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Harbour Wealth Management Group, Inc.
Form ADV Part 2A – Disclosure Brochure
Effective: January 29, 2026
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of Harbour Wealth Management Group, Inc. (“HWMG” or the “Advisor”). If you have any questions about
the content of this Disclosure Brochure, please contact the Advisor at 843-377-8448 or by email at
info@harbourwmg.com.
HWMG is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities
authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure
Brochure provides information about HWMG to assist you in determining whether to retain the Advisor.
Additional information about HWMG and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 314496.
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150
Daniel Island, SC 29492
www.harbourwealthmanagement.com
Item 2 – Material Changes
The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices
and conflicts of interest. HWMG believes that communication and transparency are the foundation of its relationship
with clients and will continually strive to provide you with complete and accurate information at all times. HWMG
encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may
have with the Advisor.
Material Changes
The following material changes have been made to this Disclosure Brochure since the annual amendment filing on
February 21th, 2025:
• The Advisor has appointed Christopher L. Corley as the Chief Compliance Officer. Please see Item 4 for
additional information.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure
Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 314496. You
may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at 843-377-8448 or by
email at info@harbourwmg.com.
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 2
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 .................................................................................................................................... 5
A. Firm Information .............................................................................................................................................................. 5
B. Advisory Services Offered ............................................................................................................................................... 5
C. Client Account Management ........................................................................................................................................... 7
D. Wrap Fee Programs ........................................................................................................................................................ 7
E. Assets Under Management ............................................................................................................................................. 7
Item 5 – Fees and Compensation ......................................................................................................................... 7
A. Fees for Advisory Services.............................................................................................................................................. 7
B. Fee Billing........................................................................................................................................................................ 8
C. Other Fees and Expenses .............................................................................................................................................. 9
D. Advance Payment of Fees and Termination ................................................................................................................... 9
E. Compensation for Sales of Securities ........................................................................................................................... 10
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
A. Methods of Analysis ...................................................................................................................................................... 10
B. Risk of Loss ................................................................................................................................................................... 11
Item 9 – Disciplinary Information ........................................................................................................................ 12
Item 10 – Other Financial Industry Activities and Affiliations .......................................................................... 12
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 13
A. Code of Ethics ............................................................................................................................................................... 13
B. Personal Trading with Material Interest ......................................................................................................................... 13
C. Personal Trading in Same Securities as Clients ........................................................................................................... 13
D. Personal Trading at Same Time as Client .................................................................................................................... 13
Item 12 – Brokerage Practices ............................................................................................................................ 13
A. Recommendation of Custodian[s] ................................................................................................................................. 13
B. Aggregating and Allocating Trades ............................................................................................................................... 14
Item 13 – Review of Accounts ............................................................................................................................. 14
A. Frequency of Reviews ................................................................................................................................................... 14
B. Causes for Reviews ...................................................................................................................................................... 14
C. Review Reports ............................................................................................................................................................. 15
Item 14 – Client Referrals and Other Compensation ........................................................................................ 15
A. Compensation Received by HWMG ............................................................................................................................. 15
B. Compensation for Client Referrals ................................................................................................................................ 15
Item 15 – Custody ................................................................................................................................................. 15
Item 16 – Investment Discretion ......................................................................................................................... 16
Item 17 – Voting Client Securities ....................................................................................................................... 16
Item 18 – Financial Information ........................................................................................................................... 16
Form ADV Part 2A – Appendix 1 ......................................................................................................................... 17
Item 2 – Material Changes ................................................................................................................................... 18
Item 3 – Table of Contents ................................................................................................................................... 18
Item 4 – Services Fees and Compensation ........................................................................................................ 19
Item 5 – Account Requirements and Types of Clients ..................................................................................... 20
Item 6 – Portfolio Manager Selection and Evaluation ....................................................................................... 20
Item 7 – Client Information Provided to Portfolio Managers ............................................................................ 22
Item 8 – Client Contact with Portfolio Managers ............................................................................................... 22
Item 9 – Additional Information ........................................................................................................................... 22
Form ADV Part 2B – Brochure Supplement ....................................................................................................... 24
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 3
Item 2 – Educational Background and Business Experience .......................................................................... 25
Item 3 – Disciplinary Information ........................................................................................................................ 26
Item 4 – Other Business Activities ..................................................................................................................... 27
Item 5 – Additional Compensation ..................................................................................................................... 27
Item 6 – Supervision ............................................................................................................................................ 27
Form ADV Part 2B – Brochure Supplement ....................................................................................................... 28
Item 2 – Educational Background and Business Experience .......................................................................... 29
Item 3 – Disciplinary Information ........................................................................................................................ 29
Item 4 – Other Business Activities ..................................................................................................................... 29
Item 5 – Additional Compensation ..................................................................................................................... 30
Item 6 – Supervision ............................................................................................................................................ 30
Form ADV Part 2B – Brochure Supplement ....................................................................................................... 31
Item 2 – Educational Background and Business Experience .......................................................................... 32
Item 3 – Disciplinary Information ........................................................................................................................ 32
Item 4 – Other Business Activities ..................................................................................................................... 32
Item 5 – Additional Compensation ..................................................................................................................... 32
Item 6 – Supervision ............................................................................................................................................ 33
Privacy Policy ....................................................................................................................................................... 34
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 4
Item 4 – Advisory Services
A. Firm Information
Harbour Wealth Management Group, Inc. (“HWMG” or the “Advisor”) is a registered investment advisor with the
U.S. Securities and Exchange Commission. The Advisor is organized as a Corporation under the laws of the State
of South Carolina. HWMG was founded in March 2021 and is owned and operated by Matthew Pardieck (Managing
Principal) and Christopher Corley (Managing Director and Chief Compliance Officer). This Disclosure Brochure
provides information regarding the qualifications, business practices, and the advisory services provided by
HWMG.
B. Advisory Services Offered
HWMG offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses,
charitable organizations, and retirement plans (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. HWMG's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more
information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
Investment Management Services
HWMG provides customized investment management services for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management services in
connection with a broad range of comprehensive financial planning services. HWMG works closely with each Client
to identify their investment goals, objectives, risk tolerance and financial situation in order to create a portfolio
strategy utilizing one of the Advisor’s model portfolios or independent managers. The Advisor’s model portfolios
primarily consist of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”). The Advisor may also
utilize individual stocks, bonds, options contracts, or independent managers to meet the needs of its Clients. The
Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio
strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client.
HWMG’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. HWMG will construct, implement and monitor the portfolio to ensure it meets the goals, objectives,
circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable
restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
HWMG evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. HWMG may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. HWMG may recommend specific positions to increase sector or asset class weightings. The Advisor may
recommend employing cash positions as a possible hedge against market movement. HWMG may recommend
selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or
sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in
the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed
unacceptable for the Client’s risk tolerance.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the
assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account
to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 5
increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a
retirement account to an account managed by the Advisor.
