning Agreement with the client. Hourly fees are payable upon presentation of an invoice which may be generated based on progress or upon completion and delivery of the financial plan. Clients are advised that fees for financial planning are strictly for financial planning services and do not include other investment advice products or other services referenced in the financial plan. Therefore, clients may pay additional fees or commissions for products or services such as asset management, legal counsel, accounting advice, and/or insurance to execute their financial plan. Financial planning fees are negotiable and may be partially or completely waived at our discretion. CCWM’s ability to negotiate the fee may result in some clients paying more for the same financial planning services than other clients receiving the same services. Financial Consulting Agreement We offer financial consulting services on both a fixed fee and hourly fee basis. Financial consulting services currently refer to consolidated investment reporting, which amalgamates client accounts from various custodians, including alternatives to show overall performance allocation and other pertinent metrics utilizing the Firm’s technology. Fees are negotiable based upon the complexity of the services requested. The fees charged will be detailed in the client’s signed Financial Consulting Agreement. Fixed Fees. CCWM’s consulting services vary based on the number of accounts subject to the account quantity, account complexity, and data sources, but typically range between $1,000 and $5,000 per month. The fixed fee will be governed by the Financial Consulting Agreement with the client. Fixed fees are payable upon presentation of an invoice, which are generated monthly in arrears. Hourly Fees. Hourly fees range from $450 to $1,000 per hour and are based on the complexity of the work and the experience and training of the Firm’s personnel involved. The hourly fee is determined on a case-by-case basis and the amount of such fees will be governed by the Financial Consulting Agreement with the client. Hourly fees are payable upon presentation of an invoice, which are generated monthly in arrears based on the time incurred. Clients are advised that fees for financial consulting are strictly for services described in their Financial Consulting Agreement and do not include investment management services or financial planning services. Financial consulting fees are negotiable and may be partially or completely waived at our discretion. Our ability to negotiate the fee may result in some clients paying more for the same financial consulting services than other clients receiving the same services. 12  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure Fee Dispersion. CCWM may charge a lesser investment management fee, investment planning fee, or investment consulting fee, or waive its fee entirely based upon certain criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, complexity of the engagement, grandfathered fee schedules, CCWM employees and family members, courtesy accounts, competition, negotiations with client, etc.). Certain clients may have accepted different service offerings from CCWM and may therefore receive services under different fee schedules than as set forth above. Accordingly, similarly situated clients could pay different fees, and CCWM reminds clients that similar services may be available from other investment advisers for similar or lower fees. Other Fees The Firm’s advisory fees are exclusive of and in addition to brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients may also incur certain other charges imposed by custodians, brokers, third-party investment managers, and other third parties, such as interest charges, deferred sales charges, odd-lot differentials, transfer taxes, expense ratios / fund management fees, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Clients are responsible for the payment of these costs and expenses. Independent Managers may execute transactions through broker-dealers other than the account custodian, in which event, the client generally will incur both the transaction fee (commission, mark-up/mark-down) charged by the executing broker-dealer and a separate “tradeaway” and/or prime broker fee charged by the account custodian. CCWM does not receive any portion of the transaction or tradeaway/prime broker fees. Clients should review all fees charged by CCWM and its custodians, brokers, and others to fully understand the total amount of fees to be paid. Mutual funds, exchange-traded funds, investment advisors and alternative investments / private funds also charge internal management fees, which are disclosed in a fund’s prospectus or offering documents. CCWM will not receive any portion of these commissions, fees, or costs. Item 6 - Performance-Based Fees and Side-by-Side Management CCWM does not use a performance-based fee structure and CCWM’s fees are not based on a share of the capital gains or capital appreciation of managed securities. Item 7 - Types of Clients CCWM may provide portfolio management and investment planning to high net worth individuals, trusts, family entities, pension and profit sharing plans, charitable organizations, and foundations. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis CCWM’s investment strategy is to identify independent managers, mutual funds, ETFs, private investment funds, and other securities that are believed to be compatible with client investment objectives, risk tolerances, goals, and financial concerns identified in their Investment Policy Statement. Through our formal and informal financial and investment planning, we help our clients determine the appropriate level of risk and expected return to meet their financial goals. 