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Item 1 Cover Page
FORM ADV PART 2A
INFORMATIONAL BROCHURE
500 North Franklin Turnpike
Suite 104
Ramsey, NJ 07446
Jason Kolinsky, CFP®
Chief Compliance Officer
(201) 474-4011
www.kolinskywealth.com
March 31, 2025
This brochure provides information about the qualifications and business practices of
Kolinsky Wealth Management, LLC. If you have any questions about the contents of this
brochure, please contact us at (201) 474-4011 or via email at jkolinsky@kolinskywealth.com.
The information in this brochure has not been approved or verified by the United States
Securities and Exchange Commission or by any state securities authority.
Additional information about Kolinsky Wealth Management, LLC (CRD #153763) is also
available on the SEC’s website at www.adviserinfo.sec.gov.
Item 2 Material Changes
Kolinsky Wealth Management LLC (“Kolinsky” or “the Firm”) is required to note any material
changes to its Form ADV here in Item 2. Since the most recent delivery of this Brochure in March
2024, we have made the following material changes:
Item 5 has been amended to discuss the billing arrangements regarding Pontera, a third-party held
away account management platform and adjustments to fee processes for Addepar reporting
services and UMA/SMA overlay services..
Item 10 has been amended to disclose new affiliated entities, KWM TPA Services, LLC and KWM
Securities, LLC.
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Item 3 Table of Contents
Brochure
Item 1 Cover Page ................................................................................................................................. 1
Item 2 Material Changes ....................................................................................................................... 2
Item 3 Table of Contents....................................................................................................................... 3
Item 4 Advisory Business ..................................................................................................................... 4
Item 5 Fees and Compensation ............................................................................................................. 7
Item 6 Performance-Based Fees and Side-by-Side Management ....................................................... 11
Item 7 Types of Clients ....................................................................................................................... 12
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ............................................... 12
Item 9 Disciplinary Information ......................................................................................................... 18
Item 10 Other Financial Industry Activities and Affiliations ............................................................. 18
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........ 19
Item 12 Brokerage Practices ............................................................................................................... 19
Item 13 Review of Accounts............................................................................................................... 22
Item 14 Client Referrals and Other Compensation ............................................................................. 22
Item 15 Custody .................................................................................................................................. 23
Item 16 Investment Discretion ............................................................................................................ 23
Item 17 Voting Client Securities......................................................................................................... 24
Item 18 Financial Information ............................................................................................................ 24
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Item 4 Advisory Business
Kolinsky Wealth Management, LLC (“Kolinsky” or “KWM”) is a registered investment advisor
firm registered with the Securities and Exchange Commission (SEC) since May 4, 2010. The
Principal Owner and Managing Member of Kolinsky Wealth Management, LLC, Steven I.
Kolinsky, has been in the industry for over 35 years assisting clients by taking a holistic approach
to investment management and helping clients achieve their financial goals.
Kolinsky Wealth Management is a full-service wealth management firm serving high net worth
individuals and business owners. Kolinsky provides a comprehensive range of financial solutions
for their clients including investment advisory services, retirement plan design and consulting,
wealth transfer planning, and financial planning. Steven Kolinsky is joined by both his sons, Jason
Kolinsky, and Chad Kolinsky to offer a multi-generational approach to investing.
Financial Planning
Kolinsky’s goal is to a work with its clients, such that, they utilize Kolinsky to help with all aspects
of their financial and life goals. Many engagements will include financial planning. The process
would begin with an introductory meeting where a Kolinsky professional meets in person with a
client and discusses their overall financial goals. If the client elects to work with Kolinsky further,
a subsequent discovery meeting would be scheduled where the client shares additional details
regarding financial objectives, financial issues, cash flow management, tax planning, and a full
investment review. Kolinsky will then customize a financial plan for each client for their specific
needs that may cover college funding projections, insurance needs, and address specific estate and
tax planning issues. Kolinsky will provide in depth analysis given the information provided to
create a blueprint for each client detailing their assessment of when each financial objective (i.e.
retirement) can occur and the income needed to meet their specific goals. A projected analysis
utilizing various cash flows corresponding with the client’s unique situation is provided.
Clients who receive planning services will either elect to continue to work with Kolinsky through
asset management and/or ongoing planning for a fee, or they may choose to implement their plan
elsewhere or not at all.