At no time will HWMG accept or maintain custody of a Client’s funds or securities, except for the limited authority as
outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian,
pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Financial Planning Services
HWMG will typically provide financial planning services as part of its investment management services described
above. HWMG may also provide standalone financial planning and consulting services to Clients, pursuant to a
written financial planning agreement. For standalone financial planning, services may be offered on a project-based
engagement or annual ongoing engagement. Generally, such financial planning services involve preparing a formal
financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This
planning or consulting may encompass one or more areas of need, including but not limited to, investment
planning, retirement planning, personal savings, education savings, insurance needs, business succession
planning and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
HWMG may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s
financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may
not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date,
assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for
investment management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to
act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
Use of Independent Managers
HWMG may recommend that Clients utilize one or more unaffiliated investment managers or investment platforms
(collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s
needs and objectives. In certain instances, the Client may be required to authorize and enter into an investment
management agreement with the Independent Manager[s] that defines the terms in which the Independent
Manager[s] will provide its services. The Advisor will perform initial and ongoing oversight and due diligence over
each Independent Manager to ensure the strategy remains aligned with Client’s investment objectives and overall
best interests. The Advisor will also assist the Client in the development of the initial portfolio recommendations and
managing the ongoing Client relationship. The Client, prior to entering into an agreement with an Independent
Manager, will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure
that makes the appropriate disclosures).
Retirement Plan Advisory Services
HWMG provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the
company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan
Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized
to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 6
Investment Policy Statement (“IPS”) Design and Monitoring
Investment Oversight Services (ERISA 3(21))
•
•
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
• Benchmarking Services
These services are provided by the Advisor serving in the capacity as a fiduciary under the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan
Sponsor is provided with a written description of the Advisor’s fiduciary status, the specific services to be rendered
and all direct and indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging HWMG to provide investment advisory services, each Client is required to enter into one or more
agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the
Client. These services may include:
• Establishing an Investment Strategy – HWMG, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s goals and objectives.
• Asset Allocation – HWMG will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
•
Investment Management and Supervision – HWMG will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
HWMG includes the securities transaction fees and custodial costs (herein “Covered Costs”) together with its
investment advisory fees. Including these fees into a single asset-based fee is considered a “Wrap Fee Program”.
The Advisor customizes its investment management services for its Clients. The Advisor sponsors the HWMG
Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees. Depending on the level
of trading required for the Client’s account[s] in a particular year, the Client may pay more or less in total fees than
if the Client paid its own securities transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure, which
is included as a supplement to this Disclosure Brochure.
E. Assets Under Management
As of December 31, 2024, HWMG manages approximately $191,288,183 in Client assets, $159,605,963 of which
are managed on a discretionary basis and $31,682,220 on a non-discretionary basis. Clients may request more
current information at any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one more
written agreement with the Advisor.
A. Fees for Advisory Services
Investment Management Services
Investment advisory fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the
investment advisory agreement. Investment advisory fees are based on the market value of assets under
management at the end of the prior quarter. Investment advisory fees range up to 1.50% annually based on several
factors, including: the scope and complexity of the services to be provided; the level of assets to be managed; and the
overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio
restrictions and other complexities may be charged a higher fee.
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 7
The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the
end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into
consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by
HWMG will be independently valued by the Custodian. HWMG will conduct periodic reviews of the Custodian’s
valuation to ensure accurate billing.
Financial Planning Services
For standalone financial planning services, HWMG offers services on an hourly and fixed fee basis. Hourly fees
range up to $500 per hour. Fixed fees range up to $50,000 annually. Fees may be negotiable based on the nature
and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours
and/or total costs will be provided to the Client prior to engaging for these services.
Use of Independent Managers
As noted in Item 4, the Advisor will implement all or a portion of a Client’s investment portfolio utilizing one or more
Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an
Independent Manager. The Advisor will only earn its investment advisory fee as described above. Independent
Managers typically do not offer any fee discounts but may have a breakpoint schedule which will reduce the fee
with an increased level of assets placed under management with an Independent Manager. The terms of such fee
arrangements are included in the Independent Manager’s disclosure brochure and applicable contract[s] with the
Independent Manager. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will
not exceed 2.00% annually.
Retirement Plan Advisory Services
Retirement plan advisory fees are paid quarterly in advance, pursuant to the terms of the retirement plan advisory
agreement. Retirement plan advisory fees are based on the market value of assets in the Plan at the end of the
prior quarter. Fees for retirement plan advisory services are charged an annual asset-based fee up to 1.00%. Fees
may be negotiable depending on the size and complexity of the Plan.
B. Fee Billing
Investment Management Services
Investment advisory fees are calculated by the Advisor and deducted from the Client’s account[s] at the Custodian.
The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s
account[s] at the beginning of the respective quarter. The amount due is calculated by applying the quarterly rate
(annual rate divided by 4) to the total assets under management with HWMG at the end of the prior quarter. Clients
will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory
fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage statement
from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization
permitting advisory fees to be deducted by HWMG to be paid directly from their account[s] held by the Custodian as
part of the investment advisory agreement and separate account forms provided by the Custodian.
Financial Planning Services
Financial planning fees for project-based engagements may be invoiced up to fifty percent (50%) of the expected total
fee upon execution of the financial planning agreement. The balance shall be invoiced upon completion of the agreed
upon deliverable[s].
Use of Independent Managers
For Client accounts implemented through an Independent Manager, the Client’s overall fee will include the
Advisor’s investment advisory fee (as noted above) plus investment management fees and/or platform fees
charged by the Independent Manager. The Independent Manager will assume the responsibility for calculating the
Client’s fees and deducting all fees from the Client’s account[s].
Retirement Plan Advisory Services
Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the
Plan, depending on the terms of the retirement plan advisory agreement.
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 8
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties in connection with investments made on behalf
of the Client’s account[s]. HWMG includes Covered Costs as part of its overall investment advisory fee through the
HWMG Wrap Fee Program. Securities transaction fees for Client-directed trades may be charged back to the
Client. Please see Item 4.D. above as well as Appendix 1 – Wrap Fee Program Brochure.
In addition, all fees paid to HWMG for investment advisory services are separate and distinct from the expenses
charged by mutual funds and ETFs 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. A Client may be able to invest in these products directly, without the services of HWMG, but would
not receive the services provided by HWMG which are designed, among other things, to assist the Client in
determining which products or services are most appropriate for each Client’s financial situation and objectives.
Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by HWMG to fully
understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information.
The Client acknowledges and accepts that if they fail to respond to any requests within a reasonable time, as
determined by the Advisor in its sole discretion, the Advisor may charge the Client an additional fee of up to $200 per
occurrence for any repeated administrative work necessitated by the Client's lack of timely response. Such additional
fees shall be due and payable by the Client in accordance with the payment terms set forth in this Agreement.
D. Advance Payment of Fees and Termination
Investment Management Services
HWMG may be compensated for its investment management services in advance of the quarter in which services are
rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written
notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business
days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges
for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the
Client. Upon termination, the Advisor will refund any unearned, prepaid investment advisory fees from the effective
date of termination to the end of the quarter. The Client’s investment advisory agreement with the Advisor is non-
transferable without the Client’s prior consent.
Financial Planning Services
For standalone financial planning services, HWMG requires an advance deposit as described above. Either party
may terminate the financial planning agreement, at any time, by providing advance written notice to the other party.
