Overview
Assets Under Management: $666 million
High-Net-Worth Clients: 285
Average Client Assets: $2 million
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Fee Structure
Primary Fee Schedule (FIRM DISCLOSURE BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | and above | 1.25% |
Minimum Annual Fee: $6,000
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $12,500 | 1.25% |
| $5 million | $62,500 | 1.25% |
| $10 million | $125,000 | 1.25% |
| $50 million | $625,000 | 1.25% |
| $100 million | $1,250,000 | 1.25% |
Clients
Number of High-Net-Worth Clients: 285
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 76.06
Average High-Net-Worth Client Assets: $2 million
Total Client Accounts: 2,985
Discretionary Accounts: 2,985
Regulatory Filings
CRD Number: 328909
Filing ID: 1986818
Last Filing Date: 2025-05-01 15:23:00
Website: https://druckerwealth.com
Form ADV Documents
Additional Brochure: FIRM DISCLOSURE BROCHURE (2025-09-25)
View Document Text
Item 1 – Cover Page
Registered as Drucker Wealth 3.0, LLC | DBA: Drucker Wealth | CRD No. 328909
Form ADV Part 2A – Firm Disclosure Brochure
2 Park Ave, New York, NY 10016
Phone: (212) 681-0460 | Fax: (419) 735-0158
Mailing Address
50 Tice Boulevard, Suite 340 | Woodcliff Lake, NJ | 07677
Website: https://druckerwealth.com/
September 25, 2025
This brochure provides information about the qualifications and business practices of Drucker Wealth. If you have any questions about
the contents of this brochure, please contact us at Phone: (212) 681-0460 Fax: (419) 735-0158. 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 Drucker Wealth is also available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s
firm name or CRD No: 328909. Registration does not imply a certain level of skill or training.
Page 1 of 27
Item 2 – Material Changes
Annually, a complete Disclosure Brochure will be offered to Clients along with a summary of material changes, if any, within 120 days
from the firm’s fiscal year-end.
At any time, the current Disclosure Brochure is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching the firm name or CRD number 328909. A copy of this Disclosure Brochure may be requested
at any time, by contacting (212) 681-0460.
Page 2 of 28
Disclosure 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 Services ...................................................................................................................................................... 4
Item 5 – Fees and Compensation ............................................................................................................................................ 8
Item 6 – Performance-Based Fees and Side-By-Side Management ................................................................................... 10
Item 7 – Types of Clients ....................................................................................................................................................... 10
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................................................ 10
Item 9 – Disciplinary Information ........................................................................................................................................ 15
Item 10 – Other Financial Industry Activities and Affiliations ......................................................................................... 15
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................ 16
Item 12 – Brokerage Practices .............................................................................................................................................. 17
Item 13 – Review of Accounts ............................................................................................................................................... 19
Item 14 - Client Referrals and Other Compensation .......................................................................................................... 19
Item 15 – Custody .................................................................................................................................................................. 20
Item 16 – Investment Discretion ........................................................................................................................................... 21
Item 17 – Voting Client Securities ........................................................................................................................................ 21
Item 18 – Financial Information ........................................................................................................................................... 21
Appendix 1 - Wrap Fee Program Brochure ………………………….…………….…………………………………….. 22
Privacy Policy ……………………………………………………………………..…………………………………..…… 27
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Disclosure Brochure
Item 4 – Advisory Services
Firm Information
Drucker Wealth is a third-generation financial planning and wealth management team based in New Jersey with virtual operations across
the country. The firm, Drucker Wealth 3.0, LLC is organized as a limited liability company (“LLC”) under the laws of New Jersey.
Drucker Wealth registered as an investment advisor with the U.S. Securities and Exchange Commission (“SEC”) in 2024. This
Disclosure Brochure provides information regarding the qualifications, business practices, and advisory services provided by Drucker
Wealth.
Principal Owners
Lance S. Drucker, ChFC® CLU® AIF®
Chairman
Lance Drucker has over 30 years of industry experience and a B.S. in accounting and finance from SUNY
Binghamton. He also earned the Chartered Financial Consultant (ChFC®) designation, Chartered Life
Underwriter (CLU®) designation and Accredited Investment Fiduciary (AIF®) designation. He also earned
a Certificate in Retirement Income Planning from the Wharton School of Business.
Gideon B. Drucker, CFP®, AIF®, ECA
President
Gideon Drucker, CERTIFIED FINANCIAL PLANNER™, Accredited Investment Fiduciary® and Equity
Compensation Associate® is the Founder and Director of the Wealth Builder Division at Drucker Wealth.
Gideon is the author of the book, "How To Avoid HENRY Syndrome®" and created the HENRY Syndrome®
suite of services as a way to educate and empower high earners not rich yet, newlyweds, and young families
to make smart financial decisions for their futures.
Gideon graduated from Lehigh University before serving as a combat paratrooper in the Israel Defense
Forces.
Financial Planning
Drucker Wealth focuses on financial planning as part of a comprehensive asset management engagement or as a stand-alone service.
The type of planning can vary greatly depending on the scope and complexity of an individual’s financial situation. An initial financial
planning engagement generally terminates within 2 to 3 months. Once the initial engagement terminates, clients may elect to enter into
an ongoing comprehensive relationship for which investment management & financial planning are provided together. Examples of
the type of planning available include the following:
Tax Planning
Drucker Wealth provides tax planning to help minimize a client’s tax liabilities.
Equity Compensation Planning
Drucker Wealth provides tips to clients employed at tech and media companies such as reviewing benefits, restricted stock
options, vesting schedules, and plan contribution limits.
Investment Management
Once a plan is completed, Drucker Wealth can help execute the investment strategy based on risk tolerance, tax situation and
a client’s unique financial circumstances. Drucker Wealth will monitor the investment program and make changes as
circumstances warrant based on the science of investing and behavioral economics.
Insurance & Estate Planning
Insurance and estate planning incorporates income, expenses, taxes, insurances, short term & long-term financial goals to help
determine efficient tax management, protection and distribution objectives
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Disclosure Brochure
Asset Management
Drucker Wealth offers discretionary1 asset management in addition to financial planning services primarily to individuals, high net
worth individuals, and small business owners (each referred to as a “client”). Investment accounts are maintained at National Financial
Services LLC, and Fidelity Brokerage Services LLC (together with all affiliates, "Fidelity") or Altruist Financial, LLC, both
FINRA/SIPC member broker/dealers to serve as the custodian for client funds (“Custodian”). Investment advice is not limited to certain
types of investments. Advisory services are tailored to the individual needs of clients who may impose restrictions on investing in
certain securities or types of securities.
Wrap Fee Program
Transaction fees are paid by Drucker Wealth instead of the client, which make the advisory accounts offered by Drucker Wealth a wrap
fee program2. Clients should understand that the cost of transaction charges can be a factor that Drucker Wealth considers when deciding
which securities to select and how frequently to place transactions. Drucker Wealth has a financial incentive to recommend Class A
Shares in cases where both Class A and Platform Shares are available. This is a conflict of interest which might incline Drucker Wealth,
consciously or unconsciously, to render advice that is not disinterested. Drucker Wealth does not pay transaction charges for Class A
Share mutual fund transactions or Platform Share mutual fund transactions. The cost3 to Drucker Wealth of transaction charges can be
a factor Advisor considers when deciding which securities to select and whether or not to place transactions in the account.
Please see Appendix 1 –Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure.
Direct Indexing
Direct indexing is an approach to index investing that involves buying some of the individual stocks that make up an index, with the
aim of tracking the overall index. This is in contrast to buying an index mutual fund or index exchange-traded fund (index ETF) that
tracks the index. Direct indexing can provide greater autonomy, control, and tax advantages to certain investors over owning an index
mutual fund or an index exchange-traded fund (index ETF). This program is generally for non-qualified accounts only. Drucker Wealth
uses either a sub-advisor or a model trading platform when implementing Direct Indexing strategies.
Pontera Solutions Inc.
Drucker Wealth provides an additional service for accounts not directly held in our custody but where we do have discretion and can
leverage an Order Management System4 to implement portfolio strategy changes and opportunistic rebalancing strategies on behalf of
the client. These are primarily 401(k) accounts and other assets we do not custody. We regularly review the available investment options
in these accounts and execute portfolio changes as appropriate. While managing employee retirement plan assets through Pontera,
Drucker Wealth is confined to the guidelines and limitations of the employer plan.