13  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure During our client discovery phase, we receive and analyze client information necessary to complete the IPS. This IPS is then utilized by the investment adviser representative and the client to help determine an appropriate level of risk and expected return to build an investment strategy designed to meet their financial goals. A client’s portfolio may be invested similar to or different from other clients with the same or similar objectives. Exceptions are made for considerations such as, but not limited to, tax sensitivity, concentrated stock positions, outside holdings and ethical or religious preferences. Portfolios will be diversified according to the target asset class percentages as described in their IPS. The client and investment advisor representative may choose to exclude certain asset classes from a portfolio or otherwise adjust the allocation as desired. Allocations may be adjusted depending on market conditions and/or client profile. Specific portfolio holdings may be increased, decreased, eliminated or added based on our ongoing due diligence process, typically limiting any single holding to 10% or less of total holdings. We generally do not time the market in making major shifts to the target allocation. The investments used may include mutual funds, ETFs, the stock of domestic large and small companies, international and emerging market equities, real estate investment trusts, government and corporate bonds, bank certificates of deposit, commodities, independent managers, alternative investments (i.e. private equity funds, venture capital funds, etc.) and any other investments as appropriate to enable the client to reach their investment objectives. Differing returns among the various asset classes could result in the asset classes becoming overrepresented or underrepresented relative to the selected target allocation. Rebalancing is the process of adjusting any over or underrepresented funds within the asset classes back to the target allocation percentages. Rebalancing may consist of buying or selling portfolio holdings and/or utilizing additional deposits to maintain the target allocation. Market conditions, client profile, income taxes and trading costs will also be taken into consideration, and portfolios will be rebalanced as appropriate. For most discretionary accounts, CCWM recommends that its clients participate in the investment opportunities that it believes are appropriate and transacts in such securities for the account. Security- specific recommendations for discretionary accounts generally include equity and fixed income securities (e.g., municipal bonds, corporate bonds, mutual funds, etc.) and exchange traded funds. Based on a specific client’s Investment Policy Statement, CCWM may have discretion to purchase additional types of securities. For most non-discretionary accounts, CCWM recommends that its clients participate in the investment opportunities that it believes are appropriate and the client ultimately decides whether or not to participate in those investments. CCWM typically recommends capital allocations to independent managers via separately managed accounts or through direct investments in pooled investment vehicles managed by the independent manager. Independent managers generally have discretion to trade, buy, sell and otherwise acquire, hold, dispose of and deal in, on margin or otherwise all types of securities (including, without limitation, long positions or short sales, on margin or otherwise, listed or unlisted), such as equities, bonds, debentures, money market obligations and options to buy and sell securities (both U.S. and non-U.S.), or commodities, futures contracts, cash and forward contracts, options on physical commodities, swaps, derivatives (including, without limitation, all forms of options whether listed or unlisted) and any other rights or interests. 14  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure Investment Managers CCWM may recommend Independent Managers to help clients meet their investment objectives. The Independent Managers that the Firm selects and monitors are responsible for the analysis, selection, and execution of the securities. Independent Managers establish their own specific asset management fee schedules and may have account minimum requirements. Account minimums are generally higher on fixed income accounts than for equity-based accounts. A complete description of the Independent Manager’s services, fee schedules and account minimums will be disclosed in the Independent Manager’s disclosure brochure which will be provided to a client prior to or at the time an agreement for services is executed and the account is established. The actual fee charged to a client will depend on the Independent Manager’s fee schedule and will be billed directly by such Independent Manager to the client. Under this program, a client may incur additional charges including but not limited to, management fees, performance fees, partnership expenses, mutual fund sales loads, 12b-1 fees and surrender charges, and IRA and qualified retirement plan fees. Sources of Information CCWM utilizes a proprietary due diligence process to evaluate investment products, independent managers, and strategies. In addition to traditional research channels, CCWM uses published databases of securities, mutual fund, ETF, Independent Manager, hedge fund, and private equity fund performance or third-party databases. Some of the information provided in these third-party databases is sourced from SEC filings, Form ADV, monthly performance returns, manager’s assets under management, narratives on the manager’s investment process, biographies on portfolio managers, changes in personnel, information on managers’ errors and omissions insurance, and litigation. CCWM does not independently audit or verify the performance figures or other information reported by the funds or managers that appear in these databases. Risks Investing in securities involves risk of loss that clients should be prepared to bear. All investments present the risk of loss of principal, which means the investments may be worth less when sold than the price paid for the securities. There is also the risk of losing purchasing power, which means the rate of appreciation of the investment is less than the rate of inflation. Generally, investors may face the following investment risks: • Portfolio Risk: The risk that an investment manager’s strategies or choice of specific securities may be unsuccessful and may cause the portfolio to incur losses. • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market events. 15  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure • Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Industry Risk: The possibility that a group of stocks in a single industry will decline in price due to developments in that industry. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. • Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. • Third Party Risk: It is common for companies to maintain third-party relationships in an effort to reduce costs, increase efficiency and focus more intently on core competencies. However, while businesses seek to gain a competitive and operational advantage through these relationships, they are also exposing themselves to an increasing level of risk. At the same time, however, it is becoming increasingly difficult for businesses to maintain the necessary controls for mitigating the risks associated with these relationships. Failure to manage these risks can expose a business to regulatory action, financial loss, litigation, and reputational damage, and may even impair the institution’s ability to establish new or service existing customer relationships. • Mutual Fund Risk: Mutual funds are operated by investment companies that raise money from shareholders and invest it in stocks, bonds, and/or other types of securities. Each fund will have a manager that trades the fund’s investments in accordance with the fund’s investment objective. Mutual funds charge a separate management fee for their services, so the returns on mutual funds are reduced by the costs to manage the funds. While mutual funds generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market. Mutual funds come in many varieties. Some invest aggressively for capital appreciation, while others are conservative and are designed to generate income for shareholders. In addition, the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). 16  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure • Exchange Traded Fund Risk: ETFs are marketable securities that are designed to track, before fees and expenses, the performance or returns of a relevant index, commodity, bonds, or basket of assets, like an index fund. Unlike mutual funds, ETFs trade like common stock on a stock exchange. ETFs experience price changes throughout the day as they are bought and sold. In addition to the general risks of investing, there are specific risks to consider with respect to an investment in ETFs, including, but not limited to: (i) an ETF’s shares may trade at a market price that is above or below its net asset value; (ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. • Interval Fund Risk: CCWM may recommend or purchase closed-end interval funds, which are unable to be repurchased or otherwise sold on a daily basis. Rather, to provide limited liquidity to its shareholders, interval funds conduct periodic repurchase offers for a portion of a fund’s outstanding shares. However, there is no guarantee that investors may sell their shares at any given time or in the desired amount. If a repurchase offer is oversubscribed, the fund will repurchase the shares tendered on a pro rata basis, and shareholders will have to wait until the next repurchase offer to make another repurchase request. As a result, shareholders may be unable to liquidate all, or a given percentage, of their investment in the fund during a repurchase offer. Some shareholders, in anticipation of proration, may tender more shares than they wish to have repurchased in a quarter, thereby increasing the likelihood that proration will occur. A shareholder may be subject to market and other risks, and the net asset value of shares tendered in a repurchase offer may decline between the repurchase request deadline and the date on which the net asset value for tendered shares is determined. In addition, the repurchase of shares by the fund may be a taxable event to shareholders. • Alternative Investment / Private Investment Fund Risk: For those clients choosing to invest in alternative investments including, but not limited to hedge funds, private equity funds and venture capital funds, such securities come with additional substantial risks as they are speculative in nature. Alternative investments generally involve various risk factors and liquidity constraints (a complete discussion of which is set forth in each fund’s offering documents) that will be provided to each client for review and consideration. Investing in alternative investments is intended for experienced and sophisticated investors only who are willing to bear the high economic risks of the investment. Investors should carefully review and consider potential risks before investing. Certain of these risks may include loss of all or a substantial portion of the investment due to: leveraging, short-selling, or other speculative practices; lack of liquidity because of redemption terms and conditions and that there may not and will not be a secondary market for the fund; volatility of returns; restrictions on transferring interests in the fund; a potential lack of diversification; higher fees than mutual funds; lack of information regarding valuations and pricing; and advisor risk. Each prospective client investor will be required to review the offering memorandum and complete a Subscription Agreement with the private investment fund itself, pursuant to which the client investor shall establish that they are qualified for investment in the fund and acknowledge and accept the various risk factors that are associated with such an investment. Private funds have liquidity risk and investors may not be able to redeem their investment per the offering document’s disclosures. As a result, the client may be required to hold alternative investments in its account after termination of this or any Investment Management Agreement with CCWM. • Independent Manager Risk: While CCWM conducts due diligence about Independent Managers and their respective investment style and process, CCWM will not necessarily have the opportunity to 17  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure evaluate each specific investment that the Independent Managers will execute on the client’s behalf. CCWM depends on Independent Managers to develop the appropriate systems and procedures to control operational risks. As a result, the rates of return to clients will primarily depend upon the choice of investments and other investment and management decisions of Independent Managers and returns could be adversely affected by unfavorable performance of such Independent Managers. Some of the strategies that Independent Managers employ may present additional risk. There may be other third-party money managers that may be suitable for a client that may be more or less costly. This Independent Manager risk description is intended to supplement but not supersede related information in this Brochure about CCWM’s allocation to Independent Managers. • Cash and Cash Equivalent Risk: CCWM may hold a portion of client’s assets in cash or cash equivalent positions (such as but not limited to money market funds) typically for defensive and liquidity purposes. Investments in these assets may cause a client to miss upswings in the markets. CCWM’s advisory fee could exceed the yield / interest income from holding cash or cash equivalents. A client can advise CCWM not to maintain (or to limit the amount of) cash or cash equivalent positions in their account. • Cybersecurity Risk: The information technology systems and networks that CCWM and its third- party service providers use to provide services to