The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s
agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory
services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination of
a project-based engagement, the Client shall be billed for actual hours logged on the planning project times the
contractual hourly rate. Upon termination, the Advisor will refund any unearned, prepaid planning fees from the
effective date of termination. The Client’s financial planning agreement with the Advisor is non-transferable without the
Client’s prior consent.
Use of Independent Managers
HWMG will have the discretion to terminate the relationship with Independent Managers if determined that an
Independent Manager is no longer in the Client’s best interest. The terms for termination are set forth in the
respective agreements between the Advisor and Independent Managers.
Retirement Plan Advisory Services
HWMG is compensated for its retirement plan advisory services in advance of the quarter in which services are
rendered. Either party may terminate the retirement plan advisory agreement, at any time, by providing advance
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 9
written notice to the other party. The Client may also terminate the retirement plan advisory agreement within five
(5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client
will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and
payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid investment advisory fees from
the effective date of termination to the end of the quarter. The Client’s retirement plan advisory agreement with the
Advisor is non-transferable without the Client’s prior consent.
E. Compensation for Sales of Securities
HWMG does not buy or sell securities to earn commissions and does not receive any compensation for securities
transactions in any Client account, other than the investment advisory fees noted above.
Certain Advisory Persons are also licensed as independent insurance professionals. As an independent insurance
professional, an Advisory Person will earn commission-based compensation for selling insurance products,
including insurance products sold to Clients. Insurance commissions earned by an Advisory Person are separate
and in addition to advisory fees charged by the Advisor. This practice presents a conflict of interest as an Advisory
Person, who is also an insurance agent, has an incentive to recommend insurance products to Clients. However,
Clients are under no obligation, contractually or otherwise, to purchase insurance products through any Advisory
Person affiliated with the Advisor. Please see Item 10 below.
Advisory Persons of HWMG are also Registered Representatives of M Holdings Securities, Inc. (“M Securities”), a
securities broker-dealer, and a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities
Investor Protection Corporation (“SIPC”). In one’s separate capacity as a Registered Representative of M
Securities, an Advisory Person will offer you variable insurance products through their separate capacity as a
registered representative and will earn commission-based compensation for transactions implemented through M
Securities. Compensation earned by an Advisory Person in one’s capacity as a Registered Representative is
separate and in addition to HWMG’s advisory fees. This practice presents a conflict of interest because Advisory
Persons who are Registered Representatives may have an incentive to recommend that you implement insurance
transactions through M Securities for the purpose of generating commissions rather than solely based on your
needs. The Advisor mitigates this conflict as Clients are under no obligation, contractually or otherwise, to
implement insurance transactions through one of our Advisory Persons. Please see Item 10 – Other Financial
Industry Activities and Affiliations.
Item 6 – Performance-Based Fees and Side-By-Side Management
HWMG does not charge performance-based fees for its investment advisory services. The fees charged by HWMG
are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by
any Client.
HWMG does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a
hedge fund) and has no financial incentive to recommend any particular investment options to its Clients.
Item 7 – Types of Clients
HWMG offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses,
charitable organizations, and retirement plans. The amount of each type of Client is available on HWMG’s Form
ADV Part 1A. These amounts may change over time and are updated at least annually by the Advisor. HWMG
generally requires a minimum relationship size of $1,000,000, which can be waived at the Advisor’s sole discretion.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
HWMG primarily employs a fundamental method in developing investment strategies for its Clients. Research and
analysis from HWMG are derived from numerous sources, including financial media companies, third-party
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 10
research materials, Internet sources, and review of company activities, including annual reports, prospectuses,
press releases and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria
consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being
analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with
a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment,
it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in
the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors
these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the
Advisor’s review process are included below in Item 13 – Review of Accounts.
As noted above, HWMG generally employs a long-term investment strategy for its Clients, as consistent with their
financial goals. HWMG will typically hold all or a portion of a security for more than a year, but may hold for shorter
periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, HWMG may also
buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the
fundamentals of the security, sector or asset class.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. HWMG will assist Clients in determining an appropriate
strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a
Client will meet their investment goals.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the
investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may
lose value and may have negative investment performance. The Advisor monitors these economic indicators to
determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are
included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the 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 inform the Advisor of any changes in financial condition, goals or
other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts.
The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction
process. Following are some of the risks associated with the Advisor’s investment strategies:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs
will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk
based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-
ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may
dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased
or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later.
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 11
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the
mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual
fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same
price as a mutual fund purchased later that same day.
Bond Risks
Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall
if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon
rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than
was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that
exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk
associated with purchasing a debt instrument which includes the possibility of the company defaulting on its
repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the
company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity
Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond.
Options Contracts
Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts
are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock.
This leverage can compound gains or losses.
Past performance is not a guarantee of future returns. Investing in securities and other investments involve
a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss
these risks with the Advisor.
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving HWMG or its management persons. HWMG
values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence
on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons
are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with
the Advisor’s firm name or CRD# 314496.
Item 10 – Other Financial Industry Activities and Affiliations
Use of Independent Managers
As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio with one or more
Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an
Independent Manager. The Advisor will only earn its investment advisory fee as described in Item 5.A. However,
the Independent Manager will calculate and deduct a single, overall fee from the Client’s account[s] at the
Custodian and remit the appropriate amount to the Advisor. All fees will be fully disclosed to the Client.
Broker-Dealer Affiliation
As noted in Item 5, Advisory Persons of HWMG are also Registered Representatives of M Securities. In an
Advisory Person’s separate capacity as a Registered Representative, an Advisory Person will receive commissions
for the implementation of recommendations for commissionable transactions. Clients are not obligated to
implement any recommendation provided by an Advisory Person of HWMG. Neither HWMG nor its Advisory
Persons will earn ongoing investment advisory fees in connection with any services implemented in an Advisory
Person’s separate capacity as a Registered Representative. Under supervision by M Securities, M Securities may
have access to certain confidential information of the Client, including, but not limited to financial information,
investment objectives, transactions and holdings information. Please see our Privacy Policy, which is included with
this Disclosure Brochure.
Insurance Agency Affiliations
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 12
As noted in Item 5, certain Advisory Persons are also licensed insurance professionals. Implementations of
insurance recommendations are separate and apart from one’s role with the Advisor. As an insurance professional,
an Advisory Person will receive customary commissions and other related revenues from the various insurance
companies whose products are sold. Advisory Persons are not required to offer the products of any particular
insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice
presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no
obligation to implement any recommendations made by an Advisory Person or the Advisor.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
HWMG has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each
Client. This Code applies to all persons associated with HWMG (“Supervised Persons”). The Code was developed
to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. HWMG
and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of
HWMG’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 843-377-8448 or via email at
info@harbourwmg.com.
B. Personal Trading with Material Interest
HWMG allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. HWMG does not act as principal in any transactions. In addition, the Advisor does
not act as the general partner of a fund or advise an investment company. HWMG does not have a material interest
in any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
HWMG 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, Supervised Persons have a conflict of interest if trading in the same securities. The
fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more
advantageous terms than Client trades, or by trading based on material non-public information. This risk is
mitigated by HWMG requiring reporting of personal securities trades by conducting a coordinated review of
personal accounts and the accounts of the Clients. The Advisor has also adopted written policies and procedures to
detect the misuse of material, non-public information.