Estate Planning
Drucker Wealth can provide access to a third-party technology platform to provide educational content and estate planning tools.
Drucker Wealth does not provide legal advice, and the available planning tools should not be considered a substitute for services
provided by a licensed attorney.
1 Client grants Advisor ongoing and continuous authority to execute its investment recommendations without the Client's prior approval
of each specific transaction. Under this authority, Client shall allow Advisor to purchase and sell securities and instruments in this
Account(s), arrange for delivery and payment in connection with the foregoing, select and retain sub-advisors, and act on behalf of the
Client in all matters necessary or incidental.
2 A wrap fee program is a comprehensive advisory account with a single fee that covers a bundle of services, such as, portfolio
management, advice, and investment research as well as trade execution, custody, and reporting fee.
3 The lack of transaction charges to Drucker Wealth for Class A Share purchases and sales, together with the fact that Platform Shares
generally are less expensive for a client to own, presents a significant conflict of interest between Drucker Wealth and the client. In
short, it costs less to recommend and select Class A share mutual funds than Platform shares, but Platform shares will generally
outperform Class A mutual fund shares on the basis of internal cost structure alone. Clients should understand this conflict and consider
the additional indirect expenses borne as a result of the mutual fund fees when negotiating and discussing fees.
4 https://pontera.com
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Disclosure Brochure
Asset Under Management
As of December 31, 2024, the assets under management are:
Discretionary
Non-Discretionary
$654,795,618
$0.00
Clients may request more current information at any time.
Artificial Intelligence
Artificial Intelligence (AI) refers to the simulation of human intelligence in machines designed to think and learn like humans. AI
encompasses a range of technologies that enable systems to perform tasks such as recognizing speech, making decisions, and
understanding complex ideas. AI tools can be used to enhance our services, improve operational efficiency, and deliver overall better
outcomes. By integrating AI into our processes, we aim to stay at the forefront of technological innovation while maintaining a strong
commitment to ethical practices and data privacy. Advisor utilizes AI for real-time note-taking during web calls to enhance accuracy,
efficiency, and productivity. Our AI tool transcribes spoken content, generates summaries, and identifies key takeaways. Participants
are informed of AI usage and have the right to opt out of AI-generated note-taking. Should a client have any questions or concerns,
please contact us at our email address, phone number, or through our website. In addition to real-time note-taking, Advisor uses AI to
gather general insights and create frameworks projects. By analyzing large volumes of data and identifying patterns, AI helps us develop
preliminary concepts, streamline research processes, and enhance decision making. This allows Advisor to focus on more complex and
creative aspects of our work, ultimately delivering more comprehensive and effective solutions for our clients. We ensure that any use
of AI is supervised and conducted with transparency, maintaining the highest standards of data privacy and ethical practices.
Retirement Plan Rollovers
An employee generally has four (4) options for their retirement plan when they leave an employer:
1. Leave the money in his/her former employer’s plan, if permitted
2. Rollover the assets to his/her new employer’s plan if one is available and permitted
3. Rollover to an Individual Retirement Account (IRA), or
4. Cash out the account value, which has significant tax considerations
Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or
tax attorney. If you are considering rolling over your retirement funds to an IRA for us to manage here are a few points to consider
before you do so:
Determine whether the investment options in your employer's retirement plan address your needs or whether you might want
to consider other types of investments.
Employer retirement plans generally have a more limited investment menu than IRAs.
Employer retirement plans may have unique investment options not available to the public such as employer securities, or
previously closed funds.
Your current plan may have lower fees.
If a client elects to roll the assets to an IRA that is subject to our management, we will charge an asset-based fee as set forth in an
agreement executed with our firm. This practice presents a conflict of interest because Investment Advisor Representatives have an
incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your needs.
Clients are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if a client completes the rollover, they
are under no obligation to have the assets in an IRA managed by Drucker Wealth.
Many employers permit former employees to keep their retirement assets in the company plan. Also, current employees can sometimes
move assets out of the company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and
to the extent the following options are available, clients should consider the costs and benefits of each. An employee will typically be
investing only in mutual funds, you should understand the cost structure of the share classes, available in your employer's retirement
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Disclosure Brochure
plan and how the costs of those share classes compare with those available in an IRA. Clients should understand the various products
and services they might take advantage of at an IRA provider and the potential costs of those products and services.
The Drucker Wealth strategy may have higher risk than the option(s) provided in an employer plan.
A client’s employer plan may also offer financial advice.
If a client keeps their assets titled in a 401k or retirement account, they could potentially delay required minimum distributions.
A 401(k) may offer more liability protection than a rollover IRA; each state may vary.
Clients may be able to take out a loan on their 401k, but not from an IRA.
IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and subject to a 10% early
distribution penalty unless they qualify for an exception such as disability, higher education expenses or home purchase.
If company stock is owned in a plan, participants may be able to liquidate those shares at a lower capital gains tax rate.
Plans may allow Advisor to be hired as the manager and keep the assets titled in the plan name.
Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from
creditors in bankruptcies. However, there can be some exceptions to the general rules so you should consult with an attorney if you are
concerned about protecting your retirement plan assets from creditors.
It is important to understand the differences between these types of accounts and to decide whether a rollover is the best option. Prior to
proceeding, if you have questions contact your Investment Adviser Representative, or call our main number as listed on the cover page
of this brochure.
Drucker Wealth generally provides educational services to retirement plan participants with assets that could potentially be rolled-over
to an IRA advisory account. Education is based on a particular Client’s financial circumstances and best interests. Again, Drucker
Wealth has an incentive to recommend such a rollover based on the compensation received, which is mitigated by the fiduciary duty to
act in a client’s best interest and acting accordingly.
If Drucker Wealth provides investment advice to you regarding your retirement plan account or individual retirement account, we are
fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we
operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s
provisions, we must:
Meet a professional standard of care when making investment recommendations (give prudent advice);
Never put our financial interests ahead of yours when making recommendations (give loyal advice);
Avoid misleading statements about conflicts of interest, fees, and investments;
Follow policies and procedures designed to ensure that we give advice that is in your best interest;
Charge no more than is reasonable for our services; and,
Give you basic information about conflicts of interest.
Business Continuity Plan
Drucker Wealth has a business continuity and contingency plan in place designed to respond to significant business disruptions. These
disruptions can be both internal and external. Internal disruptions that could impact our ability to communicate and do business, such as
a fire in the office building. External disruptions will prevent the operation of the securities markets or the operations of a number of
firms, such as earthquakes, wildfires, hurricanes, terrorist attack or other wide-scale, regional disruptions. Our continuity and
contingency plan has been developed to safeguard employees’ lives and firm property, to allow a method of making financial and
operational assessments, to quickly recover and resume business operations, to protect books and records, and to allow clients to continue
transacting business. The plan includes the following:
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Disclosure Brochure
Alternate locations to conduct business
Hard and electronic back-ups of records
Alternative means of communications with employees, clients, critical business constituents and regulators; and Details on the
firms’ employee succession plan.
Our business continuity and contingency plan is reviewed and updated on a regular basis to ensure that the policies in place are sufficient
and operational.
Item 5 – Fees and Compensation
Financial Planning Services
Depending on the circumstances, Drucker Wealth generally charges a fixed fee ranging from $3,000 to $8,000 for financial planning. The
client-specific fee is based on the scope and complexity of the engagement. Clients pay half upon engagement and the balance upon
completion.
Estate Planning
The fee for access to the third-party technology platform is up to $2,499.
Asset Under Management
Asset management fees are based on the scope and complexity of the services provided; they generally do not exceed 1.25%. That
said, our asset management services require a $6,000 minimum annual fee, which, depending on the asset under management, will
exceed a 1.25% asset management fee.
Third Party Asset Management Programs (“TAMP”)
Drucker Wealth has the ability to select other investment advisors or introduce Third-Party Asset Management Programs (“TAMP”) by
referral or sub-advisory arrangement. A third-party asset management program is an investment advisor selected to manage client assets
on behalf of Drucker Wealth. The process begins with a thorough assessment of the client's financial situation, investment objectives,
risk tolerance, and time horizon. Once an investment strategy is established and approved by the client, the third-party asset manager
takes responsibility for implementing and managing the portfolio. This includes buying and selling securities, rebalancing the portfolio
periodically to maintain the desired asset allocation, and making adjustments based on market conditions or changes in the client's
objectives.