Asset Management
Kolinsky’s principal service is providing fee-based investment advisory services. When asset
management services are performed they are done on either a discretionary or non-discretionary
basis. In many cases, Kolinsky will have a financial plan to guide these decisions to ensure they
are within the client’s investment objectives. In the event that a financial plan is not in place,
Kolinsky will work with the client to gather their investment objectives and information through
both a risk assessment questionnaire and client dialogue. When services are performed on a
discretionary basis, Kolinsky will not seek specific approval of each change to a client account.
For accounts where Kolinsky has full discretion, clients engaging us will be asked to execute a
Limited Power of Attorney (granting us the discretionary authority over the client accounts) as
well as an agreement that outlines the responsibilities of both the client and Kolinsky.
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that some recommendations may be
As mentioned, Kolinsky may provide asset management services on a non-discretionary basis,
which means we will manage the clients’ accounts as we do for our discretionary clients, except
we will consult with the client prior to implementing any investment recommendation. Clients
should be aware
time-sensitive, in which case
recommendations not implemented because we are unable to reach a non-discretionary client may
not be made on a timely basis and therefore client’s account may not perform as well as it would
have had Kolinsky been able to reach the client for a consultation on the recommendation.
Clients may engage Kolinsky to manage certain investment products that are not maintained at the
primary custodian, such as variable life insurance and annuity contracts and assets held in
employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these
situations, Kolinsky directs or recommends the allocation of client assets among the various
investment options available with the product. These assets are generally maintained at the
underwriting insurance company or the custodian designated by the product’s provider.
Kolinsky may use a third-party platform called Pontera to facilitate management of held away
assets such as 401(k) plan participant accounts, with discretion. The platform allows us to avoid
being considered to have custody of Client funds since we do not have direct access to Client log-
in credentials to affect trades. Kolinsky is not affiliated with the platform in any way and receives
no compensation from them for using their platform. Clients will be assisted in linking their
accounts to the platform. Once the Client account(s) is connected to the platform, we will review
the current account allocations. When deemed necessary, we will rebalance the account
considering the clients investment goals. To monitor our Client account(s) we have established
drift thresholds for Asset Class and Holdings. If the Client account(s) drifts outside of the
established thresholds the account will be rebalanced to the original allocation. Clients should be
aware that because we are unable to debit our fees from these accounts, we may debit the applicable
fees from other Client accounts custodied at Schwab or alternatively invoice Clients directly for
this service. When additional fees from multiple managed accounts are debited from one account
Clients should be aware that applicable account performance will be impacted. Pontera charges
Kolinsky a fee for each managed account. Clients do not pay any additional fee to Pontera or to
Kolinsky in connection with platform participation above the standard Kolinsky investment
management fee. Kolinsky is not affiliated with the Pontera platform in any way and receives no
compensation from them for using their platform.
Retirement Plan Consulting Services
Kolinsky will offer consulting services for both retirement plans and their participants. Kolinsky
will provide research and analysis with regard to investment advice and fiduciary due diligence
with regard to the selection and ongoing monitoring of funds for plan sponsors and individuals.
Consulting Services for Qualified Plans
Kolinsky will prepare and/or evaluate Investment Policy Statements (thereafter “IPS”) for plan
sponsors and will follow the IPS to arrive upon or facilitate prudent investment related
recommendations. Kolinsky will also assist plan sponsors with the selection of a 401(K) provider
or qualified plan providers for their respective plans. This process may include a review of
administrative, recordkeeping, compliance, and employee communication services. Kolinsky may
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also review fees associated with investments. Kolinsky will also assist with any conversion
process between investment providers including interfacing with company consultants and
relationship managers to facilitate conversions. Kolinsky will also provide an on-going analysis
of each qualified plans responsibilities, titled a Fiduciary Plan Review that ensures that those
responsibilities are being met including services such as:
• Analysis of relevant design
• Developments in the qualified plan landscape
• Educational modules
• Plan benchmarking
• Administrative Compliance Checklists
• Fiduciary Fitness Program Diagnostics
Consulting Services for Plan Participants
Kolinsky will provide plan participants with strategic employee education and communications in
connection with retirement plan programs. Kolinsky will assist participants by meeting with them
in a group or in one-to-one settings to help educate and create custom risk-based models utilizing
the offerings in the retirement plans.
