Overview
- Headquarters
- Mt. Pleasant, SC
- Average Client Assets
- $3.8 million
- SEC CRD Number
- 129475
Fee Structure
Primary Fee Schedule (JP WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.00% |
| $1,000,001 | $6,000,000 | 0.75% |
| $6,000,001 | $10,000,000 | 0.50% |
| $10,000,001 | and above | 0.40% |
Minimum Annual Fee: $10,000
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $40,000 | 0.80% |
| $10 million | $67,500 | 0.68% |
| $50 million | $227,500 | 0.46% |
| $100 million | $427,500 | 0.43% |
Clients
- HNW Share of Firm Assets
- 98.60%
- Total Client Accounts
- 263
- Discretionary Accounts
- 263
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Investment Advisor Selection
Regulatory Filings
Primary Brochure: JP WEALTH MANAGEMENT, LLC DISCLOSURE BROCHURE (2026-03-30)
View Document Text
Disclosure Brochure
Disclosure Brochure
March 25, 2026
JP Wealth Management Inc.
a Registered Investment Adviser
3401 Salterbeck Court, Suite 202
Mt. Pleasant, SC 29466
(866) 562-6969
www.jpwm.com
Tis brochure provides information about the qualifications and business practices of JP Wealth Management Inc.
(hereinafter “JPWM”). If you have any questions about the contents of this brochure, please contact John F. Carey at
(866) 562-6969. The information in this brochure has not been approved or verified by the United States Securities and
Exchange Commission or by any state securities authority. Additional information about JP Wealth Management Inc. is
available on the SEC’s website at www.adviserinfo.sec.gov.
JP Wealth Management Inc. is an SEC registered investment adviser. Registration does not imply any level of skill or
training.
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Disclosure Brochure
Item 2. Material Changes
In this Item, JPWM is required to discuss any material changes which have been made to the brochure
since the last annual amendment filed March 17, 2025. The Firm has no material changes to disclose.
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Item 3. Table of Contents
Item 1. Cover Page ....................................................................................................................................... i
Item 2. Material Changes ............................................................................................................................. ii
Item 3. Table of Contents ............................................................................................................................. iii
Item 4. Advisory Business ............................................................................................................................ 4
Item 5. Fees and Compensation .................................................................................................................. 6
Item 6. Performance-Based Fees and Side-by-Side Management ............................................................. 9
Item 7. Types of Clients ............................................................................................................................. 10
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ...................................................... 11
Item 9. Disciplinary Information .................................................................................................................. 15
Item 10. Other Financial Industry Activities and Affiliations ....................................................................... 16
Item 11. Code of Ethics .............................................................................................................................. 17
Item 12. Brokerage Practices ..................................................................................................................... 18
Item 13. Review of Accounts...................................................................................................................... 22
Item 14. Client Referrals and Other Compensation ................................................................................... 23
Item 15. Custody ........................................................................................................................................ 24
Item 16. Investment Discretion................................................................................................................... 25
Item 17. Voting Client Securities ................................................................................................................ 26
Item 18. Financial Information .................................................................................................................... 27
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Item 4. Advisory Business
JPWM is principally owned by Mark Perlson and John F. Carey, and has been in business as an SEC
registered investment adviser since June 2004.
JPWM provides financial planning, consulting and investment management services. Prior to engaging
JPWM to provide any of the foregoing investment advisory services, the client is required to enter into
one or more written agreements with JPWM setting forth the terms and conditions under which JPWM
renders its services (collectively the “Agreement”). As of February 10, 2026, JPWM had $274,006,047 in
assets under management, all of which was managed on a discretionary basis.
This Disclosure Brochure describes the business of JPWM. Certain sections will also describe the
activities of Supervised Persons. Supervised Persons are any of JPWM’s officers, partners, directors (or
other persons occupying a similar status or performing similar functions), or employees or any other
person who provides investment advice on JPWM’s behalf and is subject to JPWM’s supervision or
control.
Financial Planning and Consulting Services
JPWM provides its clients with a broad range of comprehensive financial planning and consulting
services. These services include, but are not limited to investments, retirement, education and cash flow
needs of the client.