Sub-advisory Agreement
A sub-advisory agreement is a contractual arrangement between two registered investment advisors, where one firm (the "sub-adviser")
is hired by another firm (Drucker Wealth) to manage all or a portion of the assets of a specific investment fund or client account. In this
arrangement, Drucker Wealth retains overall responsibility for the management of the client account, while delegating all or a portion
of the investment decisions and portfolio management functions to the sub-advisor.
The sub-advisory agreement outlines the terms and conditions of the collaboration between the two firms, including the scope of the
sub-advisor's responsibilities, the compensation structure, and any other relevant terms. The agreement will clearly define the specific
duties and responsibilities of the sub-advisor. This can include investment strategy, asset allocation, security selection, risk management,
and performance reporting. The compensation structure for the sub-advisor is usually outlined in the agreement. Compensation can be
a fixed fee, a percentage of assets under management, or a combination of both. The agreement also addresses any additional fees or
expenses that the sub-advisor is entitled to receive.
The non-exclusive functions of a sub-advisor generally include determining the composition and portfolio allocation, the nature and
timing of the changes therein and the manner of implementing such changes, investment monitoring, and research. Drucker Wealth
delegates to the Sub-Advisor the power and authority to effectuate its investment decisions, including the execution and delivery of all
investment related documents, placing trades, and billing. A sub-advisor has a fiduciary duty to Drucker Wealth and it’s clients. Drucker
Wealth has the discretionary ability to hire and fire sub-advisors.
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Disclosure Brochure
Fee Billing
Fees are assessed pursuant to the arrangement outlined in the client’s specific contract which, in some cases, includes a flat fee to satisfy
firm minimums. Flat fees are paid quarterly in advance based on the agreed upon annual amount.
Percentage Fees are charged quarterly in advance based upon the market value of the assets on the last day of the previous quarter as
valued by the custodian. The initial fee is based on the account’s starting balance and is prorated for the number of days remaining in
the calendar quarter. Client fees will reflect a pro-rated increase or decrease based on account deposits and withdrawals during the
advisory fee period. Upon termination, we will issue Clients a prorated refund of all unearned advisory fees that were paid in advance.
Unless other arrangements are made, fees are directly debited from a client's account(s). The client understands that notification of the
fee deduction will be through the statement from the custodian.
Mutual Fund Share Class Disclosure and Fiduciary Duty (12b-1 Fees)
Section 206 of the Investment Advisers Act of 1940 (“Advisers Act”) imposes a fiduciary duty to act in a client’s best interests and
specifically prohibits investment advisers, directly or indirectly, from engaging in any transaction, practice, or course of business which
operates as a fraud or deceit upon any client or prospective client. However, the fiduciary duty to which advisers are subject is not
specifically defined in the Advisers Act or the Commission rules but reflects a Congressional recognition “of the delicate fiduciary
nature of an investment advisory relationship” as well as a Congressional intent to eliminate, or at least expose, all conflicts of interest
which might incline an investment adviser, consciously or unconsciously, to render advice which was not disinterested. When selecting
a mutual fund for a client’s advisory account, the investment advisor representative has a fiduciary duty to select the share class that
helps manage the overall fee structure of the account.
Mutual Fund Fees and Other Fees and Expenses
The funds pay their investment managers and other service providers fees, which reduce the funds’ investment returns and are borne
proportionately by all fund shareholders, including clients of Drucker Wealth. These mutual fund fees, or “expense ratios,” are described
in the funds’ prospectuses, and are separate from and in addition to the fees charged by Drucker Wealth. Client assets are also held in
brokerage accounts which are subject to certain custodial fees; such as, checks returned or debit declines for insufficient funds as well
as a full transfer out fee and potential third-party service provider costs. These fees and expenses are further described in the brokerage
agreement.
Pontera Solutions Inc.
Fees are generally directly debited on a pro rata basis from client accounts. The exception for this is directly-managed held-away
accounts, such as 401(k)’s. Those fees will be assigned to the client’s taxable accounts on a pro-rata basis. If the client does not have a
taxable account, those fees will be billed directly to the client. Accounts initiated or terminated during a calendar quarter will be charged
a pro-rated fee based on the amount of time remaining in the billing period.
Payment of Fees and Termination
Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The
Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent.
Compensation for Selling Securities and Insurance Products
Drucker Wealth does not buy or sell securities for commission compensation. However, certain investment advisor representatives, in their
individual capacity as registered representatives of Purshe Kaplan Sterling Investments5 (“PKS”), can receive commission compensation
for selling securities.
5 Purshe Kaplan Sterling Investments (“PKS”) is a full-service broker/dealer and financial services firm headquartered in Albany, New
York. The Firm traces its roots to 1993 when it began as a regional brokerage firm. PKS has grown substantially over the past decade
and now has over 600 offices and more than 1,600 Registered Representatives operating in a classic open architecture environment.
PKS is registered with the U.S. Securities and Exchange Commission and is a member of FINRA and the Municipal Securities
Rulemaking Board. PKS clears its trades through National Financial Services LLC, offering state-of-the-art products and technology to
our Registered Representatives. In addition, PKS provides access to every major Investment Company, hundreds of Variable Annuity
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Disclosure Brochure
Commission rates differ from product to product and carrier to carrier. In addition to commissions, investment advisor representatives
can receive marketing support, reasonable meals and entertainment, and reimbursement of the cost to attend training, conferences, and
events hosted by insurance companies and third-party marketing organizations contracted with and receive compensation from the
insurance company. Insurance commissions and other benefits are significant sources of compensation and are paid separately from
advisory fees on assets in a client’s managed securities account. Commissions are generally paid up-front, at the time of sale, unlike
asset-based fees which are paid periodically over the course of the relationship. The amount and form of insurance compensation creates
a conflict of interest in that investment advisor representatives in their individual capacity as insurance agents are incentivized to
recommend insurance products based on the compensation received rather than on a client’s needs.
Investment advisor representatives in their individual capacity as insurance agents are not required to offer the products of a specific
insurance company. The compensation received from selling securities or insurance is separate from and does not offset regular advisory
fees. Although, Drucker Wealth will not charge advisory fees on any insurance products. Clients are under no obligation to implement
any recommendations and have the option to implement such recommendations through a different registered representative or insurance
agent.
Drucker Wealth addresses the conflict of interest related to selling securities and/or insurance products by requiring its investment
advisor representatives to always act in the best interest of the client.
Item 6 – Performance-Based Fees and Side-By-Side Management
Drucker Wealth does not charge performance-based fees for its investment advisory services - fees based on a share of capital gains or
capital appreciation of assets.
Item 7 – Types of Clients
The types of clients served by Drucker Wealth are generally pre-retirement individuals and high-net-worth individuals who are mid-
career professionals in the technology or medical industry or small business owners.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Drucker Wealth primarily employs fundamental and technical analysis in developing investment strategies for it clients. Research and
analysis from Drucker Wealth are derived from numerous sources, including unaffiliated third-party registered investment advisors,
financial media companies, third-party research materials, Internet sources, and reviews of company activities, including annual reports,
prospectuses, press releases, and research or market signals prepared by others.
Fundamental Analysis
Drucker Wealth attempts to measure the intrinsic value of a security by looking at economic and financial factors (including the overall
economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is
underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Drucker Wealth looks at historical
and present financial statements of the company, annual reports, governmental filings and business activities. Fundamental analysis
does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along
with the overall market regardless of the economic and financial factors considered in evaluating the stock. Individualized analysis of
underlying documentation can vary.
Technical Method of Investing
products and access to some of the top professional money managers in the country. PKS is committed to providing its Registered
Representatives with the freedom to offer clients a full spectrum of investment choices. PKS does not own investment products. The
absence of proprietary products coupled with unrestricted access to investment products provides our Registered Representatives with
the flexibility to help you achieve your investment objectives.
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Disclosure Brochure
The technical method of investing, also known as technical analysis, is an investment strategy that focuses on analyzing historical price
patterns, market trends, and trading volume data of an asset to make investment decisions. It is primarily concerned with studying charts
and using various technical indicators to identify potential buying or selling opportunities. Unlike fundamental analysis, which assesses
the intrinsic value of an asset, technical analysis aims to predict future price movements based on historical patterns and market behavior.