Selection of Independent Managers
Kolinsky may recommend and refer clients to unaffiliated money managers or independent
managers through Managed Account programs sponsored by a third-party provider. In these
arrangements, the client will then enter into a program and investment advisory agreement with
the program sponsor and sub-advisors. Kolinsky will assist and advise the client in establishing
investment objectives for the sub-advisors and continue to provide oversight of the client account
and ongoing monitoring of the activities of the sub-advisors. The sub-advisors will develop an
investment strategy to meet those objectives by identifying appropriate investments and
monitoring such investments. Kolinsky evaluates a variety of information about the independent
managers, which may include the independent managers’ public disclosure documents, materials
supplied by the independent managers themselves and other third-party analyses it believes are
reputable. To the extent possible, Kolinsky seeks to assess the independent managers’ investment
strategies, past performance and risk results in relation to its clients’ individual portfolio
allocations and risk exposure. Kolinsky also takes into consideration each manager or sub-
advisors’ management style, returns, reputation, financial strength and reporting among other
factors. In consideration for such services, the program sponsor will charge a program fee that
includes the investment advisory fee of the sub-advisors, the administration of the program and
trading, clearance and settlement costs. The program sponsor will add Kolinsky’s investment
advisory fee (described below in the answer to Item 5) and will deduct the overall fee from the
client account quarterly in advance based on the fair market value at the end of the preceding
quarter. The asset-based program fee is tiered and varies depending on the size of the account, the
asset class of the underlying securities and the sub-advisor selected. The client, prior to entering
into an agreement with a third party money manager selected by Kolinsky, will be provided with
that manager’s Brochure that makes the appropriate disclosures. In addition, Kolinsky and its
client will agree in writing that the client’s account will be managed by that selected third party
money manager on a discretionary basis.
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American Funds
Kolinsky has an agreement to establish 529 investment advisory accounts directly through
American Funds in their F2 advisory share class funds. These accounts are managed by Kolinsky
based on the client’s needs, goals and objectives. The fee for such accounts varies from 0.00%-
0.50% per annum.
Kolinsky does not provide portfolio management services to wrap fee programs.
Additional Consulting Services
Kolinsky also provides 1031 Exchange consulting services, which, based on the client's individual
circumstances, may include but are not limited to the following: finding replacement properties,
connecting the client with qualified intermediaries, and developing the exchange strategy. Clients
receiving 1031 Exchange consulting services are charged an additional fixed fee as negotiated
based on the complexities of each exchange situation. Kolinsky may invoice the Client directly for
this service or alternatively the Client may elect to have the fee deducted from exchange proceeds
held at the Client’s Qualified Intermediary.
As of December 31, 2024, Kolinsky manages $493,754,689 of which $489,568,046 is managed
on a discretionary basis.
Item 5 Fees and Compensation
A. Fees Charged
All investment management clients will be required to execute an investment advisory contract
that will describe the type of management services to be provided and the fees, among other items.
Clients are advised that they may pay fees that are higher or lower than fees they may pay another
advisor for the same services. Clients are under no obligation at any time to engage or to continue
to engage, Kolinsky for investment services.
Financial Planning
In circumstances when financial planning is done on a stand-alone basis, the fees charged are based
on the fee agreed upon by the adviser and client. Typically, Kolinsky will charge a fixed fee for
services of up to $10,000 depending on the services to be provided as contracted for and negotiated
with client in advance. Clients may also contract to have financial planning advice provided based
on an hourly fee rather than based on the assets under management. The Advisors hourly fee will
be billed at a rate of $300 to $500 per hour, but may be negotiated in advance. The Advisors
hourly fees will be negotiated and agreed upon by the parties in advance. Hourly fee-based clients
are billed on a monthly basis upon completion of work performed.
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Asset Management
Generally, fees vary from 0.00% to 1.30% per annum of the market value of a client’s assets
managed by Kolinsky. Fees are negotiable, and the fee range stated is a guide. The fee chosen
within that range is determined in part by the nature of the account, including the size of the
account, complexity of asset structures, the nature of the ongoing work needed for that particular
client, the complexity of the portfolio, and other factors that would be dependent upon the specific
client.