In performing its services, JPWM is not required to verify any information received from the client or from
the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on
such information. JPWM recommends the services of itself, and/or other professionals to implement its
recommendations. Clients are advised that a conflict of interest exists if JPWM recommends its own
services. The client is under no obligation to act upon any of the recommendations made by JPWM
under a financial planning or consulting engagement or to engage the services of any such recommended
professional, including JPWM itself. The client retains absolute discretion over all such implementation
decisions and is free to accept or reject any of JPWM’s recommendations. Clients are advised that it
remains their responsibility to promptly notify JPWM if there is ever any change in their financial situation
or investment objectives for the purpose of reviewing, evaluating or revising JPWM’s previous
recommendations and/or services.
Investment Management Services
Clients can engage JPWM to manage all or a portion of their assets on a discretionary basis.
JPWM primarily allocates clients’ investment management assets among mutual funds, exchange-traded
funds (“ETFs”), individual debt and equity securities and/or options, as well as the securities components
of variable annuities and variable life insurance contracts, in accordance with the investment objectives of
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the client. JPWM may provide advice about any type of investment or legacy position otherwise held in
clients' portfolios.
JPWM also renders non-discretionary investment management services to clients relative to variable
life/annuity products that they own, their individual employer-sponsored retirement plans or other products
that are not be held by the client’s primary custodian. In so doing, JPWM either directs or recommends
the allocation of client assets among the various investment options that are available with the product.
Client assets are maintained at the specific insurance company or custodian designated by the product.
JPWM tailors its advisory services to the individual needs of clients. JPWM consults with clients initially
and on an ongoing basis to determine risk tolerance, time horizon and other factors that may impact the
clients’ investment needs. JPWM ensures that clients’ investments are suitable for their investment
needs, goals, objectives and risk tolerance.
Clients are advised to promptly notify JPWM if there are changes in their financial situation or investment
objectives or if they wish to impose any reasonable restrictions upon JPWM’s management services.
Clients may impose reasonable restrictions or mandates on the management of their account (e.g.,
require that a portion of their assets be invested in socially responsible funds) if, in JPWM’s sole
discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly
burdensome to its management efforts.
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Item 5. Fees and Compensation
JPWM offers its services on a fee basis, which includes hourly and/or fixed fees, as well as fees based
upon assets under management.
Financial Planning and Consulting Fees
JPWM charges a fixed fee and/or hourly fee for financial planning and consulting services.
Investment management clients can engage JPWM to provide a financial plan (which may include non-
investment related matters). JPWM’s investment management fee, as described below, is generally
inclusive of any investment-related consulting services. In addition, JPWM generally waives financial
planning fees for new clients.
Alternatively, JPWM can be engaged to provide a less comprehensive investment policy statement on an
hourly basis at a rate of $200 per hour. JPWM may also charge a fee of $200 on an hourly rate basis to
non-investment management and investment management clients that require a disproportionate amount
of financial planning and/or consulting services.
Prior to engaging JPWM to provide financial planning and/or consulting services, the client is required to
enter into a written agreement with JPWM setting forth the terms and conditions of the engagement.
Generally, JPWM requires one-half of the financial planning and/or consulting fee (estimated hourly)
payable upon entering the written agreement. The balance is generally due upon delivery of the financial
plan or completion of the agreed upon services.
Investment Management Fees
JPWM provides investment management services for an annual fee based upon a percentage of the
market value of the assets being managed by JPWM. The annual fee varies (between 0.40% and 1.00%)
depending upon the market value of the assets under management, as follows:
PORTFOLIO VALUE
ANNUAL FEE
up to $1,000,000
1.00%
$1,000,001 - $6,000,000
0.75%
$6,000,001 - $10,000,000
0.50%
above $10,000,000
0.40%
JPWM’s annual fee is prorated and charged monthly, in advance, based upon the market value of the
assets being managed by JPWM on the last day of the previous month. JPWM’s annual fee is exclusive
of, and in addition to, brokerage commissions, transaction fees and other related costs and expenses
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which are incurred by the client. JPWM does not, however, receive any portion of these commissions,
fees and costs.
Fee Discretion
JPWM, in its sole discretion, may negotiate to charge a lesser advisory fee based upon certain criteria
(i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to
be managed, related accounts, account composition, pre-existing client, account retention, pro bono
activities, etc.).
Fees Charged by Financial Institutions
As further discussed in response to Item 12 (below), JPWM generally recommends that clients utilize the
brokerage and clearing services of Charles Schwab & Co., Inc. (“Schwab”) for investment management
accounts.