D. Personal Trading at Same Time as Client
While HWMG 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 afterwards. At no
time will HWMG, or any Supervised Person of HWMG, transact in any security to the detriment of any
Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
HWMG does not have discretionary authority to select the broker-dealer/custodian for custody and execution
services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets
and authorize HWMG to direct trades to the Custodian as agreed upon in the investment advisory agreement.
Further, HWMG does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-
by-trade basis.
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 13
Where HWMG does not exercise discretion over the selection of the Custodian, it may recommend the Custodian
to Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will
not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by HWMG.
However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged.
HWMG may recommend the Custodian based on criteria such as, but not limited to, reasonableness of
commissions charged to the Client, services made available to the Client, and its reputation and/or the location of
the Custodian’s offices.
HWMG will generally recommend that Clients establish their account[s] at Raymond James & Associates, Inc.
(“Raymond James”), member New York Stock Exchange/SIPC. Raymond James will serve as the Client’s
“qualified custodian”. The Advisor maintains an institutional relationship with Raymond James, whereby the Advisor
receives economic benefits from Raymond James. Please see Item 14 below.
As Registered Representatives of M Securities, the Advisor may be limited in using other broker-dealers/custodians
as M Securities must approve the use of any outside broker-dealer/custodian.
Following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor
enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and
other services. HWMG does not participate in soft dollar programs sponsored or offered by any broker-
dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see
Item 14 below.
2. Brokerage Referrals - HWMG does not receive any compensation from any third party in connection with the
recommendation for establishing an account.
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where HWMG will place trades
within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded
within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any
security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a
security into one Client account from another Client’s account[s]). HWMG will not be obligated to select competitive
bids on securities transactions and does not have an obligation to seek the lowest available transaction costs.
These costs are determined by the Custodian.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results considering such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4)
confidentiality and 5) skill required of the Custodian. HWMG will execute its transactions through the Custodian as
authorized by the Client. HWMG may aggregate orders in a block trade or trades when securities are purchased or
sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be
executed in full at the same price or time, the securities purchased or sold by the close of each business day must
be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be
done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons and periodically
reviewed by Christopher L. Corley, Chief Compliance Officer of HWMG. Formal reviews are generally conducted at
least annually or more frequently depending on the needs of the Client.
B. Causes for Reviews
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 14
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least
annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result
of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or
withdrawals in the Client’s account[s]. The Client is encouraged to notify HWMG if changes occur in the Client’s
personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be
triggered by material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage
statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the
Custodian’s website so that the Client may view these reports and their account activity. Client brokerage
statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also
provide Clients with periodic reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by HWMG
HWMG is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment product.
HWMG does not receive commissions or other compensation from product sponsors, broker-dealers or any un-
related third party. HWMG may refer Clients to various unaffiliated, non-advisory professionals (e.g., attorneys,
accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise,
HWMG may receive non-compensated referrals of new Clients from various third-parties.
Participation in Institutional Advisor Platform
HWMG has established an institutional relationship with Raymond James to assist the Advisor in managing Client
account[s]. Access to the Raymond James platform is provided at no charge to the Advisor. The Advisor receives
access to software and related support without cost because the Advisor renders investment management services
to Clients that maintain assets at Raymond James. The software and related systems support may benefit the
Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the
interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a
Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this
Custodian over one that does not furnish similar software, systems support, or services.
Additionally, the Advisor has the following benefits from Raymond James: financing services, receipt of duplicate
Client confirmations and bundled duplicate statements; access to a trading desk that exclusively services its
institutional participants; access to block trading which provides the ability to aggregate securities transactions and
then allocate the appropriate shares to Client accounts; and access to an electronic communication network for
Client order entry and account information.
B. Compensation for Client Referrals
The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for
Client referrals.
Item 15 – Custody
HWMG does not accept or maintain custody of Client accounts, except for the limited circumstances outlined
below:
Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction of
advisory fees, all Clients for whom HWMG exercises discretionary authority must hold their assets with a "qualified
custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and securities and
must instruct HWMG to utilize that Custodian for securities transactions on their behalf. Clients are encouraged to
review statements provided by the Custodian and compare to any reports provided by HWMG to ensure accuracy,
as the Custodian does not perform this review.
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 15
Money Movement Authorization - For instances where Clients authorize HWMG to move funds between their
accounts, HWMG and the Custodian have implemented safeguards to ensure that all money movement activities
are conducted strictly in accordance with the Client’s documented instructions.
Item 16 – Investment Discretion
HWMG generally has discretion over the selection and amount of securities to be bought or sold in Client accounts
without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to
specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by
HWMG. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such
authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable
limitations to such authority. All discretionary trades made by HWMG will be in accordance with each Client's
investment objectives and goals.
In certain circumstances, HWMG may not have discretion over the selection and amount of securities to be bought
or sold in Client accounts without obtaining prior approval from the Client. The Advisor will contact the Client and
obtain approval prior to executing trades or allocating investment assets.
Item 17 – Voting Client Securities
HWMG does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from
the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the
sole responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither HWMG, nor its management, have any adverse financial situations that would reasonably impair the ability
of HWMG to meet all obligations to its Clients. Neither HWMG, nor any of its Advisory Persons, have been subject
to a bankruptcy or financial compromise. HWMG 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.
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 16
Form ADV Part 2A – Appendix 1
(“Wrap Fee Program Brochure”)
Effective: January 29, 2026
This Form ADV2A - Appendix 1 (“Wrap Fee Program Brochure”) provides information about the qualifications and
business practices for Harbour Wealth Management Group, Inc. (“HWMG” or the “Advisor”) services when offering
services pursuant to a wrap program. This Wrap Fee Program Brochure shall always be accompanied by the
HWMG Disclosure Brochure, which provides complete details on the business practices of the Advisor. If you did
not receive the complete HWMG Disclosure Brochure or you have any questions about the contents of this Wrap
Fee Program Brochure or the HWMG Disclosure Brochure, please contact the Advisor at 843-377-8448 or by email
at info@harbourwmg.com.
HWMG is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Wrap Fee Program Brochure has not been approved or verified by the SEC or by any state
securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This
Wrap Fee Program Brochure provides information about HWMG to assist you in determining whether to retain the
Advisor.
Additional information about HWMG and its advisory persons are available on the SEC’s website at
www.adviserinfo.sec.gov by searching for our firm name or by our CRD# 314496.
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 17
Item 2 – Material Changes
Form ADV 2A - Appendix 1 provides information about a variety of topics relating to an Advisor’s business practices
and conflicts of interest. In particular, this Wrap Fee Program Brochure discusses Wrap Fee Programs offering by
the Advisor.
Material Changes
There have been no material changes to this Wrap Fee Program Brochure since the last filing and distribution to
Clients.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure
Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 314496. You
may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at 843-377-8448 or by
email at info@harbourwmg.com.