CCWM’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in CCWM’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and CCWM are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost, and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although CCWM has established its systems to reduce the risk of cybersecurity incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that CCWM does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. • Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase morbidity and mortality over a wide geographic area, crossing international boundaries, and causing significant economic, social, and political disruption. The foregoing list of risk factors does not purport to be a complete explanation of the risks involved with investing. Each type of investment has unique risk characteristics which must be considered before investing. These risks could include loss of value, loss of purchasing power and the ability to convert investments quickly to cash. More information about the risks of any specific investment should be discussed before investing. We do not warrant, nor should it be inferred that the services or methods of analysis used can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to major market corrections or crashes. 18  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure Past performance is no indication of future performance. No guarantees can be offered that client goals or objectives will be achieved. Further, no promises or assumptions can be made that the advisory services offered, or our investment adviser representatives will provide a better return than other investment strategies. Therefore, if a client participates in any of the investment management services recommended by us, those clients should be prepared to bear the risk of loss as well as fluctuations in the value of their accounts. Item 9 - Disciplinary Information Registered investment advisors are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of CCWM or the integrity of CCWM’s management. CCWM has no information applicable to this Section as neither it nor any of its employees have faced legal or disciplinary matters since its inception. Item 10 - Other Financial Industry Activities and Affiliations Neither CCWM or its representatives are registered or have an application pending to register as: a broker-dealer or a registered representative of a broker-dealer, a futures commission merchant, a commodity pool operator, a commodity trading advisor, or a representative of the foregoing. As described in Item 4, CCWM does not serve as an attorney, accountant, or insurance agent, and no portion of our services should be construed as same. Accordingly, CCWM does not prepare legal documents, prepare tax returns, or sell insurance products. Upon specific client request, we may recommend the services of other professionals for non-investment implementation purpose (i.e., attorneys, accountants, insurance, etc.), including CCWM’s affiliated CPA firm (Citrin Cooperman Advisors, LLC (“CPA”), which owns 100% of CCWM. Clients are advised that fees for accounting services by CPA are in addition to fees paid for advisory services. Clients are not obligated to engage any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from CCWM and/or its representatives. The recommendation by CCWM that a client engage CPA to provide services presents a conflict of interest. Clients can obtain accounting and insurance services from other unaffiliated service providers. Engagement of CPA is subject to the terms and conditions of a separate agreement and fee. There are no fee sharing arrangements between CCWM’s affiliates and CCWM. However, key CCWM employees, Michael Dooley, and Arnold Herrmann, are also minority owners of the CPA, and will indirectly benefit from compensation paid to CPA. Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading CCWM has adopted a Code of Ethics for all supervised persons of the firm that describes its high standard of business conduct, and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, and standard of conduct in order to comply with federal security laws, among other things. The Code of Ethics includes, among other things, that employees: 19  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure  Act with integrity, competence, diligence, respect, and in an ethical manner with the public, clients, prospective clients, employers, employees, colleagues in the investment profession, and other participants in the global capital markets;  Place the integrity of the investment profession, the interests of clients, and the interests of CCWM above one’s own personal interests;  Disclose conflicts of interest;  Conduct all personal securities transactions in a manner consistent with this policy;  Promote the right of the client to select and choose any broker or dealer they wish to utilize;  Emphasize the unrestricted right of the client to decline to implement or modify any advice rendered;  Use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, taking investment actions, and engaging in other professional activities;  Practice and encourage others to practice in a professional and ethical manner that will reflect favorably on themselves and the profession;  Promote the integrity of, and uphold the rules governing, capital markets;  Maintain and improve one’s professional competence and strive to maintain and improve the competence of other investment professionals; and  Comply with applicable provisions of the federal securities laws. All supervised persons at CCWM must acknowledge the terms of the Code of Ethics annually, or as amended. CCWM anticipates that, in appropriate circumstances, consistent with clients’ investment objectives, it will cause accounts over which CCWM has management authority to effect and will recommend to investment management clients or prospective clients, the purchase or sale of securities in which CCWM, its affiliates and/or clients, directly or indirectly, have a position of interest. CCWM’s employees and persons associated with CCWM are required to follow CCWM’s Code of Ethics. Subject to satisfying this policy and applicable laws, officers, directors, and employees of CCWM and its affiliates may trade for their own accounts in securities which are recommended to and/or purchased for CCWM’s clients. The Code of Ethics is designed to assure that the personal securities transactions, activities, and interests of the employees of CCWM will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code of Ethics, certain classes of securities have been designated as exempt transactions, based upon a determination that these would not materially interfere