Retirement Plan Consulting Services
For plan sponsors, fees for consulting on retirement plan options vary from 0.00% to 1.00% per
annum of the market value of the plan’s assets under the direction of Kolinsky or will be charged
a flat annual fee for service ranging from $3,000 to $50,000. These are the only fees, either direct
or indirect, that Kolinsky reasonably expects to receive from the plan. Fees are negotiable and
will be determined by the scope and nature of the services provided the size of the account, the
complexity of the plan document and other factors. Unless the plan sponsor elects to be invoiced
directly, asset-based fees will be calculated and deducted by the plan recordkeeper on either a
monthly or quarterly basis in arrears or in advance and distributed to Kolinsky.
For asset management clients with Retirement Plans, fees for choosing and monitoring plan
options will vary depending upon the available options in the plan, the client’s needs, and
frequency of desired monitoring. Retirement Plan Consulting fees are negotiable and are
dependent on the nature of the engagement in the sole discretion of Kolinsky.
American Funds
For client whose accounts are held directly at American Funds, fees will be debited directly from
each client’s account by the American Funds Service Company. The fee is paid quarterly, in
arrears. The fee shall be the calculated by multiplying the average daily net asset value of client
assets during the quarter by clients annual fee rate, then dividing by the number of days in the year
and multiplying that number by days in that quarter. There are no trading fees to buy or sell F-2
shares in these accounts. American Funds may impose account setup fees for certain account types.
See the American Funds application, prospectus or Statement of Additional Information for
details.
Retirement Account Rollovers
Depending on a client’s given circumstances, Kolinsky may recommend that a client rollover
retirement plan assets to an Individual Retirement Account (IRA) managed by us. As a result of
a rollover, Kolinsky may earn fees on those accounts. This presents a conflict of interest, as
Kolinsky has a financial incentive to recommend that a client roll over retirement assets into an
IRA we will manage. This conflict is disclosed to clients verbally and in this brochure. Clients
are also advised that they are under no obligation to implement the recommendation to roll over
retirement plan assets. Kolinsky attempts to mitigate this conflict by requiring that all investment
recommendations have a sound basis for the recommendation, and by requiring employees to
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acknowledge their fiduciary responsibility toward each client. When we provide investment advice
to you regarding your retirement plan account or individual retirement account, we are fiduciaries
within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal
Revenue Code, as applicable, which are laws governing retirement accounts. The way we make
money creates some conflicts with your interests, so we operate under a special rule that requires
us to act in your best interest and not put our interest ahead of yours. Under this special rule’s
provisions, we must: • Meet a professional standard of care when making investment
recommendations (give prudent advice); • Never put our financial interests ahead of yours when
making recommendations (give loyal advice); • Avoid misleading statements about conflicts of
interest, fees, and investments; • Follow policies and procedures designed to ensure that we give
advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give
you basic information about conflicts of interest.
Additional Fees
For a limited portion of client accounts, we utilize the unified managed account program provided
by Adhesion to access third-party managers. The accounts in Adhesion’s unified managed account
program may pay an annual manager fee up to 0.50% depending on the manager(s) selected, in
addition to the annual advisory fee described above. This additional fee is collected alongside the
advisory fee described above and the applicable client portion is paid by Kolinsky to Adhesion.
We make available and, where appropriate and permitted by applicable law, may select our own
manager option within the Adhesion Wealth unified managed account program to manage client
accounts. Where we select this option for a client, we will receive the manager fee for those
accounts. This creates a conflict of interest because we will receive the manager fee in addition to
the annual advisory fee and additional annual advisory fee. Clients will receive statements from
the custodian that present the fees charged to accounts and may also ask us at any time for a
description and accounting of the annual advisory fees, additional annual advisory fees and
manager fees being charged.
In addition to the fees charged above, all UMA/SMA program assets (accounts on the Adhesion
platform), and all Kolinsky model accounts are assessed an additional 0.05% Wealth Management
Platform fee. This fee is payable to Kolinsky and compensates the firm for the additional services
paid for by Kolinsky to deliver UMA/SMA, Model Management, and reporting services.
Kolinsky provides clients access to Addepar, Inc., a wealth management platform for registered
investment advisors, specializing in data aggregation, analytics, and portfolio reporting. Addepar
allows Kolinsky to provide reporting and analytics services to all client assets including those not
under Kolinsky’s direct management but under our advisement. Certain client assets under our
advisement but not direct management may include securities not subject to an advisory fee that
we are holding for a client such as Pontera accounts, cash management accounts, real estate and
alternative investment securities, managed bond accounts directly through Schwab’s SMA
platform, securities held inside of a UMA/SMA program or KWM model accounts that are not
part of the manager or model positions, and any security or investment that the client requests
reporting services be provided for that is not part of a model or UMA/SMA program account. For
these assets Kolinsky assesses a 0.03% Wealth Management Platform fee.