Item 3 – Table of Contents
Form ADV Part 2A – Appendix 1 ("Wrap Fee Program Brochure") ................................................................. 17
Item 2 – Material Changes ................................................................................................................................... 18
Item 3 – Table of Contents ................................................................................................................................... 18
Item 4 – Services Fees and Compensation ........................................................................................................ 19
Item 5 – Account Requirements and Types of Clients ..................................................................................... 20
Item 6 – Portfolio Manager Selection and Evaluation ....................................................................................... 20
Item 7 – Client Information Provided to Portfolio Managers ............................................................................ 22
Item 8 – Client Contact with Portfolio Managers ............................................................................................... 22
Item 9 – Additional Information ........................................................................................................................... 22
Privacy Policy ............................................................................................................. Error! Bookmark not defined.
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 18
Item 4 – Services Fees and Compensation
A. Services
HWMG provides customized investment advisory services for its Clients. This Wrap Fee Program Brochure is
provided as a supplement to the HWMG Disclosure Brochure (Form ADV 2A). This Wrap Fee Program Brochure is
provided along with the complete Disclosure Brochure to provide full details of the business practices and fees
when selecting HWMG as your investment advisor.
As part of the investment advisory fees noted in Item 5 of the Disclosure Brochure, HWMG includes the securities
transaction fees and custodial costs (herein “Covered Costs”) as part of the overall investment advisory fee.
Securities regulations often refer to this combined fee structure as a “Wrap Fee Program”. The Advisor’s
recommended Custodian does not charge securities transaction fees for exchange-traded fund (“ETF”) and equity
trades in Client accounts, but typically charges for mutual funds and other types of investments. The Advisor
sponsors the HWMG Wrap Fee Program.
The sole purpose of this Wrap Fee Program Brochure is to provide additional disclosure relating the combination of
Covered Costs into a single “bundled” investment advisory fee. This Wrap Fee Program Brochure references back
to the HWMG Disclosure Brochure in which this Wrap Fee Program Brochure serves as an Appendix. Please see
Item 4 – Advisory Services of the Disclosure Brochure for details on HWMG’s investment philosophy and
related services.
B. Program Costs
Advisory services provided by HWMG are offered in a wrap fee structure whereby Covered Costs are included in
the overall investment advisory fee paid to HWMG. As the level of activity in a Client’s account[s] may vary from
year to year, the annual cost to the Client may be more or less than engaging for advisory services where the
Covered Costs are borne separately by the Client. The cost of the Wrap Fee Program varies depending on services
to be provided to each Client, however, the Client is not charged more if there is higher trading activity or other
Covered Costs. A Wrap Fee structure presents a conflict of interest as the Advisor is incentivized to limit the
number of trades placed in the Client’s account[s] or to utilize securities that do not have transaction fees. As noted
above, the Advisor’s recommended Custodian does not charge securities transaction fees for ETF and equity
trades in Client accounts, but typically charges for mutual funds and other types of investments. As such, the
Advisor is incentivized to utilize ETFs and other equity securities to limit the overall cost to the Advisor. The Advisor
will only place Client assets into a Wrap Fee Program when it is believed to be in the Client’s best interest. Please
see Item 5 – Fees and Compensation of the Disclosure Brochure for complete details on fees.
C. Fees
Investment advisory fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the
investment advisory agreement. Investment advisory fees are based on the market value of assets under
management at the end of the prior quarter. Investment advisory fees range up to 1.50% annually based on several
factors, including: the scope and complexity of the services to be provided; the level of assets to be managed; and the
overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio
restrictions and other complexities may be charged a higher fee.
The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the
end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into
consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by
HWMG will be independently valued by the Custodian. HWMG will conduct periodic reviews of the Custodian’s
valuations..
As noted above, the Wrap Fee Program includes Covered Costs incurred in connection with the discretionary
investment management services provided by HWMG, as part of its overall investment advisory fee. Securities
transaction fees for Client-directed trades may be charged back to the Client. Clients may incur certain fees or
charges imposed by third parties in connection with investments made on behalf of the Client’s account[s]. Under this
Wrap Fee Program, HWMG includes securities transactions costs as part of its overall investment advisory fee.
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 19
Investment advisory fees are calculated by the Advisor and deducted from the Client’s account[s] at the Custodian.
The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s
account[s] at the beginning of the respective quarter. The amount due is calculated by applying the quarterly rate
(annual rate divided by 4) to the total assets under management with HWMG at the end of the prior quarter. Clients
will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory
fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage statement
from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization
permitting advisory fees to be deducted by HWMG to be paid directly from their account[s] held by the Custodian as
part of the investment advisory agreement and separate account forms provided by the Custodian.
In addition, all fees paid to HWMG 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. Securities transaction fees for Client-directed
trades will be charged back to the Client. In connection with the discretionary investment management services
provided by HWMG, the Client will incur other costs assessed by the Custodian or other third parties, other than the
Covered Costs noted above, such as [wire transfer fees, fees for trades executed away from the Custodian and
other fees].The Advisor 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 HWMG to fully understand the total fees to be paid. Please see Item 5.C. – Other
Fees and Expenses in the Disclosure Brochure (included with this Wrap Fee Program Brochure).
D. Compensation
HWMG is the sponsor and portfolio manager of this Wrap Fee Program. HWMG receives investment advisory fees
paid by Clients for participating in the Wrap Fee Program and pays the Covered Costs associated with the
management of the Client’s account[s].
Item 5 – Account Requirements and Types of Clients
HWMG offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses,
charitable organizations, and retirement plans. HWMG generally imposes a minimum relationship size of
$1,000,000, which can be waived at the sole discretion of the Advisor. Please see Item 7 – Types of Clients in the
Disclosure Brochure for additional information.
Item 6 – Portfolio Manager Selection and Evaluation
Portfolio Manager Selection
HWMG serves as sponsor and as portfolio manager for the services under this Wrap Fee Program.
Related Persons
HWMG personnel serve as portfolio managers for this Wrap Fee Program.
Performance-Based Fees
HWMG does not charge performance-based fees for its investment advisory services. The fees charged by HWMG
are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by
any Client.
Supervised Persons
HWMG Advisory Persons serve as portfolio managers for all accounts, including the services described in this
Wrap Fee Program Brochure. Details of the advisory services provided are included in Item 4.A. of the Disclosure
Brochure.
Methods of Analysis
Please see Item 8 of the Disclosure Brochure (included with this Wrap Fee Program Brochure) for details on the
research and analysis methods employed by the Advisor.
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 20
Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. HWMG will assist Clients in determining an appropriate
strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a
Client will meet their investment goals.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the
investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may
lose value and may have negative investment performance. The Advisor monitors these economic indicators to
determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are
included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the 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 inform the Advisor of any changes in financial condition, goals or
other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts.
The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction
process. Following are some of the risks associated with the Advisor’s investment strategies:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs
will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk
based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-
ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may
dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased
or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the
mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual
fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same
price as a mutual fund purchased later that same day.
Bond Risks
Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall
if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon
rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than
was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that
exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk
associated with purchasing a debt instrument which includes the possibility of the company defaulting on its
repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the
company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity
Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond.
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 21
Options Contracts
Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts
are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock.