with the best interest of CCWM’s clients. In addition, the Code of Ethics requires pre-clearance of certain transactions, and may restrict certain trading in close proximity to client trading activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is 20  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure monitored under the Code of Ethics to reasonably prevent conflicts of interest between CCWM and its clients. It is CCWM’s policy that clients’ transactions will always have priority over the transaction of an employee of CCWM. Additional procedures have been adopted to ensure compliance with the provisions of the Code of Ethics, including affirmations of compliance annually and upon amendment and regular reviews of holdings and transactions. CCWM’s clients or prospective clients may request a copy of the Firm’s Code of Ethics by contacting the CCO at (212) 697-1000 or mdooley@ccwmlp.com. It is CCWM’s policy that the Firm will not affect any principal or agency cross securities transactions for client accounts. CCWM will also not cross trades between client accounts. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. A principal transaction may also be deemed to have occurred if a security is crossed between an affiliated hedge fund and another client account. An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions may arise where an adviser is dually registered as a broker-dealer or has an affiliated broker-dealer. Item 12 - Brokerage Practices We may, pursuant to the terms of our Investment Management Agreements with clients, have discretionary authority to determine which securities are to be bought and sold, and the amount of such securities, the executing broker-dealer, and the commission rates to be paid to affect such transactions. When seeking “best execution,” from a broker-dealer, the determinative factor is not always the lowest possible cost, but whether the transaction represents the best qualitative execution when considering the full range of a broker-dealer’s services including the value of research provided, execution capability, commission rates, and responsiveness. Although CCWM cannot guarantee that clients will always experience the best possible execution available, CCWM seeks to recommend a broker-dealer/custodian that will hold client assets and execute transactions on terms that are, overall, most advantageous when compared with other available providers and their services. We will follow a process in an attempt to ensure that it is seeking to obtain the most favorable execution under the prevailing circumstances when placing client orders. These factors, in no particular order, include, but are not limited to the following: 1. The financial strength, reputation and stability of the broker; 2. Combination of transaction execution services and asset custody services (generally without a separate fee for custody); 3. Capability to execute, clear and settle trades (buy and sell securities for client accounts); 4. The efficiency with which the transaction is executed; 5. The ability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread or commission, if any); 21  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure 6. The availability of the broker to stand ready to effect transactions of varying degrees of difficulty in the future; 7. The efficiency of error resolution, clearance and settlement; 8. Block trading and positioning capabilities; 9. Performance measurement; 10. Online access to computerized data regarding customer accounts; 11. Availability, comprehensiveness, and frequency of brokerage and research services; 12. Price competitiveness of services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices; 13. Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.); 14. Quality of service; 15. Breadth of available investment products (stocks, bonds, mutual funds, ETFs, etc.); 16. The economic benefit to the client; and 17. Related matters involved in the receipt of brokerage services. Consistent with our fiduciary responsibilities, we seek to ensure that clients receive best execution with respect to clients’ transactions by blocking client trades to reduce commissions and transaction costs. To the best of our knowledge, these custodians provide high-quality execution, and our clients do not pay higher transaction costs in return for such execution. If a client requests that CCWM recommend a broker-dealer/custodian for custodial services and execution, CCWM generally recommends that investment management accounts be maintained at Charles Schwab & Co., Inc. and its affiliates (“Schwab”) or LPL Financial, LLC and its affiliates (“LPL”), each a FINRA registered broker-dealer and a member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. Although we may recommend that clients establish accounts at Schwab or LPL, it is the client’s decision as to where they wish to custody assets. For client accounts maintained at Schwab and/or LPL, the custodian generally does not charge separately for custody services but is compensated by account holders through commissions and other transaction-related or asset-based fees for securities trades that are executed through Schwab and/or LPL. Although CCWM will seek competitive rates, it may not necessarily obtain the lowest possible commission rates for all client account transactions. The fees charged by the designated broker- dealer/custodian are exclusive of, and in addition to, CCWM’s investment management fees. Our advice to certain clients and entities and the actions of the Firm for those and other clients are frequently premised not only on the merits of a particular investment, but also on the suitability of that investment for the particular client in light of his or her applicable investment objective, guidelines and circumstances. Thus, any of our actions with respect to a transaction’s particular investment, may, for a particular client, differ from the recommendation, advice, or actions of us on behalf of other clients. Before engaging CCWM to provide investment management services, the client enters into an agreement with CCWM setting forth the terms and conditions for the management of the client’s assets, and a separate custodial/clearing agreement with each designated broker-dealer/custodian. Depending on which broker-dealer/custodian clients select to maintain their account, they may experience differences in customer service, transaction timing, the availability and yield / interest income of sweep account vehicles and money market funds, and other aspects of investing that could cause differences in account performance. 