JPWM may only implement its investment management recommendations after the client has arranged
for and furnished JPWM with all information and authorization regarding accounts with appropriate
financial institutions. Financial institutions include, but are not limited to, Schwab, any other broker-dealer
recommended by JPWM, broker-dealer directed by the client, trust companies, banks etc. (collectively
referred to herein as the “Financial Institutions”).
Clients will incur certain charges imposed by the Financial Institutions and other third parties such as
custodial fees, charges imposed directly by a mutual fund or ETF in the account, which are disclosed in
the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges,
odd-lot differentials, transfer taxes, wire transfer and electronic fund fees and other fees and taxes on
brokerage accounts and securities transactions. Additionally, for assets outside of any wrap fee
programs, clients will incur brokerage commissions and transaction fees. Such charges, fees and
commissions are exclusive of and in addition to JPWM’s fee.
Fee Debit
JPWM’s Agreement and the separate agreement with any Financial Institutions authorize JPWM to debit
the client’s account for the amount of JPWM’s fee and to directly remit that management fee to JPWM.
Any Financial Institutions recommended by JPWM have agreed to send a statement to the client, at least
quarterly, indicating all amounts disbursed from the account including the amount of management fees
paid directly to JPWM.
Fees for Management During Partial Months of Service
For the initial period of investment management services, the fees are calculated on a pro rata basis.
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The Agreement between JPWM and the client will continue in effect until terminated by either party
pursuant to the terms of the Agreement. JPWM’s fees are prorated through the date of termination and
any remaining balance is charged or refunded to the client, as appropriate.
Clients may make additions to and withdrawals from their account at any time, subject to JPWM’s right to
terminate an account. Additions may be in cash or securities provided that JPWM reserves the right to
liquidate any transferred securities or decline to accept particular securities into a client’s account.
Clients may withdraw account assets on notice to JPWM, subject to the usual and customary securities
settlement procedures. However, JPWM designs its portfolios as long-term investments and the
withdrawal of assets may impair the achievement of a client’s investment objectives. JPWM may consult
with its clients about the options and ramifications of transferring securities. However, clients are advised
that when transferred securities are liquidated, they are subject to transaction fees, fees assessed at the
mutual fund level (i.e. contingent deferred sales charge) and/or tax ramifications.
If assets are deposited into or withdrawn from an account after the inception of a month, the fee payable
with respect to such assets will not be adjusted or prorated based on the number of days remaining in the
month.
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Item 6. Performance-Based Fees and Side-by-Side Management
JPWM does not provide any services for performance-based fees. Performance-based fees are those
based on a share of capital gains on or capital appreciation of the assets of a client.
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Item 7. Types of Clients
JPWM provides its services to individuals, pension and profit sharing plans, trusts, estates, charitable
organizations, corporations and business entities.
Minimum Fee
As a condition for starting and maintaining a relationship, JPWM generally imposes a minimum annual
fee of $10,000. This minimum fee may have the effect of making JPWM’s service impractical for clients,
particularly those with portfolios less than $1,000,000 under JPWM’s management. JPWM, in its sole
discretion, may waive its minimum annual fee based upon certain criteria including anticipated future
earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related
accounts, account composition, pre-existing client, account retention and pro bono activities.
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Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
JPWM’s primary method of analysis can be described as fundamental in nature.
Fundamental analysis involves assessing the economic and political conditions that affect the overall
trends of the markets. JPWM analyzes many factors, included but not limited to macroeconomic and
political factors that it believes may influence market trends—such as whether the economy is expanding
or contracting, stock market valuation, inflation levels and trends, changes in tax policy and Federal
monetary policy decisions. JPWM’s analysis of whether the stock market is trending “up” or “down” is
used (along with client investment objectives and time horizons) to make tactical changes in asset
allocation in client portfolios. JPWM’s analysis of whether interest rates are trending “up” or “down” is
also used in making tactical changes in asset allocation, as well as average bond market maturities in
client portfolios.
Investment Strategies
Portfolio Philosophy
JPWM seeks to diversify investment exposures over numerous asset classes and asset class sectors in
an attempt to reduce the risk of sustaining substantial losses. JPWM believes that the allocation of an
investor’s assets is an important determining factor in long-term portfolio performance. A flexible strategic
asset allocation foundation is utilized, which allows for any tactical tilts that JPWM feels are necessary to
reduce risk when asset valuations, the economic environment and other considerations warrant.