Tactical Method of Investing
The tactical method of investing refers to an investment strategy that involves actively adjusting a portfolio's asset allocation based on
short-term market conditions, economic trends, or other factors. Unlike a passive strategy that follows a long-term buy-and-hold
approach, tactical investing aims to capitalize on short-term opportunities and mitigate risks by making strategic allocation shifts.
Behavioral
Behavioral investing, often referenced within the broader realm of behavioral finance, examines how psychological and emotional
factors influence the investment decisions of individuals and institutions. It challenges the traditional finance paradigm, which assumes
that investors are always rational and markets are always efficient. Instead, behavioral investing posits that investors are often irrational
due to cognitive biases that can lead to systematic errors in decision making.
Cognitive Biases: These are systematic patterns of deviation from norm or rationality in judgment. Some common biases in
investing include: overestimating one's knowledge or abilities, focusing on and valuing information that confirms one’s pre-
existing beliefs, while ignoring contradictory evidence.
Recency Bias: Overemphasizing recent events or trends and extrapolating them into the future. For example, assuming that a
stock that has recently risen will continue to do so.
Loss Aversion: Feeling the pain of losses more acutely than the pleasure of gains. This can lead to holding onto losing
investments too long or selling winning investments too soon.
Anchoring: Relying heavily on an initial piece of information (the "anchor") when making subsequent judgments. For instance,
becoming anchored to the price at which one bought a stock and basing future decisions on it.
Emotional Factors: Emotions play a significant role in investment decisions. Fear and greed are two major emotional drivers:
that can cause investors to avoid necessary risks or sell assets hastily during market downturns.
Asset Allocation
Asset allocation is a key concept in investment management and refers to dividing investments among different asset classes. The primary
goal of asset allocation is to create a balanced portfolio that aligns with investment goals, risk tolerance, and time horizon.
Risk and Return Balance: Different asset classes (like stocks, bonds, and real estate) have varying levels of risk and expected
returns. By diversifying investments across multiple asset classes, you can potentially achieve a desired return while managing
risk.
Diversification Benefits: No single asset class consistently outperforms the others. Allocating resources across different assets
can reduce the impact of any one asset's poor performance on the overall portfolio.
Investment Goals: Asset allocation helps align your portfolio with your investment goals.
Risk Tolerance: This is a measure of your willingness and ability to withstand fluctuations in the value of your investments.
If you're risk-averse, you might lean more towards bonds and cash; if you're risk-tolerant, you might have a higher allocation
to stocks.
Time Horizon: The length of time you expect to keep your money invested. Longer horizons may allow for more aggressive
allocations since there's more time to recover from potential downturns.
Financial Goals: Whether you're saving for retirement, a home, or education can influence your allocation.
Current Financial Situation: Existing financial resources, debts, and other obligations can also influence decisions.
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Rebalancing: Over time, due to the varying returns of asset classes, a portfolio can drift from its target allocation. Rebalancing
involves adjusting the portfolio back to the desired allocation. This might mean selling some assets that have performed well
and buying more of those that have underperformed.
Strategic Asset Allocation: This involves setting and maintaining a long-term asset mix based on expected returns and risk
for each asset class.
Tactical Asset Allocation: Allows for short-term deviations from the strategic allocation to exploit market anomalies or
opportunities.
Investment Diversity
Investment diversity, more commonly referred to as "investment diversification," is a risk management strategy that mixes a wide variety
of investments within a portfolio. The rationale behind this approach is that a portfolio constructed of diverse investments will, on
average, yield higher returns and pose a lower risk than any individual investment found within the portfolio.
Risk Reduction: Diversification spreads investments across various assets or asset classes. This spread can reduce the negative
impact any single investment's poor performance might have on the overall portfolio.
Potential for Higher Returns: With investments spread across different areas, there's a possibility that at least one of them
might perform exceptionally well, thus boosting the portfolio's overall returns.
Asset Class Diversification: This involves spreading investments across different types of assets like stocks, bonds, real estate,
commodities, etc. Each asset class reacts differently to market events, providing a balancing effect.
Geographical/Regional Diversification: Investing in assets from different countries or regions. This minimizes risks
associated with downturns in any particular country or region's economy.
Sectoral Diversification: Investing across different industries or sectors, such as technology, healthcare, finance, etc. This
ensures that a downturn in one sector doesn't drag down the entire portfolio.
Diversification by Strategy: Implementing multiple investment strategies, such as growth, value, income, etc.
Time Diversification: Spreading out investments over various time horizons, often achieved through techniques like dollar-
cost averaging.
Risk of Loss
Investing in securities involves risk. Securities tend to fluctuate in value and can lose value. Clients should be prepared to bear the
potential risk of loss. Drucker Wealth will assist Clients in determining an appropriate strategy based on their investment objective and
tolerance for risk. However, there is no guarantee that a Client will meet their investment goals or assets will increase in value. Drucker
Wealth will rely on financial and other information provided by the Client or their designees without the duty or obligation to validate
the accuracy and completeness of the provided information. It is the responsibility of the Client to advise of any changes in financial
condition, goals or other factors.
The following are some of the general risks associated with investing that Clients should understand, consider and determine the amount
of risk they are able to accept prior to opening an account:
Business Risk: The measure of risk associated with a particular security. It is also known as unsystematic risk and refers to the
risk associated with a specific issuer of a security. Generally speaking, all businesses in the same industry have similar types of
business risk. More specifically, business risk refers to the possibility that the issuer of a particular company stock or a bond may
go bankrupt or be unable to pay the interest or principal in the case of bonds.
Call Risk: The risk specific to bond issues and refers to the possibility that a debt security will be called prior to maturity. Call
risk usually goes hand in hand with reinvestment risk because the bondholder must find an investment that provides the same level
of income for equal risk. Call risk is most prevalent when interest rates are falling, as companies trying to save money will usually
redeem bond issues with higher coupons and replace them on the bond market with issues with lower interest rates.
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Credit Risk: The risk that an investor could lose money if the issuer or guarantor of a fixed income security is unable or unwilling
to meet its financial obligations.
Currency/Exchange Rate Risk: The risk of a change in the price of one currency against another.
ETF Risks, including Net Asset Valuations and Tracking Error: ETF performance may not exactly match the performance of
the index or market benchmark that the ETF is designed to track because 1) the ETF will incur expenses and transaction costs not
incurred by any applicable index or market benchmark; 2) certain securities comprising the index or market benchmark tracked
by the ETF may, from time to time, temporarily be unavailable; and 3) supply and demand in the market for either the ETF and/or
for the securities held by the ETF may cause the ETF shares to trade at a premium or discount to the actual net asset value of the
securities owned by the ETF. Certain ETF strategies may from time to time include the purchase of fixed income, commodities,
foreign securities, American Depositary Receipts, or other securities for which expenses and commission rates could be higher
than normally charged for exchange-traded equity securities, and for which market quotations or valuation may be limited or
inaccurate. An ETF typically includes embedded expenses and related fees that reduce the fund's net asset value, and therefore
directly affect the fund's performance and indirectly affect a Program Account’s performance or an index benchmark comparison.
Expenses of an ETF generally include investment adviser management fees, custodian fees, brokerage commissions, and legal
and accounting fees. ETF expenses can change from time to time at the sole discretion of the ETF issuer. ETF tracking error and
expenses can vary.
Extraordinary Events: Terrorism and the United States’ involvement in armed conflict may negatively affect general economic
fortunes, including sales, profits, and production. An unstable geopolitical climate and continued threats of terrorism and war
could have a material effect on general economic conditions, market conditions, and market liquidity (i.e., depressed securities
prices and problems with trading facilities and infrastructure). Additionally, a serious pandemic or natural disaster could severely
disrupt the global, national, and/or regional economies. A resulting negative impact on economic fundamentals and consumer
confidence may increase the risk of default of particular companies and negatively impact our clients.
Inflationary Risk: The risk that future inflation will cause the purchasing power of cash flow from an investment to decline.
Interest Rate Risk: The risk that fixed income securities will decline in value because of an increase in interest rates; a bond or a
fixed income fund with a longer duration will be more sensitive to changes in interest rates.
Legislative Risk: The risk of a legislative ruling resulting in adverse consequences.