22  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure Research and Other Soft Dollar Benefits. The term “soft dollar” generally refers to the practice of using client brokerage commissions to obtain research and other services used in the conduct of our business, rather than purchasing the services directly. We do not engage in soft dollar practices, and we do not use brokerage commissions (or markups or markdowns) to obtain research or other products or services. While CCWM does not receive traditional “soft dollar benefits,” CCWM and by extension, its clients, receive access to certain institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab or LPL retail customers. Schwab and LPL also make various support services available to CCWM. Some of those services help CCWM manage or administer its clients’ accounts; while others help it manage and grow its business. Schwab and LPL’s support services generally are available on an unsolicited basis (CCWM does not have to request them) and at no charge to CCWM. Schwab and LPLs 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 and LPL include some to which CCWM might not otherwise have access or that would require a significantly higher minimum initial investment by its clients. These services benefit CCWM’s clients and their accounts. Schwab and LPL also make other products and services available to CCWM that benefits CCWM but may only indirectly benefit its clients or their accounts, such as investment research developed by Schwab or LPL, or third parties that CCWM may use to service clients’ accounts. In addition to investment research, Schwab and LPL also makes available software and other technology that:  Provide access to client account data (such as duplicate trade confirmations and account statements);  Facilitate trade execution and allocate aggregated trade orders for multiple client accounts;  Provide pricing and other market data;  Facilitate payment of our fees from other clients’ accounts; and  Assist with back-office functions, recordkeeping, and client reporting. Schwab may offer other services intended to help CCWM manage and further develop its business. These services include:  Educational conferences and events;  Consulting on technology, compliance, legal and business needs;  Publications and conferences on practice management and business succession; and  Access to employee benefits providers, human capital consultants, and insurance providers. Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to CCWM Schwab may discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab can also provide occasional business meals and entertainment for CCWM’s personnel. 23  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure CCWM’s Interest in Schwab and LPL’s Services and Benefits and Related Conflict of Interest. The availability of the services and products described above that CCWM receives from Schwab and LPL (the “Services and Products”) provides CCWM with an advantage, because CCWM does not have to produce or purchase them. However, CCWM does not have to pay Schwab or LPL or any other entity for Services and Products that Schwab and LPL provides. CCWM’s clients do not pay more for investment transactions executed or assets maintained at Schwab or LPL as a result of this arrangement. The receipt of Services and Products is not contingent upon CCWM committing any specific amount of business to Schwab or LPL in trading commissions or assets in custody. There is no corresponding commitment made by CCWM to Schwab or LPL or any other entity to invest any specific amount or percentage of client assets in any specific securities or investment products as a result of the above. However, this arrangement nonetheless incentivizes CCWM to recommend that clients maintain their account with Schwab or LPL, based on its interest in receiving Schwab’s services that benefit its business rather than based on clients’ interest in receiving the best value in custody services and the most favorable execution of their transactions. This presents a conflict of interest. When making such a recommendation, however, CCWM does so when it reasonably believes that recommending Schwab or LPL to serve as broker-dealer/custodian is in the best interests of its clients. It is primarily supported by the scope, quality, and price of Schwab or LPL’s services and not Schwab or LPL’s services that benefit only CCWM. CCWM does not receive referrals from broker-dealers. Directed Brokerage. CCWM recommends that its clients utilize the brokerage and custodial services provided by Schwab or LPL. For our accounts custodied at Schwab or LPL, Schwab or LPL is generally compensated by clients through commissions, trails, or other transaction-based fees for trades that are executed through Schwab or LPL or that settle into Schwab or LPL accounts. For IRA accounts, Schwab and LPL generally charge account maintenance fees. In addition, Schwab and LPL may also charge clients miscellaneous fees and charges, such as account transfer fees. LPL charges an asset-based administration fee for administrative services provided by LPL. Such administration fees are not directly borne by clients but may be taken into account when we negotiate advisory fees with clients. The Firm may accept directed brokerage arrangements (when a client requires that account transactions be effected through a specific broker-dealer). In such client directed arrangements, the client will negotiate terms and arrangements for their account with that broker-dealer, and Firm will not seek better execution services or prices from other broker-dealers or be able to "batch" the client’s transactions for execution through other broker-dealers with orders for other accounts managed by CCWM. As a result, a client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case. In the event that the client directs CCWM to effect securities transactions for the client’s accounts through a specific broker-dealer, the client correspondingly acknowledges that such direction may cause the accounts to incur higher commissions or transaction costs than the accounts would otherwise incur had the client determined to effect account transactions through alternative clearing arrangements that may be available through CCWM. Higher transaction costs adversely impact account performance. Order Aggregation. If CCWM is executing transactions directly, it will generally do so for each client independently, unless CCWM decides to purchase or sell the same securities for several clients at approximately the same time. CCWM may (but is not obligated to) combine or “bunch” such orders 24  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure to seek best execution, to negotiate more favorable commission