This leverage can compound gains or losses.
Past performance is not a guarantee of future returns. Investing in securities and other investments involve
a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss
these risks with the Advisor. Please see Item 8.B. – Risk of Loss in the Disclosure Brochure for details on
investment risks.
Proxy Voting
HWMG does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from
the Custodian. The Advisor will 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
HWMG is the sponsor and sole portfolio manager for the Program. The Advisor does not share Client information
with other portfolio managers because it is the sole portfolio manager for this Wrap Fee Program. Please also see
the HWMG Privacy Policy (included after this Wrap Fee Program Brochure).
Item 8 – Client Contact with Portfolio Managers
HWMG is a full-service investment management advisory firm. Clients always have direct access to the Portfolio
Managers at HWMG.
Item 9 – Additional Information
A. Disciplinary Information and Other Financial Industry Activities and Affiliations
There are no legal, regulatory or disciplinary events involving HWMG or its management persons. HWMG
values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence
on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons
are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with
the Advisor’s firm name or CRD# 314496.
Please see Item 9 of the HWMG Disclosure Brochure as well as Item 3 of each Advisory Person’s Brochure
Supplement (included with this Wrap Fee Program Brochure) for additional information on how to research the
background of the Advisor and its Advisory Persons.
Other Financial Activities and Affiliations
Please see Items 10 and 14 of the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Program
Brochure).
B. Code of Ethics, Review of Accounts, Client Referrals, and Financial Information
HWMG has implemented a Code of Ethics that defines our fiduciary commitment to each Client. This Code of
Ethics applies to all persons subject to HWMG’s compliance program (our “Supervised Persons”). Complete details
on the HWMG Code of Ethics can be found under Item 11 – Code of Ethics, Participation in Client Transactions
and Personal Trading in the Disclosure Brochure (included with this Wrap Fee Program Brochure).
Review of Accounts
Investments in Client accounts are monitored on a regular and continuous basis by Advisory Persons of HWMG
under the supervision of Christopher Corley, Chief Compliance Officer (“CCO”). Details of the review policies and
practices are provided in Item 13 of the Form ADV Part 2A – Disclosure Brochure.
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 22
Other Compensation
HWMG has established an institutional relationship with Raymond James to assist the Advisor in managing Client
account[s]. Access to the Raymond James platform is provided at no charge to the Advisor. The Advisor receives
access to software and related support without cost because the Advisor renders investment management services
to Clients that maintain assets at Raymond James. The software and related systems support may benefit the
Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the
interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a
Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this
Custodian over one that does not furnish similar software, systems support, or services.
Additionally, the Advisor has the following benefits from Raymond James: financing services, receipt of duplicate
Client confirmations and bundled duplicate statements; access to a trading desk that exclusively services its
institutional participants; access to block trading which provides the ability to aggregate securities transactions and
then allocate the appropriate shares to Client accounts; and access to an electronic communication network for
Client order entry and account information.
Please see Item 14 – Other Compensation in the Form ADV Part 2A – Disclosure Brochure (included with this
Wrap Fee Program Brochure) for details on additional compensation that may be received by HWMG or its
Advisory Persons. Each Advisory Person’s Brochure Supplement (also included with this Wrap Fee Program
Brochure) provides details on any outside business activities and the associated compensation.
Compensation for Client Referrals
The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for
Client referrals.
Financial Information
Neither HWMG, nor its management, have any adverse financial situations that would reasonably impair the ability
of HWMG to meet all obligations to its Clients. Neither HWMG, nor any of its Advisory Persons, have been subject
to a bankruptcy or financial compromise. HWMG 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.
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 23
Form ADV Part 2B – Brochure Supplement
for
Matthew D. Pardieck CIMA®, CFP®, ChFC®, CLU®
Managing Principal
Effective: January 29, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Matthew D. Pardieck CIMA®, CFP®, ChFC®, CLU® (CRD# 2625967) in addition to the information contained in the
Harbour Wealth Management Group, Inc. (“HWMG” or the “Advisor”, CRD# 314496) Disclosure Brochure. If you
have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the HWMG
Disclosure Brochure or this Brochure Supplement, please contact the Advisor at 843-377-8448 or by email at
info@harbourwmg.com.
Additional information about Mr. Pardieck is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2625967.
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 24
Item 2 – Educational Background and Business Experience
Matthew D. Pardieck, CIMA®, CFP®, ChFC®, CLU® born in 1969, is dedicated to advising Clients of HWMG as the
Managing Principal. Mr. Pardieck earned a Bachelors of Science in Aeronautical / Aerospace Engineering from
Purdue University in 1991. Additional information regarding Mr. Pardieck’s employment history is included below.
Employment History:
08/2021 to Present
10/2021 to Present
02/2012 to 07/2021
03/2005 to 02/2012
Managing Principal, Harbour Wealth Management Group, Inc.
Registered Representative, M Holdings Securities, Inc.
1st Vice President, Wealth Management, Raymond James & Associates, Inc.
Wealth Management Advisor/Associate Resident Director, Merrill Lynch, Pierce,
Fenner & Smith Inc
Consultant, Palmer & Cay Securities Corporation
Consultant, Atlantic Strategic Business Planning/Wealth Preservation Group
Agent/Registered Representative, Northwestern Mutual Life Insurance Company
02/2001 to 02/2005
10/1997 to 02/2001
07/1995 to 10/1997
Certified Investment Management Analyst™ (“CIMA®”)
The CIMA® certification signifies that an individual has met initial and ongoing experience, ethical, education, and
examination requirements for investment management consulting, including advanced investment management
theory and application. To earn CIMA® certification, candidates must: submit an application, pass a background
check and have an acceptable regulatory history; pass an online Qualification Examination; complete an in-person
or online executive education program at an AACSB® accredited university business school; pass an online
Certification Examination; and have an acceptable regulatory history as evidenced by FINRA Form U-4 or other
regulatory requirements and have three years of financial services experience at the time of certification.
CIMA® certificates must adhere to IMCA’s Code of Professional Responsibility, Standards of Practice, and Rules
and Guidelines for Use of the Marks. CIMA® designees must report 40 hours of continuing education credits,
including two ethics hours every two years to maintain the certification. The designation is administered through the
Investment Management Consultants Association™ (IMCA®).
CERTIFIED FINANCIAL PLANNER™ (“CFP®”)
The CERTIFIED FINANCIAL PLANNER™, CFP®, and federally registered CFP® (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by CERTIFIED
FINANCIAL PLANNER™ Board of Standards, Inc. (“CFP® Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to
hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high
standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical
requirements that govern professional engagements with clients. Currently, more than 87,000 individuals have
obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
• Education – Complete an advanced college-level course of study addressing the financial planning subject
areas that CFP Board’s studies have determined as necessary for the competent and professional delivery
of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States
college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject
areas include insurance planning and risk management, employee benefits planning, investment planning,
income tax planning, retirement planning, and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case
studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues
and apply one’s knowledge of financial planning to real-world circumstances;
• Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 25
Individuals who become certified must complete the following ongoing education and ethics requirements in order
to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards
prominently require that CFP® professionals provide financial planning services at a fiduciary standard of
care. This means CFP® professionals must provide financial planning services in the best interests of their
clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s
enforcement process, which could result in suspension or permanent revocation of their CFP®.