Portfolio Strategy
A globally diversified asset allocation strategy is employed, maintaining a core of passive and indexed
investments supported by appropriate active portfolio managers. JPWM believes that there are specific
asset classes, market conditions and situations that may allow active managers to add value. As a result,
the overall combination of these methods produce portfolios designed for long-term success with proper
diversification and liquidity.
Portfolio Implementation
JPWM implements portfolios utilizing various types of securities including mutual funds, exchanged
traded funds (ETFs), closed-end funds and individual stocks and bonds to name a few. The decision of
what method of investing and type of security is used to gain exposure to an asset class is influenced by
many factors including but not limited to: the asset class or asset class sector being invested, asset
valuations, the economic environment, taxes, liquidity and the costs associated with investing.
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Risks of Loss
The following list of risk factors does not purport to be a complete enumeration or explanation of the risks
involved with respect to the Firm’s investment management activities. Clients should consult with their
legal, tax, and other advisors before engaging the Firm to provide investment management services on
their behalf.
Market Risks
Investing involves risk, including the potential loss of principal, and all investors should be guided
accordingly. The profitability of a significant portion of JPWM’s recommendations and/or investment
decisions may depend to a great extent upon correctly assessing the future course of price movements of
stocks, bonds and other asset classes. In addition, investments may be adversely affected by financial
markets and economic conditions throughout the world. There can be no assurance that JPWM will be
able to predict these price movements accurately or capitalize on any such assumptions.
Volatility Risks
The prices and values of investments can be highly volatile, and are influenced by, among other things,
interest rates, general economic conditions, the condition of the financial markets, the financial condition
of the issuers of such assets, changing supply and demand relationships, and programs and policies of
governments.
Cash Management Risks
The Firm may invest some of a client’s assets temporarily in money market funds or other similar types of
investments, during which time an advisory account may be prevented from achieving its investment
objective.
Mutual Funds and Exchange-Traded Funds (ETFs)
An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF
shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s
underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains,
as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities
for a profit that cannot be offset by a corresponding loss.
Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a
broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated
daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees,
redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day,
although the actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. The
trading prices of a mutual fund’s shares may differ significantly from the NAV during periods of market
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volatility, which may, among other factors, lead to the mutual fund’s shares trading at a premium or
discount to NAV.
Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary
market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at
least once daily for indexed-based ETFs and more frequently for actively managed ETFs. However,
certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV.
There is also no guarantee that an active secondary market for such shares will develop or continue to
exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 50,000 shares
or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a
shareholder may have no way to dispose of such shares.
Cyber Security
With the increased use of technologies such as the internet, email, mobile applications, etc. to conduct
business, the Firm and other service providers used by the Firm, as well as the underlying investments
made by clients are susceptible to operational, information security and related risks. In general, cyber
incidents can result from deliberate attacks or unintentional events and may arise from external or internal
sources. Cyber incidents have the ability to cause disruptions and impact business operations, potentially
resulting in financial losses, the release of investor information or confidential business information,
interference with the ability to calculate the value of client investments, destruction to equipment and
systems, violations of applicable privacy and other laws, regulatory fines or penalties, reputation damage,
or additional compliance costs. The Firm will seek to implement safeguards to protect clients against
cyber attacks. However, there can be no assurance that the Firm will be successful in preventing the
occurrence of cyber attacks or mitigating the impact of cyber attacks. In addition, many cyber incidents
begin with client breaches. Clients should be cognizant of the risks of cybersecurity, including internet
and email hygiene and should notify the Firm if they believe that their communications have been
compromised.
Use of Margin
To the extent that a client authorizes the use of margin, and margin is thereafter employed by JPWM in
the management of the client’s investment portfolio, the market value of the client’s account and
corresponding fee payable by the client to JPWM will not be increased.
While the use of margin borrowing can substantially improve returns, such use may also increase the
adverse impact to which a client’s portfolio may be subject. Borrowings will usually be from securities
brokers and dealers and will typically be secured by the client’s securities and/or other assets. Under
certain circumstances, such a broker-dealer may demand an increase in the collateral that secures the
client’s obligations and if the client were unable to provide additional collateral, the broker-dealer could
liquidate assets held in the account to satisfy the client’s obligations to the broker-dealer. Liquidation in
that manner could have extremely adverse consequences. In addition, the amount of the client’s
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borrowings and the interest rates on those borrowings, which will fluctuate, will have a significant effect on
the client’s profitability.