rates, or to equitably allocate differences in prices and commissions or other transaction costs among CCWM’s clients, which might have been obtained if the orders were placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among clients in proportion to the purchase and sale orders placed for each client account on any given day. CCWM will not receive any additional compensation or remuneration as a result of such aggregation. To minimize performance dispersion, “strategy” trades should be aggregated and average priced. However, when a trade is to be executed for an individual account and the trade is not in the best interests of other accounts, then the trade will only be performed for that account. This is true even if we believe that a larger size block trade would lead to best overall price for the security being transacted. Allocation of Trades: Our allocation procedures seek to allocate investment opportunities among clients in the fairest possible way, considering the clients’ best interests. We will follow procedures to ensure that allocations do not involve a practice of favoring or discriminating against any client or group of clients. Account performance is never a factor in trade allocations. All allocations will be made prior to the close of business on the trade date. In the event an order is “partially filled,” the allocation will be made in the best interests of all the clients in the order, considering all relevant factors including, but not limited to, the size of each client’s allocation, clients’ liquidity needs and previous allocations. In most cases, accounts will get a pro forma allocation based on the initial allocation. This policy also applies if an order is “over-filled.” We act in accordance with our duty to seek best price and execution and will not continue any arrangements if we determine that such arrangements are no longer in the best interest of our clients. Item 13 - Review of Accounts Account Reviews For those clients to whom CCWM provides investment management services, CCWM reviews their portfolios at least quarterly, but often more frequently, for performance, target allocations, and client restrictions. Client accounts are reviewed in the first instance by the investment advisor representative, who will be a supervised person of the Firm. Such professionals are subject to the general authority of our Investment Committee, who will periodically review accounts. The frequency of reviews is determined based on the client’s investment objectives, but reviews are conducted no less frequently than quarterly. For those clients to whom CCWM provides financial planning services, clients receive their financial plans and recommendations at the time service is completed. There are no post-plan reviews unless clients engage us to do so. For those clients to whom CCWM provides consulting services, clients receive their consolidated reports at a regular frequency as described in their financial consulting agreement. The frequency of reviews is determined based on changes in the client’s balance sheet, such as, but not limited to asset 25  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure acquisitions and dispositions, new accounts, closed accounts, or change of custodians. Clients are encouraged to inform CCWM of balance sheet and portfolio changes to ensure timely and accurate reporting. Account Statements and Supplemental Reports Unless otherwise agreed upon, clients are provided with transaction confirmation notices and account statements directly from the broker-dealer or custodian for the client accounts no less than quarterly. However, CCWM may provide clients with supplemental reports including relevant account or market-related information such as an inventory of account holdings and account performance from time to time. Those reports may vary from custodial statements based on accounting procedures, accruals. reporting dates, or valuation methodologies of certain securities. Clients are urged to carefully review their qualified custodian transaction confirmation notices and account statements promptly upon receipt and compare the account statement against any reports that they might receive from CCWM. Financial Planning and/or Consulting Reports Those clients to whom CCWM provides financial planning and/or consulting services will receive reports from CCWM summarizing its analysis and conclusions as requested by the client or otherwise agreed to in writing by CCWM. Review Triggers Triggering factors for an immediate review include, but are not limited to a change in the client’s investment objectives, tax considerations, material deposits or withdrawals, large acquisitions or dispositions, loss of confidence in the underlying investment, or changes in macro-economic climate. Clients are encouraged to discuss their needs, goals, and objectives with CCWM and to keep CCWM informed of any changes thereto. Item 14 - Client Referrals and Other Compensation CCWM receives economic benefits from Schwab and LPL including support services and/or products without cost or at a discount as described in Item 12. CCWM’s clients do not pay more for investment transactions executed at or assets maintained at Schwab or LPL as a result of this arrangement. There is no corresponding commitment made by CCWM to Schwab, LPL, or any other entity to invest any specific amount or percentage of client assets in any specific mutual funds, securities, or other investment products as a result of the above arrangement. CCWM does not compensate any person or entity besides its supervised persons for client referrals. Item 15 - Custody Custody – Fee Debiting 26  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure Client cash, securities, and other liquid funds are held with a qualified custodian. Clients have the ability to authorize their custodian (i.e. Schwab, LPL, etc.) to deduct fees from client accounts in accordance with their Investment Management Agreement. Clients will receive written account statements and transaction confirmation notices directly from the custodian at least quarterly. Clients are urged to carefully review their qualified custodian account statements promptly upon receipt and compare the account statement against any reports that they might receive from CCWM. The account custodian does not verify the accuracy of CCWM’s advisory fee calculation. The custodian also offers the option of viewing portfolio information and account statements through the client’s online account access. CCWM recommends that clients set up their on-line account. Custody – Third Party Money Transfers Clients may provide us with a standing letter of authorization (or similar asset