Liquidity Risk: The possibility that an investor may not be able to buy or sell an investment as and when desired or in sufficient
quantities because opportunities are limited.
Market Risk: The risk that the value of securities may go up or down, sometimes rapidly or unpredictably, due to factors affecting
securities markets generally or particular industries.
Mutual Fund Risks: A risk exists that the investment strategies employed by the mutual funds will not meet the stated investment
objectives the fund is seeking to obtain. Mutual funds may invest in equities, fixed income, derivatives, and other asset classes;
the risks associated with such investments are described in the fund’s prospectus. The performance of a mutual fund may not
exactly match the performance of the index or market benchmark that the fund is designed to track due to the mutual fund incurring
expenses and transaction costs not incurred by any applicable index or market benchmark. Expenses can change from time to time
at the sole discretion of the issuer and expenses can vary.
Pandemic Risk: Large-scale outbreaks of infectious disease that can greatly increase morbidity and mortality over a wide
geographic area, crossing international boundaries, and causing significant economic, social, and political disruption.
Reinvestment Risk: The risk that falling interest rates will lead to a decline in cash flow from an investment when its principal
and interest payments are reinvested at lower rates.
Social/Political: The possibility of nationalization, unfavorable government action or social changes resulting in a loss of value.
Taxability Risk: The risk that a security that was issued with tax-exempt status could potentially lose that status prior to maturity.
Since municipal bonds carry a lower interest rate than fully taxable bonds, the bond holders would end up with a lower after-tax
yield than originally planned.
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Types of Investments
There are different types of investments that involve varying degrees of risk, and it should not be assumed that future performance of any
specific investment or investment strategy will be profitable or equal any specific performance level(s). Past performance is not indicative
of future results. The types of investments typically used by Drucker Wealth include:
Mutual Funds: A pool of funds collected from many investors for the purpose of investing in securities such as stocks, bonds,
money market instruments and similar assets. An open-end mutual fund is a type of mutual fund that does not have restrictions on
the amount of shares the fund will issue and will buy back shares when investors wish to sell. Investing in mutual funds carries
the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment
returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. A closed-end mutual fund is a type
of mutual fund that raises a fixed amount of capital through an initial public offering (IPO). The fund is then structured, listed, and
traded like a stock on a stock exchange. Clients should be aware that closed-end funds available within the program are not readily
marketable. In an effort to provide investor liquidity, the funds may offer to repurchase a certain percentage of shares at net asset
value on a periodic basis. Thus, clients may be unable to liquidate all or a portion of their shares in these types of funds. Alternative
strategy mutual funds primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies
may not be suitable for all investors and involves special risks, such as risks associated with commodities, real estate, leverage,
selling securities short, the use of derivatives, potential adverse market forces, regulatory changes, and potential illiquidity. There
are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real
estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry.
Equity: Investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital
gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each
company, industry conditions and the general economic environment.
Exchange Traded Funds (ETFs): An ETF is a portfolio of securities invested to track a market index similar to an index
mutual fund, but the shares are traded on an exchange like an equity. An ETF share price fluctuates intraday depending on
market conditions instead of having a net asset value (NAV) that is calculated once at the end of the day. The shares may trade
at a premium or discount; and as a result, investors pay more or less when purchasing shares and receive more or less than
when selling shares. The supply of ETF shares is regulated through a mechanism known as creation and redemption that
involves large specialized investors, known as authorized participants (APs). Authorized participants are large financial
institutions with a high degree of buying power, such as market makers, banks or investment companies that provide market
liquidity. When there is a shortage of shares in the market, the authorized participant creates more (creation). Conversely, the
authorized participant will reduce shares in circulation (redemption) when supply falls short of demand. Multiple authorized
participants help improve the liquidity of a particular ETF and stabilize the share price. To the extent that authorized
participants cannot or are otherwise unwilling to engage in creation and redemption transactions, shares of an ETF tend to trade
at a significant discount or premium and may face trading halts and delisting from the exchange. The performance of ETFs is
subject to market risk, including the complete loss of principal. ETFs also have a trading risk based on cost inefficiency if the
ETFs are actively traded and a liquidity risk if the ETFs has a large price spread and low trading volume. In addition, investors
buying or selling shares in the secondary market pay brokerage commissions, which may be a significant proportional cost not
incurred by mutual funds.
Cash and Cash Equivalents: Cash is money in the form of currency, which includes all bills, coins, and currency notes. Cash
and cash equivalents refers to the line item on the balance sheet that reports the value of a company's assets that are cash or can be
converted into cash immediately. Cash equivalents include bank accounts and marketable securities, which are debt securities with
maturities of less than 90 days. Examples of cash equivalents include commercial paper, Treasury bills, and short-term
government bonds with a maturity date of three months or less. Marketable securities and money market holdings are considered
cash equivalents because they are liquid and not subject to material fluctuations in value.
Additional types of investments will be considered for asset allocation and risk management purposes.
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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 an advisory firm or the integrity of a firm’s management. Drucker Wealth has no information to disclose.
Item 10 – Other Financial Industry Activities and Affiliations
Broker-Dealer Affiliation
Certain Investment Advisor Representatives of Drucker Wealth are Registered Representatives of Purshe Kaplan Sterling Investments
(PKS), member FINRA/SIPC, and licensed insurance agents. As a result of these transactions, they receive commissions. A conflict of
interest exists as these commissionable sales create an incentive to recommend products based on the compensation earned. To mitigate
this potential conflict, our firm will act in the client’s best interest.
The individuals that are licensed as registered representatives are subject to regulations that restrict them from conducting securities
transactions away from PKS through other broker/dealers.
Insurance Agency Affiliations
Certain Investment Advisor Representatives are also a licensed insurance professional (agent). Insurance Agents earn commission
compensation for selling insurance products. Commissions generated by insurance sales do not offset regular advisory fees. This
represents a conflict of interest. Clients are under no obligation to implement any recommendations made.
Insurance Products Compensation
Certain Investment Advisor Representatives of Drucker Wealth are licensed as insurance agents, receive commissions and other
compensation from insurance companies and insurance intermediaries for the sale of insurance products. Commission rates differ from
product to product and carrier to carrier. In addition to commissions, its representatives can also receive marketing support, reasonable
meals and entertainment, and costs to attend training, conferences, and events hosted by insurance companies and third-party marketing
organizations that are contracted with and receive compensation from the insurance company. Insurance commissions and other benefits
are significant sources of compensation and are paid separately from advisory fees on assets in a client’s managed securities account.
Commissions are generally paid up-front, at the time of sale, unlike asset-based fees which are paid periodically over the course of the
relationship. This amount and form of insurance compensation creates a conflict of interest in that investment advisor representatives in
their individual capacity as insurance agents are incentivized to recommend insurance products based on the compensation received rather
than on a client’s needs.
Investment Advisor Representatives in their individual capacity of insurance agents are not required to offer the products of a specific
insurance company. Any compensation received is separate from, and does not offset regular advisory fees. Drucker Wealth will not charge
advisory fees on any insurance products. Clients are under no obligation to implement any recommendations, and have the option to
implement such recommendations through brokers or agents unaffiliated with Drucker Wealth.
Drucker Wealth addresses the conflict of interest related to insurance products sales by requiring its investment advisor representatives to
act in the best interest of the client, including when acting as insurance agents. Insurance-licensed investment advisor representatives
employ a process of analyzing each customer’s financial situation, needs, goals and risk profile for the purpose of making recommendations
that are based on an objective evaluation of each client’s best interest rather than on the receipt of any commissions or other benefits.
Loan Management Analytics & Credit Management
Drucker Wealth, through a partner program with Sora Finance, can offer clients the opportunity to explore secured and unsecured loans
with partnered banking institutions at potentially more favorable rates. Clients are under no obligation to accept the terms available through
Sora Finance and can elect to negotiate loan terms elsewhere. Drucker Wealth receives no compensation from Sora Finance.
While participation in the Sora Finance partnership program can be mutually beneficial for an existing or new debt obligation, the
compensation is a conflict of interest because it creates an incentive for Drucker Wealth to recommend financing through Sora Finance
rather than recommend a client withdraw invested assets. Interest and fees paid to Sora Finance’s lending partners in connection with a
loan are separate from and in addition to advisory fees paid to Drucker Wealth.