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Item 9. Disciplinary Information
JPWM is required to disclose the facts of any legal or disciplinary events that are material to a client’s
evaluation of its advisory business or the integrity of management. JPWM does not have any required
disclosures to this Item.
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Item 10. Other Financial Industry Activities and Affiliations
JPWM is required to disclose any relationship or arrangement that is material to its advisory business or
to its clients with certain related persons.
Related Certified Public Accountants
JPWM does not render accounting advice or tax preparation services to its clients. Rather, to the extent
that a client requires accounting advice and/or tax preparation services, JPWM, if requested,
recommends the services of Perlson, LLP, a Certified Public Accounting firm. All services performed by
Perlson, LLP are rendered independent of JPWM and pursuant to a separate agreement between the
client and Perlson, LLP. JPWM does not receive any of the fees charged by Perlson, LLP, referral or
otherwise.
Related Businesses and Investments
Mark Perlson and John F. Carey are shareholders of Cube Components, Inc., a privately-held electronic
components business. Although one client of JPWM has invested in Cube Components, Inc. and is a
creditor to the company, JPWM did not recommend such investments to the client. Nonetheless, the
additional incentive for JPWM to maintain this relationship creates a conflict of interest. In addition, the
principals may invest in other companies through private placements. Similar to mentioned above, if any
client also invests in those private placements, it is not through a recommendation of the Firm or the
principals and the client is fully responsible for the decision to invest, including doing proper due diligence
on the investment.
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Item 11. Code of Ethics
JPWM and persons associated with JPWM (“Associated Persons”) are permitted to buy or sell securities
that it also recommends to clients consistent with JPWM’s policies and procedures.
JPWM has adopted a code of ethics that sets forth the standards of conduct expected of its associated
persons and requires compliance with applicable securities laws (“Code of Ethics”). JPWM’s Code of
Ethics contains written policies reasonably designed to prevent the unlawful use of material non-public
information by JPWM or any of its associated persons. The Code of Ethics also requires that certain of
JPWM’s personnel (called “Access Persons”) report their personal securities holdings and transactions
and obtain pre-approval of certain investments such as initial public offerings and limited offerings.
When JPWM is engaging in or considering a transaction in any security on behalf of a client, no Access
Person may effect for themselves or for their immediate family (i.e., spouse, minor children, and adults
living in the same household as the Access Person) a transaction in that security unless:
•
the transaction has been completed;
•
the transaction for the Access Person is completed as part of a batch trade (as defined below in
Item 12) with clients; or
• a decision has been made not to engage in the transaction for the client.
These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii)
money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper,
repurchase agreements and other high quality short-term debt instruments, including repurchase
agreements; (iii) shares issued by mutual funds or money market funds; and (iv) shares issued by unit
investment trusts that are invested exclusively in one or more mutual funds.
This Code of Ethics has been established recognizing that some securities trade in sufficiently broad
markets to permit transactions by Access Persons to be completed without any appreciable impact on the
markets of such securities. Therefore, under certain limited circumstances, exceptions may be made to
the policies stated above.
Clients and prospective clients may contact JPWM to request a copy of its Code of Ethics.
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Item 12. Brokerage Practices
As discussed above, in Item 5, JPWM generally recommends that clients utilize the brokerage and
clearing services of Schwab.
The final decision to custody assets with Schwab is at the discretion of the client, including those
accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan
sponsor or IRA accountholder. JPWM is independently owned and operated and not affiliated with
Schwab. Schwab provides JPWM with access to its institutional trading and custody services, which are
typically not available to retail investors.
Factors which JPWM considers in recommending Schwab or any other broker-dealer to clients include
their respective financial strength, reputation, execution, pricing, research and service. Schwab enables
the Firm to obtain many mutual funds without transaction charges and other securities at nominal
transaction charges. The commissions and/or transaction fees charged by Schwab may be higher or
lower than those charged by other Financial Institutions.
The commissions paid by JPWM’s clients to Schwab comply with the Firm’s duty to obtain “best
execution.” Clients may pay commissions that are higher than another qualified Financial Institution
might charge to effect the same transaction where JPWM determines that the commissions are
reasonable in relation to the value of the brokerage and research services received. In seeking best
execution, the determinative factor is not the lowest possible cost, but whether the transaction represents
the best qualitative execution, taking into consideration the full range of a Financial Institution’s services,
including among others, the value of research provided, execution capability, commission rates and
responsiveness. JPWM seeks competitive rates but may not necessarily obtain the lowest possible
commission rates for client transactions.