transfer authorization) which allows us to disburse funds on behalf of clients to third parties. We ensure the following conditions are in place when deemed to have custody via third party money movement: 1. The client provides a Written Authorization to the custodian that includes all appropriate information as to how the transfer should be directed; 2. The Written Authorization includes instruction to direct transfers to the third party either on a specified schedule or from time to time; 3. Appropriate verification is performed by the custodian, along with a transfer of funds notice to the client promptly after each transfer; 4. The client may terminate or change the instruction to the custodian; 5. We have no authority or ability to designate or change any information about the third party contained in the instruction; 6. We maintain records showing that the third party is not a related party of the Firm or located at the same address as ours; and 7. The custodian sends the client a written initial notice confirming the instruction and an annual written confirmation thereafter. Access to or Elements of Control over Certain Client Assets CCWM does not directly hold client funds or securities; all client assets are held by unaffiliated qualified custodians (i.e. Schwab, LPL, etc.). However, under the Rule 206(4)-2 under the Investment Advisers Act of 1940, CCWM is deemed to have custody as a result of having certain types of access to or elements of control over certain client funds that require disclosure at Form ADV Part 1, Item 9. Clients receive no less than quarterly statements from their qualified custodian and are urged to carefully review their qualified custodian account statements promptly upon receipt and compare the account statement against any reports that they might receive from CCWM. For those elements of custody requiring a surprise custody examination, CCWM engages an independent public accountant registered with, and subject to regular inspection by, the Public 27  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure Company Accounting Oversight Board to conduct the surprise exam in accordance with Rule 206(4)- 2 under the Investment Advisers Act of 1940. Item 16 - Investment Discretion If the client signs a discretionary Investment Management Agreement, CCWM will be granted discretionary authority from the client at the outset of the advisory relationship. This authority will allow CCWM to select the identity, amount, time, and price at which securities are to be purchased and sold for the client’s portfolio. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account. When selecting securities and making investment decisions, CCWM observes the investment policies, limitations, and restrictions of the clients for which it provides discretionary investment management services. CCWM allows its clients to place reasonable restrictions on the management of their portfolio. For registered investment companies, our authority to trade securities may also be limited by certain federal securities and tax laws that require diversification of investments and favor the holding of investments once made. For discretionary clients, all investment guidelines and restrictions must be agreed to in writing between CCWM and the client. Clients may grant us a limited power of attorney with respect to trading activity in their accounts by signing the appropriate custodian limited power of attorney form. In those cases, we will exercise full discretion as to the nature and type of securities to be purchased and sold, the amount of securities for such transactions, the amount of commissions to be paid, and the executing broker to be used. Investment limitations may be designated by the client as outlined in the Investment Management Agreement. In addition, subject to the terms of its Investment Management Agreement, we may be granted discretionary authority for the retention of Independent Managers. Investment limitations may be designated by the client as outlined in the Investment Management Agreement. Please see the applicable third-party manager’s disclosure brochure for detailed information relating to discretionary authority. Clients who engage CCWM on a non-discretionary basis concurrently acknowledge that CCWM cannot execute any account transactions without obtaining the client’s prior consent to the transactions. Therefore, if CCWM would like to make a transaction for a client’s account (including selling a security or firing an independent manager that CCWM no longer believes is appropriate, or buying a security or hiring an independent manager that CCWM believes is appropriate), and the client is unavailable to provide consent, CCWM will be unable to execute the account transactions (as it would for its discretionary clients). Affected clients may be disadvantaged as a result, which could include investment losses or missing potential gains as a result. Item 17 - Voting Client Securities Discretionary Investment Management Agreement CCWM will vote proxies for securities over which we maintain discretionary authority. Our priority and utmost concern are that all decisions be made solely in the client’s best interest. We will act in a prudent and diligent manner intended to enhance the economic value of the assets of the client’s portfolio. Although many proxy proposals can be voted in accordance with our established guidelines, 28  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure we recognize that some proposals require special consideration, which may dictate that we make an exception to the guidelines. Clients may direct our vote; however, direction must be received in writing. Clients may contact us for information about proxy voting. Non-Discretionary Investment Management Agreement CCWM will not vote proxies for securities over which we maintain non-discretionary authority. For these relationships CCWM does not have authority to and does not vote proxies on behalf of its advisory clients, unless the particular Investment Management Agreement states otherwise. The obligation to vote client proxies shall always rest with the client who will receive proxies directly from the appropriate financial institutions. Clients utilizing Independent Managers may assign proxy voting authority to the Independent Manager at their discretion. Item 18 - Financial Information CCWM has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. CCWM does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients. CCWM does not require prepayment of fees both more than $1,200 per client, six months or more in advance, and therefore, we are not required to provide a balance sheet to clients. 29