Conflicts of Interest
Conflicts of interests exist because securities and insurance sales create an incentive to recommend products based on the compensation
earned rather than the best interests of the Client. Such potential conflicts of interest are subject to review by the Chief Compliance Officer.
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Disclosure Brochure
This chart is intended to explain the potential capacity a Financial Advisor can serve, and the type of compensation received.
Capacity
Compensation
Investment Advisor Representatives
Advisory Fee
Registered Representative
Commissions
Insurance Agent
Commissions
Additional Registrations
Neither Drucker Wealth nor any of the management persons are registered or has a registration pending to register as a futures
commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. There
are no other relationships or arrangement material to the advisory business of Drucker Wealth that require disclosure.
Drucker Wealth can recommend and select other investment advisers and receive compensation directly or indirectly from those advisers
that create a material conflict of interest, which is mitigated by the fiduciary duty to only act in a client's best interest.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics
Drucker Wealth has implemented a Code of Ethics (the “Code”) pursuant to SEC rule 204A-1. A copy of our code of ethics will be
provided to any client or prospective client upon request. This Code applies to all persons associated with Drucker Wealth (“Covered
Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the
Client. Drucker Wealth and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation
of Drucker Wealth’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that
guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code,
please contact the Advisor at (212) 681-0460.
Personal Trading with Material Interest
Certain covered persons are considered “access” persons. An access person is a covered person who has access to nonpublic information
regarding the purchase or the sale of securities, is involved in making securities recommendations to clients or who has access to such
recommendations that are nonpublic. Drucker Wealth allows Access Persons to purchase or sell the same securities that may be
recommended to and purchased on behalf of Clients. Access persons must notify the Compliance Department of, and receive prior
approval for, opening accounts or holding personal securities and/or holdings. Access persons are required to provide duplicate
statements for review. Drucker Wealth does not act as principal in any transaction, act as the general partner of a fund, or advise an
investment company, have a material interest in any securities traded in Client accounts.
Personal Trading in Same Securities as Clients
Drucker Wealth allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf
of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as
fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the
Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and
personal securities reporting. When trading for personal accounts, Access Persons have a conflict of interest if trading in the same
securities but their fiduciary duty to act in the best interest of its Clients mitigates this conflict. This risk is further mitigated by requiring
reporting of personal securities trades by its Access Persons for review by the Chief Compliance Officer (“CCO”) or delegate.
Personal Trading at the Same Time as Client
While Drucker Wealth allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased
on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward. At no time will Drucker Wealth, or any
Supervised Person of Drucker Wealth, transact in any security to the detriment of any Client.
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Item 12 – Brokerage Practices
Broker/Dealer Recommendation
National Financial Services LLC, and Fidelity Brokerage Services LLC
Drucker Wealth will generally not allow advisory clients to determine the broker/dealer to use. Rather, Drucker Wealth will generally
require that clients establish brokerage accounts with National Financial Services LLC, and Fidelity Brokerage Services LLC (together
with all affiliates, "Fidelity") or Altruist Financial, LLC. Fidelity provides the Company with Fidelity's "platform" services. The platform
services include, among others, brokerage, custodial, trade execution, clearance, settlement of transactions, administrative support,
record keeping and related services that are intended to support intermediaries like the Company in conducting business and in serving
the best interests of their clients but that may benefit the Company.
Fidelity charges brokerage commissions and transaction fees for effecting certain securities transactions (i.e., transactions fees are
charged for certain no-load mutual funds, commissions are charged for individual equity and debt securities transactions). Fidelity
enables the Company to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction
charges. Fidelity's commission rates are generally considered discounted from customary retail commission rates. However, the
commissions and transaction fees charged by Fidelity may be higher or lower than those charged by other custodians and broker/dealers.
Some of these transaction fees are covered by the Company under its wrap program.
As part of the arrangement, Fidelity may also make available to the Company, at no additional charge, certain research and brokerage
services, including research services obtained by Fidelity directly from independent research companies, as selected by the Company
(within specified parameters). These research and brokerage services would be used by the Company to manage accounts for which it
has investment discretion. Services provided by Fidelity may include research (including mutual fund research, third-party research, and
Fidelity's proprietary research), brokerage, clearing, custody, and access to mutual funds and other investments that are available only
to institutional investors or would require a significantly higher minimum initial investment.
Research and brokerage services presently include access to a full array of proprietary and third-party investment offerings, spanning
alternatives, structured products, separately managed accounts and mutual funds; comprehensive technology integration, training and
support; Integrated Trust Services offering efficient, custody and clearing; business-building solutions ranging from marketing support
to client management tools; integrated charitable and foundation services through Fidelity Charitable Services; and leading retirement
programs and offerings to help the Company meet both the asset accumulation and income distribution needs of its clients. The Company
may also receive additional services from Fidelity. Without this arrangement, the Company might be compelled to purchase the same
or similar services at its own expense.
Drucker Wealth may be eligible for a specific schedule of fees based upon our assets under management with Fidelity. A client may pay
a commission that is higher than another qualified broker-dealer might charge to affect the same transaction where Drucker Wealth
determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received. In
seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative
execution, taking into consideration the full range of a broker-dealer's services, including the value of research provided, execution
capability, commission rates, and responsiveness. Accordingly, although Drucker Wealth will seek competitive rates, to the benefit of
all clients, it may not necessarily obtain the lowest possible commission rates for specific client account transactions. Although the
investment research products and services that may be obtained by Drucker Wealth will generally be used to service all of its clients, a
brokerage commission paid by a specific client may be used to pay for research that is not used in managing that specific client's account.
Drucker Wealth and Fidelity are not affiliates.
Altruist Financial, LLC
For the benefit of no commissions or transaction fees, fully digital account opening, a large variety of security options, and complete
integration with software tools, Drucker Wealth can also recommend Altruist Financial LLC.
Soft Dollars
Soft dollars refer to the practice where investment advisors receive research or other products and services from broker/dealers in
exchange for placing client trades with them. This is an arrangement that allows the advisor to use a portion of the brokerage
commissions generated by client trades to pay for services that benefit clients, such as research on investments. The concept of soft
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Disclosure Brochure
dollars can create a conflict of interest, as advisors might be incentivized to direct trades to broker/dealers offering these services,
potentially at the expense of achieving the best trade execution for clients.
Druker Wealth has soft dollar arrangements that create a conflict of interest. The receipt of soft dollars creates an incentive to use a
product or service that may not otherwise be in a client's best interest. This conflict of interest is mitigated by Drucker Wealth’s fiduciary
duty to always act in a client’s best interest.
Brokerage Referrals
Drucker Wealth does not receive any compensation from a third-party in connection with the recommendation for establishing an
account. By directing brokerage you may be unable to achieve the most favorable execution of client transactions, this practice may
cost clients more money.
Directed Brokerage
All Clients trades a directed to a broker/dealer determined by Drucker Wealth. Clients do not have the ability to direct trades to a
different broker/dealer. Drucker Wealth does not have any broker/dealer affiliates or other economic relationships that create a material
conflict of interest.
Aggregating and Allocating Trades
Drucker Wealth does not aggregate orders when securities are purchased or sold through the Custodian for multiple accounts on the same
trading day.
Best Execution
Drucker Wealth recognizes that the analysis of execution quality involves a number of qualitative and quantitative factors.
Consequently, Drucker Wealth 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 include, but are not limited, to the following:
The financial strength, reputation and stability of the broker-dealer;
The efficiency with which the transaction is effected; the ability to effect prompt and reliable executions
at favorable prices (including the applicable dealer spread or commission, if any);
The availability of the broker-dealer to stand ready to effect transactions of varying degrees of difficulty in the future;
The efficiency of error resolution, clearance and settlement;
Block trading and positioning capabilities;
Performance measurements;
Online access to computerized data regarding customer accounts;
Availability, comprehensiveness, and frequency of brokerage and research services;
Commission rate;
The economic benefit to the clients; and
Related matters involved in the receipt of brokerage services.
Trade Errors
Drucker Wealth has implemented procedures designed to prevent trade errors; however, trade errors in client accounts cannot always be
avoided. Consistent with its fiduciary duty, it is the policy of Drucker Wealth to correct trade errors in a manner that is in the best interest
of the client. In cases where the client causes the trade error, the client is responsible for any loss resulting from the correction. Depending
on the specific circumstances of the trade error, the client may not be able to receive any gains generated as a result of the error correction.