Transactions may be cleared through other broker-dealers with whom the Firm and its custodians have
entered into agreements for prime brokerage clearing services. Should an account make use of prime
brokerage, the Client may be required to sign an additional agreement, and additional fees are likely to be
charged.
Consistent with obtaining best execution, brokerage transactions are directed to certain broker-dealers in
return for investment research products and/or services which assist JPWM in its investment decision-
making process. Such research will be used to service all of the Firm’s clients, but brokerage
commissions paid by one client may be used to pay for research that is not used in managing that client’s
portfolio. The receipt of investment research products and/or services as well as the allocation of the
benefit of such investment research products and/or services poses a conflict of interest because JPWM
does not have to produce or pay for the products or services.
JPWM periodically and systematically reviews its policies and procedures regarding its recommendation
of Financial Institutions in light of its duty to obtain best execution.
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Software and Support Provided by Financial Institutions
JPWM receives without cost from Schwab administrative support, computer software, related systems
support, as well as other third party support as further described below (together "Support") which allow
JPWM to better monitor client accounts maintained at Schwab and otherwise conduct its business.
JPWM receives the Support without cost because the Firm renders investment management services to
clients that maintain assets at Schwab. The Support is not provided in connection with securities
transactions of clients (i.e., not “soft dollars”). The Support benefits JPWM, but not its clients directly.
Clients should be aware that JPWM’s receipt of economic benefits such as the Support from a broker-
dealer creates a conflict of interest since these benefits will influence the Firm’s choice of broker-dealer
over another that does not furnish similar software, systems support or services. In fulfilling its duties to
its clients, JPWM endeavors at all times to put the interests of its clients first and has determined that the
recommendation of Schwab is in the best interest of clients and satisfies the Firm's duty to seek best
execution.
Specifically, JPWM receives the following benefits from Schwab: i) receipt of duplicate client
confirmations and bundled duplicate statements; ii) access to a trading desk that exclusively services its
institutional traders; iii) access to block trading which provides the ability to aggregate securities
transactions and then allocate the appropriate shares to client accounts; and iv) access to an electronic
communication network for client order entry and account information.
These services generally are available to independent investment advisors on an unsolicited basis, at no
charge to them so long as a certain amount of the advisor’s clients’ assets are maintained in accounts at
Schwab Advisor Services. Schwab’s services include brokerage services that are related to the
execution of securities transactions, custody, research, including that in the form of advice, analyses and
reports, and access to mutual funds and other investments that are otherwise generally available only to
institutional investors or would require a significantly higher minimum initial investment.
For client accounts maintained in its custody, Schwab generally does not charge separately for custody
services but is compensated by account holders through commissions or other transaction-related or
asset-based fees for securities trades that are executed through Schwab or that settle into Schwab
accounts.
Schwab also makes available to the Firm other products and services that benefit the Firm but may not
benefit its clients’ accounts. These benefits may include national, regional or Firm specific educational
events organized and/or sponsored by Schwab. Other potential benefits may include occasional
business entertainment of personnel of JPWM by Schwab personnel, including meals, invitations to
sporting events, including golf tournaments, and other forms of entertainment, some of which may
accompany educational opportunities. Other of these products and services assist JPWM in managing
and administering clients’ accounts. These include software and other technology (and related
technological training) that provide access to client account data (such as trade confirmations and
account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple
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client accounts), provide research, pricing information and other market data, facilitate payment of the
Firm's fees from its clients’ accounts, and assist with back-office training and support functions,
recordkeeping and client reporting. Many of these services generally may be used to service all or some
substantial number of the Firm’s accounts, including accounts not maintained at Schwab. Schwab also
makes available to JPWM other services intended to help the Firm manage and further develop its
business enterprise. These services may include professional compliance, legal and business consulting,
publications and conferences on practice management, information technology, business succession,
regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing.
In addition, Schwab may make available, arrange and/or pay vendors for these types of services
rendered to the Firm by independent third parties. Schwab may discount or waive fees it would otherwise
charge for some of these services or pay all or a part of the fees of a third-party providing these services
to the Firm. While, as a fiduciary, JPWM endeavors to act in its clients’ best interests, the Firm's
recommendation that clients maintain their assets in accounts at Schwab may be based in part on the
benefits received and not solely on the nature, cost or quality of custody and brokerage services provided
by Schwab, which creates a potential conflict of interest.