Chartered Financial Consultant™ (“ChFC®”)
The Chartered Financial Consultant™ (ChFC®) program prepares you to meet the advanced financial planning
needs of individuals, professionals, and small business owners. You'll gain a sustainable advantage in this
competitive field with in-depth coverage of the key financial planning disciplines, including insurance, income
taxation, retirement planning, investments, and estate planning. The ChFC® requires three years of full-time,
relevant business experience, nine two-hour course-specific proctored exams, and 30 hours of continuing
education every two years. Holders of the ChFC® designation must adhere to The American College’s Code of
Ethics.
Program Objectives:
• Function as an ethical, competent and articulate practitioner in the field of financial planning
• Utilize the intellectual tools and framework needed to maintain relevant and current financial planning
knowledge and strategies.
• Apply financial planning theory and techniques through the development of case studies and solutions.
• Apply in-depth knowledge in a holistic manner from a variety of disciplines, namely, estate planning,
retirement planning, or non-qualified deferred compensation.
The Chartered Life Underwriter™ (“CLU®”)
The Chartered Life Underwriter™ (CLU®) is a designation of insurance expertise, helping gain a significant
advantage in a competitive market. This course of study helps by providing in-depth knowledge of the insurance
needs of individuals, business owners, and professional clients.
Program Learning Objectives:
• Provide guidance to clients on types and amounts of life insurance needed
• Make recommendations on aspects of risk management, including personal and business uses of a variety
of insurance solutions
• Provide guidance to clients on legal aspects of life insurance contracts and beneficiaries
• Assist clients in making decisions about estate planning, including the proper holding of assets and title to
assets, as well as the implications of various wills and trust arrangements on financial, retirement and
succession planning issues
• Provide a holistic and comprehensive approach to addressing the insurance planning needs of their clients
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Pardieck. Mr. Pardieck has never
been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Mr. Pardieck.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 26
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Pardieck.
However, we do encourage you to independently view the background of Mr. Pardieck on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
2625967.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mr. Pardieck is a licensed insurance professional. Implementations of insurance recommendations are separate
and apart from Mr. Pardieck’s role with HWMG. As an insurance professional, Mr. Pardieck will receive customary
commissions and other related revenues from the various insurance companies whose products are sold. Mr.
Pardieck is not required to offer the products of any particular insurance company. Commissions generated by
insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending
certain products of the insurance companies. Clients are under no obligation to implement any recommendations
made by Mr. Pardieck or the Advisor. Mr. Pardieck spends approximately 5% of his time per month in this capacity.
Broker-Dealer Affiliation
Mr. Pardieck is also a Registered Representative of M Holdings Securities, Inc. (“M Securities”), M Securities is a
registered broker-dealer (CRD# 43285), member FINRA, SIPC. In Mr. Pardieck‘s separate capacity as a
Registered Representative, Mr. Pardieck will receive commissions for the implementation of recommendations for
commissionable transactions. Clients are not obligated to implement any recommendation provided by Mr.
Pardieck. Neither the Advisor nor Mr. Pardieck will earn ongoing investment advisory fees in connection with any
products or services implemented in Mr. Pardieck‘s separate capacity as a Registered Representative. Mr.
Pardieck spends approximately 10% of business time per month in his role as a Registered Representative of M
Securities.
Harbour Wealth Management Group Real Estate, LLC
Mr. Pardieck is also a managing director of Harbour Wealth Management Group Real Estate, LLC (“HWMRE,
LLC”). In his role as a managing director, Mr. Pardieck leases office space to Harbour Wealth Management Group,
Inc. Mr. Pardieck spends less than 5% of his time per month in this capacity.
Mr. Pardieck also serves as a Board Member for the Jazz Artists of Charleston. Mr. Pardieck devotes
approximately 3 hours per month providing guidance and leadership to the musical nonprofit and assists with
fundraising.
Mr. Pardieck is also an Author for the Bottom Line of Happiness book series. Mr. Pardieck devotes approximately 5
hours per month toward book sales and speaking on behalf of the book.
Item 5 – Additional Compensation
Mr. Pardieck has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Pardieck serves as the Managing Principal of HWMG and is supervised by Christopher Corley, the Chief
Compliance Officer. Mr. Corley can be reached at 843-377-8448.
HWMG has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person
in meeting their fiduciary obligations to Clients of HWMG. Further, HWMG is subject to regulatory oversight by
various agencies. These agencies require registration by HWMG and its Supervised Persons. As a registered
entity, HWMG is subject to examinations by regulators, which may be announced or unannounced. HWMG is
required to periodically update the information provided to these agencies and to provide various reports regarding
the business activities and assets of the Advisor.
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 27
Form ADV Part 2B – Brochure Supplement
for
Christopher L. Corley, AIF®, CFPA®, MBA
Managing Director and Chief Compliance Officer
Effective: January 29, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Christopher L. Corley (CRD# 5140415) in addition to the information contained in the Harbour Wealth Management
Group, Inc. (“HWMG” or the “Advisor”, CRD# 314496) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the HWMG Disclosure Brochure or this
Brochure Supplement, please contact the Advisor at 843-377-8448 or by email at info@harbourwmg.com.
Additional information about Mr. Corley is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5140415.
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 28
Item 2 – Educational Background and Business Experience
Christopher L. Corley, born in 1974, is dedicated to advising Clients of HWMG as the Managing Director and Chief
Compliance Officer. Mr. Corley earned a Masters of Business from The Citadel in 2003. Mr. Corley also earned a
Bachelor of Arts from Wofford College in 1998. Additional information regarding Mr. Corley’s employment history is
included below.
Employment History:
08/2021 to Present
Managing Director and Chief Compliance Officer, Harbour Wealth Management
Group, Inc.
Registered Representative, M Holdings Securities, Inc.
Financial Advisor, Raymond James & Associates, Inc.
Financial Advisor, Merrill Lynch, Pierce, Fenner & Smith Inc
10/2021 to Present
02/2012 to 07/2021
04/2006 to 02/2012
Accredited Investment Fiduciary™ (“AIF®”)
The AIF® mark is held by the Center for Fiduciary Studies, LLC, a Fiduciary360 (fi360) company.
The professional designations awarded by fi360 demonstrate the focus on all the components of a comprehensive
investment process, related fiduciary standards of care, and commitment to excellence. AIF® designees undergo an
initial training program, annual continuing education, and pledge to abide by the designation’s code of ethics.
Since October 2002, the Accredited Investment Fiduciary™ (AIF®) designation has been the mark of commitment
to a standard of fiduciary investment excellence. Those who earn the AIF® mark successfully complete a
specialized program on investment fiduciary standards of care and subsequently passed a comprehensive
examination. AIF® designees demonstrate a thorough understanding of fi360’s Prudent Practices for investment
advisors and stewards.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Corley. Mr. Corley has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Mr. Corley.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Corley.