In all situations where the client does not cause the trade error, the client is made whole and any loss resulting from the trade error is
absorbed by Drucker Wealth if the error is caused by Drucker Wealth. If the error is caused by the broker/dealer, the broker/dealer is
responsible for handling the trade error. If an investment gain results from the correcting trade, the gain remains in the client’s account
unless the same error involved other client account(s) that should also receive the gains. It is not permissible for all clients to retain the
gain. Drucker Wealth may also confer with a client to determine if the client should forego the gain (e.g., due to tax reasons). Drucker
Wealth will never benefit or profit from trade errors.
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Cash Sweep Program
Investment portfolios often include a cash allocation to maintain liquidity, manage risk, and provide funds for opportunistic investments.
Cash allocations can serve as a buffer against market volatility and ensure that funds are readily available for future investment
opportunities or withdrawals. Sweep programs automatically transfer uninvested cash from a brokerage account into a money market
fund or other short-term investment vehicle at the custodian. This process is automated and occurs regularly, often at the end of each
business day. While the cash is held in the sweep account, it earns interest. This ensures that even idle cash is generating some return,
albeit typically lower than other investment options.
By automating the movement of cash, sweep programs reduce the need for manual transfers, saving time and minimizing the risk of
human error in managing cash balances. Sweep accounts provide quick access to cash for reinvestment or withdrawals, enhancing
liquidity management within the portfolio. Minimizing manual cash management tasks reduces administrative burdens for both the
investor and the advisor, allowing them to focus on strategic investment decisions.
Sweep programs often offer lower interest rates compared to other short-term investments like high-yield savings accounts or CDs. This
is due to the liquidity and convenience they provide. While convenient, the lower interest rates mean that investors can miss out on
higher returns if cash is kept in the sweep account for extended periods.
Advisor uses sweep programs strategically to manage cash flows within a portfolio, ensuring that cash is readily available for investment
opportunities without sacrificing significant returns. Sweep accounts can also be used to facilitate regular transactions, such as
automatic withdrawals for living expenses or periodic investments in other asset classes. While sweep programs offer convenience and
liquidity, they require careful consideration as part of an overall investment strategy. Advisors and clients should weigh the benefits of
liquidity and automation against the potential for higher returns through alternative cash management strategies.
Item 13 – Review of Accounts
Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by the Drucker Wealth Chief Compliance Officer of
Drucker Wealth. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client.
Causes for Reviews
Client accounts are reviewed at least annually and more frequently at a Client’s request. Accounts are reviewed as a result of major
changes in economic conditions, changes in financial situation, and/or based on large deposits or withdrawals. Clients are encouraged
to notify Drucker Wealth of such changes. Additional reviews can be triggered by material market, economic or political events.
Review Reports
Clients receive written statements no less than quarterly directly from the Custodian. The Client may establish electronic access to the
Custodian’s website so that they can view these reports and their account activity. Client statements will include all positions,
transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports during regular
meetings regarding their holdings, allocations, and performance that do not constitute official statements.
Item 14 – Client Referrals and Other Compensation
Drucker Wealth is a fee-based advisory firm, that is compensated by its Clients to provide investment advice and not from any investment
product or someone other than the Client. Advisor does not receive commissions or other economic benefit or compensation from
product sponsors, broker/dealers or any un-related third party.
Client Referrals from Solicitors
Drucker Wealth does not receive client referrals from a paid solicitor, also known as a promoter.
Money Managers and Product Sponsors
Investment advisor representatives will, on occasion, have an opportunity to attend a training event or participate in a due
diligence visit where the Money Manager or Product Sponsor will cover the associated travel expenses such as airfare, hotel
and meals. Training opportunities are often held at luxury resorts where amenities such as golf, spas and entertainment are
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Disclosure Brochure
provided. Such accommodations represent a conflict of interest that can influence the evaluation of the Money Manager or
Product sponsor based on factors other than the quality of services.
Additional Compensation
Drucker Wealth can receive an economic benefit for providing advisory services from sources other than the client. Economic
benefits include sales awards and gifts, an occasional meal, as well as entertainment such as a concert, show or sporting
event. Such compensation is not directly related to the advice or services provided to a particular client, but it does create a
conflict of interest that can influence the selection of services based on the compensation received.
Industry Professionals
When it is in the best interests of the client, Drucker Wealth can introduce the services of other professionals for certain non-
investment purposes (i.e. attorneys or accountants). Introductions represent a conflict of interest because they create a
relationship where the other professional has an implied obligation to introduce potential new clients to Drucker
Wealth. Clients are under no obligation to engage the services of any such professional. If the client engages any such
professional, and a dispute arises, any recourse will be exclusively from and against the engaged professional.
Conflicts of interest are mitigated by the fiduciary duty to always act in a client’s best interest and acting accordingly. Drucker Wealth
will seek independent counsel to evaluate conflicts as they arise and provide sufficient disclosure and controls which may include
declining to participate or proceed with an engagement.
Fidelity Brokerage and Custody Services
As disclosed in item 12 (Brokerage Practices) above, Drucker Wealth participates in Fidelity's institutional advisor program, and
will recommend Fidelity to clients for custody and brokerage services. There is no direct link between the Company's participation
in the program and the investment advice it gives to its clients, although the Company receives economic benefits through its
participation in the program that are typically not available to Fidelity retail investors.
Fidelity can make available to Drucker Wealth other products and services that benefit us, but that may not directly benefit our
clients' accounts, such as,
Provide access to client account data (such as trade confirmations and account statements);
Facilitate trade execution and allocate aggregated trade orders for multiple client accounts;
Provide research, pricing and other market data;
Facilitate payment of our fees from clients' accounts; and assist with back-office functions, record keeping and client
reporting;
Receipt of duplicate client statements and confirmations; and
The ability to have advisory fees deducted directly from our client's accounts.
Other services can be offered to help Drucker Wealth manage and further develop the business enterprise.
Altruist
Drucker Wealth can also recommend Altruist Financial for custody and brokerage services. There is no direct link between participation
in the program and the investment advice given to Clients, although Drucker Wealth can receive economic benefits through its
participation in programs typically not available to Altruist Financial retail investors.
The benefits received by Drucker Wealth do not depend on the amount of transactions directed to Altruist Financial. The receipt of such
services creates a conflict of interest that is mitigated by a fiduciary duty to always act in a Client’s best interest.
Item 15 – Custody
Drucker Wealth does not accept or maintain actual custody of funds or securities. A qualified custodian is responsible to provide Clients
with trade confirmations, tax forms and quarterly statements that include account balance(s). Clients are advised to carefully review the
information provided by the custodian and notify their Investment Advisor Representative with any questions or if such information is
not received.
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Disclosure Brochure
Item 16 – Investment Discretion
Drucker Wealth provides investment advisory services on a discretionary basis. Prior to assuming discretionary authority, the Client
grants permission by executing an Advisory Agreement, granting Drucker Wealth full authority to buy and/or sell the type and amount
of securities.
Item 17 – Voting Client Securities
Drucker Wealth does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the
Custodian. Drucker Wealth can assist in answering questions relating to proxies, however, the Client retains the sole responsibility for
proxy decisions and voting.
Clients will receive their proxies or other solicitations directly from their custodian or a transfer agent or from you, and discuss whether
(and, if so, how) clients can contact you with questions about a particular solicitation.
Item 18 – Financial Information
Neither Drucker Wealth nor its management, have any adverse financial situations that would reasonably impair the ability of Drucker
Wealth to meet all obligations to its Clients. Neither Drucker Wealth nor any of its Advisory Persons, have been subject to a bankruptcy
or financial compromise. Drucker Wealth is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor
does not collect advance fees of $1,200 or more for services to be performed six months or more in the future.
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Disclosure Brochure
Item 1 – Cover Page
Registered As: Drucker Wealth 3.0, LLC | DBA: Drucker Wealth | CRD No. 328909
Appendix 1 – Wrap Fee Program Brochure
September 25, 2025
This wrap fee program brochure provides information about the qualification and business practices of Advisor . If you have any
questions about the contents of this brochure, please contact us at Phone: (212) 681-0460 Fax: (419) 735-0158. 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 Advisor is also available on the SEC’s website at www.adviserinfo.sec.gov.