Directed Brokerage
The client may direct JPWM in writing to use a particular Financial Institution to execute some or all
transactions for the client. In that case, the client will negotiate terms and arrangements for the account
with that Financial Institution and the Firm will not seek better execution services or prices from other
Financial Institutions or be able to “batch” client transactions for execution through other Financial
Institutions with orders for other accounts managed by JPWM (as described above). As a result, the
client may pay higher commissions or other transaction costs, greater spreads or may receive less
favorable net prices, on transactions for the account than would otherwise be the case. Subject to its
duty of best execution, JPWM may decline a client’s request to direct brokerage if, in the Firm’s sole
discretion, such directed brokerage arrangements would result in additional operational difficulties.
Trade Aggregation
Transactions for each client will be effected independently, unless JPWM decides to purchase or sell the
same securities for several clients at approximately the same time. JPWM may (but is not obligated to)
combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates or
to allocate equitably among the Firm’s clients differences in prices and commissions or other transaction
costs that might not have been obtained had such orders been placed independently. Under this
procedure, transactions will be averaged as to price and allocated among JPWM’s clients pro rata to the
purchase and sale orders placed for each client on any given day. To the extent that the Firm determines
to aggregate client orders for the purchase or sale of securities, including securities in which JPWM’s
Supervised Persons may invest, the Firm does so in accordance with applicable rules promulgated under
the Advisers Act and no-action guidance provided by the staff of the U.S. Securities and Exchange
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Commission. JPWM does not receive any additional compensation or remuneration as a result of the
aggregation.
In the event that the Firm determines that a prorated allocation is not appropriate under the particular
circumstances, the allocation will be made based upon other relevant factors, which include: (i) when only
a small percentage of the order is executed, shares may be allocated to the account with the smallest
order or the smallest position or to an account that is out of line with respect to security or sector
weightings relative to other portfolios, with similar mandates; (ii) allocations may be given to one account
when one account has limitations in its investment guidelines which prohibit it from purchasing other
securities which are expected to produce similar investment results and can be purchased by other
accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an allocation,
shares may be reallocated to other accounts (this may be due to unforeseen changes in an account’s
assets after an order is placed); (iv) with respect to sale allocations, allocations may be given to accounts
low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis
allocation in one or more accounts, the Firm may exclude the account(s) from the allocation; the
transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a
small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts
on a random basis.
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Item 13. Review of Accounts
Account Reviews
For those clients to whom JPWM provides investment management services, JPWM monitors those
portfolios as part of an ongoing process while regular account reviews are conducted on at least a
quarterly basis. For those clients to whom JPWM provides financial planning and/or consulting services,
reviews are conducted on an “as needed” basis. Such reviews are conducted by the Principals of JPWM,
John F. Carey and Mark Perlson. All investment advisory clients are encouraged to discuss their needs,
goals and objectives with JPWM and to keep JPWM informed of any changes thereto. JPWM contacts
ongoing
investment advisory clients at
least annually
to review
its previous services and/or
recommendations and to discuss the impact resulting from any changes in the client’s financial situation
and/or investment objectives.
General Reports and Statements
Unless otherwise agreed upon, clients are provided with transaction confirmation notices and regular
summary account statements directly from the broker-dealer or custodian for the client accounts. Those
clients to whom JPWM provides investment advisory services may also receive a report from JPWM
and/or a third-party vendor that may include such relevant account and/or market-related information
such as an inventory of account holdings and account performance. Clients should compare the account
statements they receive from their custodian with those they receive from JPWM or another provider.
Financial Planning and Consulting Reports
Those clients to whom JPWM provides financial planning and/or consulting services will receive reports
from JPWM summarizing its analysis and conclusions as requested by the client or otherwise agreed to in
writing by JPWM.
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Item 14. Client Referrals and Other Compensation
Client Referrals
JPWM does not currently provide compensation to third-party solicitors for client referrals.
Other Economic Benefit
JPWM receives economic benefits from Schwab. The benefits, conflicts of interest and how they are
addressed are discussed above in response to Item 12.
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Item 15. Custody
JPWM’s Agreement and/or the separate agreement with any Financial Institution authorizes JPWM
through such Financial Institution to debit the client’s account for the amount of JPWM’s fee and to
directly remit that management fee to JPWM in accordance with applicable custody rules.