However, we do encourage you to independently view the background of Mr. Corley on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
5140415.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mr. Corley is a licensed insurance professional. Implementations of insurance recommendations are separate and
apart from Mr. Corley’s role with HWMG. As an insurance professional, Mr. Corley will receive customary
commissions and other related revenues from the various insurance companies whose products are sold. Mr.
Corley is not required to offer the products of any particular insurance company. Commissions generated by
insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending
certain products of the insurance companies. Clients are under no obligation to implement any recommendations
made by Mr. Corley or the Advisor. Mr. Corley spends approximately 5% of his time per month in this capacity.
Broker-Dealer Affiliation
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 29
Mr. Corley is also a Registered Representative of M Holdings Securities, Inc. (“M Securities”), M Securities is a
registered broker-dealer (CRD# 43285), member FINRA, SIPC. In Mr. Corley‘s separate capacity as a Registered
Representative, Mr. Corley will receive commissions for the implementation of recommendations for
commissionable transactions. Clients are not obligated to implement any recommendation provided by Mr. Corley.
Neither the Advisor nor Mr. Corley will earn ongoing investment advisory fees in connection with any products or
services implemented in Mr. Corley‘s separate capacity as a Registered Representative. Mr. Corley spends
approximately 10% of business time per month in his role as a Registered Representative of M Securities.
Harbour Wealth Management Group Real Estate, LLC
Mr. Corley is also a managing director of Harbour Wealth Management Group Real Estate, LLC (“HWMRE, LLC”).
In his role as a managing director, Mr. Corley leases office space to Harbour Wealth Management Group, Inc. Mr.
Corley spends less than 5% of his time per month in this capacity.
My. Corley also serves as a Member for the Town of Awendaw Board of Zoning Appeals. Mr. Corley devotes
approximately 1 hour per month granting or denying requests for zoning appeals.
Item 5 – Additional Compensation
Mr. Corley has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Corley serves as the Managing Director and Chief Compliance Officer of HWMG. Mr. Corley can be reached at
843-377-8470. HWMG has implemented a Code of Ethics, an internal compliance document that guides each
Supervised Person in meeting their fiduciary obligations to Clients of HWMG. Further, HWMG is subject to
regulatory oversight by various agencies. These agencies require registration by HWMG and its Supervised
Persons. As a registered entity, HWMG is subject to examinations by regulators, which may be announced or
unannounced. HWMG is required to periodically update the information provided to these agencies and to provide
various reports regarding the business activities and assets of the Advisor.
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 30
Form ADV Part 2B – Brochure Supplement
for
Martha L. Clark
Wealth Advisor
Effective: January 29, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Martha
L. Clark (CRD# 7831369) in addition to the information contained in the Harbour Wealth Management Group, Inc.
(“HWMG” or the “Advisor”, CRD# 314496) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the HWMG Disclosure Brochure or this Brochure
Supplement, please contact us at 843-377-8448 or by email at info@harbourwmg.com.
Additional information about Ms. Clark is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 7831369.
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 31
Item 2 – Educational Background and Business Experience
Martha L. Clark, born in 2000, is dedicated to advising Clients of HWMG as a Wealth Advisor. Ms. Clark earned a
Bachelor of Science in Mathematics from Sewanee: The University of the South in 2023. Additional information
regarding Ms. Clark’s employment history is included below.
Employment History:
Wealth Advisor, Harbour Wealth Management Group, Inc.
Registered Representative, M Holdings Securities, Inc.
Camp Counselor, Monteagle Sunday School Assembly
Server, Lumiere
Teacher’s Aide, New Covenant Presbyterian Weekday School
Server/Cook, Shenanigans
Data Intern, Sewanee Data Institute
10/2023 to Present
03/2024 to Present
06/2023 to 08/2023
03/2023 to 06/2023
06/2018 to 07/2022
01/2022 to 04/2022
06/2021 to 12/2021
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Ms. Clark. Ms. Clark has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Ms. Clark.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud;
false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or
extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or
disciplinary events to disclose regarding Ms. Clark.
However, we do encourage you to independently view the background of Ms. Clark on the Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 7831369.
Item 4 – Other Business Activities
Broker-Dealer Affiliation
Ms. Clark is also a registered representative of M Holdings Securities, Inc. (“M Holdings”). M Holdings is a registered
broker-dealer (CRD# 43285), member FINRA, SIPC. In Ms. Clark’s separate capacity as a registered representative,
Ms. Clark will receive commissions for the implementation of recommendations for commissionable transactions.
Clients are not obligated to implement any recommendation provided by Ms. Clark. Neither the Advisor nor Ms. Clark
will earn ongoing investment advisory fees in connection with any products or services implemented in Ms. Clark’s
separate capacity as a registered representative. Ms. Clark spends approximately 10% of her time per month in her
role as a registered representative of M Holdings.
Insurance Agency Affiliations
Ms. Clark is also a licensed insurance professional. Implementations of insurance recommendations are separate
and apart from Ms. Clark’s role with HWMG. As an insurance professional, Ms. Clark will receive customary
commissions and other related revenues from the various insurance companies whose products are sold. Ms. Clark
is not required to offer the products of any particular insurance company. Commissions generated by insurance sales
do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of
the insurance companies. Clients are under no obligation to implement any recommendations made by Ms. Clark or
the Advisor. Ms. Clark spends approximately 5% of her time per month in this capacity.
Item 5 – Additional Compensation
Ms. Clark has additional business activities where compensation is received that are detailed in Item 4 above.
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 32
Item 6 – Supervision
Ms. Clark serves as a Wealth Advisor of HWMG and is supervised by Christopher Corley, the Chief Compliance
Officer. Mr. Corley can be reached at 843-377-8448.
HWMG has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in
meeting their fiduciary obligations to Clients of HWMG. Further, HWMG is subject to regulatory oversight by various
agencies. These agencies require registration by HWMG and its Supervised Persons. As a registered entity, HWMG
is subject to examinations by regulators, which may be announced or unannounced. HWMG is required to periodically
update the information provided to these agencies and to provide various reports regarding the business activities
and assets of the Advisor.
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 33
Privacy Policy
Effective: January 29, 2026
Our Commitment to You
Harbour Wealth Management Group, Inc. (“HWMG” or the “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. HWMG (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.
HWMG 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
Other advisory agreements and legal documents
Transactional information with us or others
Account applications and forms
Investment questionnaires and suitability
documents
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.
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 34
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
No
Not Shared
Yes
Yes
No
Not Shared
Servicing our Clients
We may share non-public personal information with 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 limited to: processing transactions; general account maintenance;
responding to regulators or legal investigations; and credit reporting.
HWMG shares Client information with M Holdings Securities, Inc. (“M
Securities”) due to the oversight M Securities has over Supervised
Persons of the Advisor. You may also contact us at any time for a copy of
the M Securities’ Privacy Policy.
Marketing Purposes
HWMG 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 HWMG 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.
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent[s] or
representative[s].
Information About Former Clients
HWMG 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.
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 843-377-8448 or via email at info@harbourwmg.com.
Harbour Wealth Management Group, Inc.
126 Seven Farms Drive, Ste 150, Daniel Island, SC 29492
Phone: 843-377-8448
www.harbourwealthmanagement.com
Page 35