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Disclosure Brochure
Item 2 – Material Changes
Material Changes
Annually, a complete Disclosure Brochure will be offered to Clients along with a summary of material changes, if any, within 120 days
from the firm’s fiscal year-end.
At any time, the current Disclosure Brochure is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching the firm name or CRD number 328909. A copy of this Disclosure Brochure may be requested
at any time, by contacting (212) 681-0460.
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Disclosure Brochure
Item 3 – Table of Contents
Item 1 – Cover Page ……………………………………………………………………………..…..………………………….…….. 22
Item 2 – Material Changes ……………………………………………………………….…………………………….……….….…. 23
Item 3 – Table of Contents ……………………………………………..………………...................................................................... 24
Item 4 – Services, Fees and Compensation ……………………….………….………………….....…………………………….…... 25
Item 5 – Account Requirments and Types of Clients …………….………………………………………………………...…..….… 25
Item 6 – Portfolio Manager Selection and Evaluation ……………………………………...……………………………..….…..….. 25
Item 7 – Client Information Provided by Portfolio Managers ………….……………………….…..……………………….….….... 26
Item 8 – Client Contact with Portfolio Managers …………………………..………………………………………......….….…...… 26
Item 9 – Additional Information …………………………………………………………..….........................................................… 26
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Disclosure Brochure
Item 4 – Services Fees and Compensation
Services
Drucker Wealth can provide portfolio management services as a Wrap Fee Program, where the asset management fee and brokerage
transaction fees (ticket charges) are combined or “wrapped” into a single fee. For such accounts,Advisor is considered the Sponsor and
Portfolio Manager. This brochure is provided as an appendix to Form ADV 2A to desribe fee structure of a wrap fee program.
Other than the fee structure, the services offered in a wrap fee and a non-wrap fee account are identical. In either account type the total
fees are negotiable and paid to Advisor. A wrap fee program will generally have a higher asset management fee to account for the
additional cost of ticket charges paid by Advisor.
Program Costs
The fee structure that is in the client’s best interest depends on the type of positions held, anticipated frequency of trading and fee
payment preference. For example, a portfolio of primarily No Transaction Fee (NTFs) positions or an account with a low volume of
trading will generally not benefit from the higher asset management fee of a wrap fee account. Whereas an account that has positions
that include a ticket charge per transaction and there is an anticipated high degree of trading would likely benefit from a wrap fee
program.
A Wrap Fee program introduces a conflict of interest because it creates an incentive to limit the number of trades placed in the Client’s
account to reduce the ticket charges to the Advisor .
Fees
Investment advisory fees, not to exceed 1.25%. Fees are charged quarterly in advance based on the average daily account balance. Fees for
the initial or a partial quarter are charges on a pro-rata basis. Unearned fees will be refunded if the client terminates our services prior to
the quarter end. Unless other arrangements are made, fees are directly debited from a client’s account(s). The applicable fee is based on
several factors, including, the complexity of the services to be provided, the level of assets to be managed, and the overall relationship with
the Drucker Wealth. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions and other complexities
may be charged a higher fee.
Clients will incur certain fees or charges imposed by third parties in connection with investments made on behalf of the Client’s account[s].
In addition, all fees paid to Drucker Wealth for investment advisory services or part of the Wrap Fee Program are separate and distinct from
the expenses charged by mutual funds and exchange-traded funds to their shareholders, if applicable. These fees and expenses are described
in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses,
account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee.
The Client can also incur other costs assessed by the Custodian or other parties for account related activity fees, such as wire transfer fees,
fees for trades executed away from the Custodian and other fees. Drucker Wealth does not control nor share in these fees. The Client
should review both the fees charged by the fund[s] and the fees charged by Drucker Wealth to fully understand the total fees to be paid.
Compensation
Drucker Wealth receives investment advisory fees paid by Clients for participating in the Wrap Fee Program and pays the Custodian for
the costs associated with the normal trading activity in the Client’s account(s).
Item 5 – Account Requirements and Types of Clients
There are no other types of clients to disclose other than those listed in Item 7 of the preceding ADV 2A.
Item 6 – Portfolio Manager Selection and Evaluation
Portfolio Manager Selection
Drucker Wealth serves as sponsor and as portfolio manager for the services under this Wrap Fee Program.
Performance-Based Fees
Drucker Wealth does not charge performance-based fees.
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Disclosure Brochure
Proxy Voting
Drucker Wealth does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the
Custodian. Drucker Wealth can assist in answering questions relating to proxies, however, the Client retains the sole responsibility for
proxy decisions and voting.
Item 7 – Client Information Provided to Portfolio Managers
Drucker Wealth is the sponsor and sole portfolio manager for the Program. Drucker Wealth does not share Client information with
other portfolio managers because it is the sole portfolio manager for this Wrap Fee Program.
Item 8 – Client Contact with Portfolio Managers
Drucker Wealth is a full-service investment management advisory firm. Clients always have direct access to the Portfolio Managers at
Drucker Wealth.
Item 9 – Additional Information
Disciplinary Information
There is no information to disclose.
Other Financial Industry Activities and Affiliations
Item 10 of the ADV 2A provides complete information about Other Financial Industry Activities and Affiliations. There is no additional
information to disclose regarding a wrap fee program.
Code of Ethics
Item 11 of the ADV 2A provides complete information regarding the Code of Ethics. There is no additional information to disclose
regarding a wrap fee program.
Client Referrals and Other Compensation
Item 14 of the ADV 2A provides complete information regarding the client referrals and other compensation. There is no additional
information to disclose regarding a wrap fee program.
Financial Information
Item 18 of the ADV 2A provides complete information regarding financial information. There is no additional information to disclose
regarding a wrap fee program.
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Disclosure Brochure
Privacy Policy
Our Commitment to You
Drucker Wealth (“Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and
“your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our
most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to
maintain that trust. Drucker Wealth (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal
information we have and implements controls to ensure that such information is used for proper business purposes in connection with
the management or servicing of our relationship with you. Drucker Wealth does not sell your non-public personal information to
anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the
servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal
non-public information is collected and used are set forth in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal
and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your
personal information.
What information do we collect from you?
Driver’s license number
Date of birth
Social security or taxpayer identification number
Assets and liabilities
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Account applications and forms
Other advisory agreements and legal documents
Investment questionnaires and suitability documents
Transactional information with us or others
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use, we maintain physical, procedural and electronic security
measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology
vendors provide security and access control over personal information and have policies over the transmission of data. Our associates
are trained on their responsibilities to protect Client’s personal information.
We require third parties that assist in providing our services to you to protect the personal information they receive from us.
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Disclosure Brochure
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may
share your personal information.
Basis For Sharing
Do we share?
Can you limit?
Yes
No
limited
to: processing
Servicing our Clients - We may share non-public personal information with
affiliated and non-affiliated third parties (such as administrators, brokers,
custodians, regulators, credit agencies, other financial institutions) as necessary
for us to provide agreed upon services to you, consistent with applicable law,
including but not
transactions; general account
maintenance; responding to regulators or legal investigations; and credit reporting.
No
Not Shared
Marketing Purposes - Drucker Wealth does not disclose, and does not intend to
disclose, personal information with non-affiliated third parties to offer you
services. Certain laws may give us the right to share your personal information
with financial institutions where you are a customer and where Drucker Wealth or
the client has a formal agreement with the financial institution. We will only share
information for purposes of servicing your accounts, not for marketing purposes.
that we believe
Yes
Yes
Authorized Users - Your non-public personal information may be disclosed to
you and persons
to be your authorized agent[s] or
representative[s].
No
Not Shared
Information About Former Clients - Drucker Wealth does not disclose and does
not intend to disclose, non-public personal information to non-affiliated third
parties with respect to persons who are no longer our Clients.
Other Important State Specific Information
In response to Massachusetts law, the Client must “opt-in” to share non-public personal information with non-affiliated third
parties before any personal information is disclosed. Client opt-in is obtained through the Client’s execution of authorization
forms provided by the third parties, by executing an Information Sharing Authorization Form, or by other written consent by
the Client, as appropriate and consistent with applicable laws and regulations.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy, and will provide you with a revised Policy if the changes materially alter the previous Privacy
Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described
in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (212) 681-0460.
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Disclosure Brochure