The Financial Institutions recommended by JPWM have agreed to send a statement to the client, at least
quarterly, indicating all amounts disbursed from the account including the amount of management fees
paid directly to JPWM. In addition, as discussed in Item 13, JPWM and/or third party vendor may also
send periodic supplemental reports to clients. Clients should carefully review the statements sent directly
by the Financial Institutions and compare them to those received from JPWM.
JPWM also has custody due to clients giving the Firm limited power of attorney in a standing letter of
authorization (“SLOA”) to disburse funds to one or more third parties as specifically designated by the
client. In such circumstances, the Firm will implement the steps in the SEC’s no-action letter on February
21, 2017 which includes (in summary): i) client will provide instruction for the SLOA to the custodian; ii)
client will authorize the Firm to direct transfers to the specific third party; iii) the custodian will perform
appropriate verification of the instruction and provide a transfer of funds notice to the client promptly after
each transfer; iv) the client will have the ability to terminate or change the instruction; v) the Firm will have
no authority or ability to designate or change the identity or any information about the third party; vi) the
Firm will keep records showing that the third party is not a related party of the Firm or located at the same
address as the Firm; and vii) the custodian will send the client an initial and annual notice confirming the
SLOA instructions.
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Item 16. Investment Discretion
JPWM is given the authority to exercise discretion on behalf of clients. JPWM is considered to exercise
investment discretion over a client’s account if it can effect transactions for the client without first having
to seek the client’s consent. JPWM is given this authority through a power-of-attorney included in the
agreement between JPWM and the client. Clients may request a limitation on this authority (such as
certain securities not to be bought or sold). JPWM takes discretion over the following activities:
• The securities to be purchased or sold;
• The amount of securities to be purchased or sold;
• When transactions are made; and
• The Financial Institutions to be utilized.
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Item 17. Voting Client Securities
JPWM may vote client securities (proxies) on behalf of its clients. When JPWM accepts such
responsibility, it will only cast proxy votes in a manner consistent with the best interest of its clients.
Absent special circumstances, which are fully-described in JPWM’s Proxy Voting Policies and
Procedures, all proxies will be voted consistent with guidelines established and described in JPWM’s
Proxy Voting Policies and Procedures, as they may be amended from time-to-time. Clients may contact
JPWM to request information about how JPWM voted proxies for that client’s securities or to get a copy of
JPWM’s Proxy Voting Policies and Procedures. A brief summary of JPWM’s Proxy Voting Policies and
Procedures is as follows:
•
JPWM has formed a Proxy Voting Committee that will be responsible for monitoring corporate
actions, making voting decisions in the best interest of clients and ensuring that proxies are
submitted in a timely manner.
• The Proxy Voting Committee will generally vote proxies according to JPWM’s then current Proxy
Voting Guidelines. The Proxy Voting Guidelines include many specific examples of voting
decisions for the types of proposals that are most frequently presented, including: composition of
the board of directors; approval of
independent auditors; management and director
compensation; anti-takeover mechanisms and related issues; changes to capital structure;
corporate and social policy issues; and issues involving mutual funds.
• Although the Proxy Voting Guidelines are followed as a general policy, certain issues are
considered on a case-by-case basis based on the relevant facts and circumstances. Since
corporate governance issues are diverse and continually evolving, JPWM devotes an appropriate
amount of time and resources to monitor these changes.
• Clients cannot direct JPWM’s vote on a particular solicitation but can revoke JPWM’s authority to
vote proxies.
In situations where there is a conflict of interest in the voting of proxies due to business or personal
relationships that JPWM maintains with persons having an interest in the outcome of certain votes, JPWM
takes appropriate steps to ensure that its proxy voting decisions are made in the best interest of its clients
and are not the product of such conflict.
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Item 18. Financial Information
JPWM is not required to disclose any financial information pursuant to this Item due to the following:
• The firm does not require or solicit the prepayment of more than $1,200 in fees six months or
more in advance;
• The firm does not have a financial condition that is reasonably likely to impair its ability to meet
contractual commitments to clients; and
• The firm has not been the subject of a bankruptcy petition at any time during the past ten years.
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JP Wealth Management Inc.
a Registered Investment Adviser
3401 Salterbeck Court, Suite 202
Mt. Pleasant, SC 29466
(866) 562-6969
www.jpwm.com
Prepared by:
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