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The Wealth Management Platform fee may be waived or reduced at the discretion of Kolinsky.
B. Fee Payment
Asset Management fees will be debited directly from each client’s account. The advisory fee is
paid quarterly, in advance, based upon the market value of the assets being managed by Kolinsky
on the last day of the previous billing period as valued by the custodian of your assets. This means
that if your annual fee is 1.0%, we will take the previous quarter’s ending value, multiply the value
by 1.0%, then divide by four to calculate our fee. To the extent there is cash in your account, it
will be included in the value for the purpose of calculating fees unless otherwise agreed upon
between Kolinsky and the Client. Once the calculation is made, we will instruct your account
custodian to deduct the fee from your account and remit it to Kolinsky. Clients whose fees are
directly debited will provide written authorization to debit advisory fees from their accounts held
by the qualified custodian. Each quarter, the client will receive a statement from their account
custodian showing all transactions in their account, including the fee. Clients may be invoiced
directly upon request.
Financial planning fees will be due upon receipt of invoice from Kolinsky. In many cases, clients
will be asked to put forth a retainer at the onset of the engagement which may be for up to 50% of
the expected final cost.
Fixed Fees: Fixed fee-based clients are billed either quarterly, semi-annually, or annually in
advance, but in no event will the Advisor charge more than $1200 for services six or more months
in advance.
C. Other Fees
There are a number of other fees that can be associated with holding and investing in securities. In
addition to the advisory fees paid to Kolinsky, clients may also incur certain charges imposed by
other third parties, such as broker-dealers, custodians, trust companies, banks and other financial
institutions (collectively “Financial Institutions”). These additional charges may include securities
brokerage commissions, transaction fees, custodial fees, fees charged by the Independent
Managers, margin costs, charges imposed directly by a mutual fund or ETF in a client’s account,
as 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. For complete
discussion of expenses related to each mutual fund or ETF clients should read a copy of the
prospectus issued by that fund. Kolinsky can provide or direct clients to a copy of the prospectus
for any fund that we recommend. Kolinsky may also charge a fee to clients for utilizing their
performance management system, Envestnet. For clients who receive reporting only services from
Envestnet the additional fee for that service would be .03% of their account value with a minimum
fee of $30.
Please make sure to read Item 10 and Item 12 of this informational brochure, where we discuss
additional broker-dealer, custodial issues, and brokerage practices.
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D. Pro-rata Fees
If you become a client during a quarter, you will pay a management fee for the number of days left
in that quarter. If you terminate the relationship during a quarter, you will be entitled to a refund
of any management fees for the remainder of the quarter. Once your notice of termination is
received, we will assess pro-rated fees for the number of days between the end of the prior billing
period and the date of termination. Kolinsky’s reporting system; Envestnet will then adjust the fee
in your account accordingly and reimburse the account for any amount owed. Kolinsky will cease
to perform services, including processing trades and distributions, upon termination. Assets not
transferred from terminated accounts within 30 (thirty) days of termination may be “de-linked”,
meaning they will no longer be visible to Kolinsky and will become a retail account with the
custodian.
E. Compensation for the Sale of Securities
To permit Kolinsky clients to have access to as many investment solutions as possible, certain
employees of Kolinsky are registered representatives of KWM Securities, LLC., a registered
broker‐dealer and a FINRA member. This relationship allows these professionals to provide
additional products to clients’ portfolios that would not otherwise be available. KWM Securities
is affiliated with Kolinsky through common ownership and control. Registered representative
status enables these professionals to receive customary commissions for the sales of various
securities, including those recommended to clients. Commission charges for these products will
not offset management fees owed to Kolinsky.
Receipt of commissions for investment products that are recommended to clients gives rise to a
conflict of interest for the representative, in that the individual who will receive the commissions
is also the individual that is recommending that the client purchase a given product. This conflict
is disclosed to clients verbally and in this brochure. Clients are advised that they may choose to
implement any investment recommendation through another broker-dealer that is not affiliated
with Kolinsky. Kolinsky attempts to mitigate this conflict by requiring that all investment
recommendations have a sound basis for the recommendation, and by requiring employees to
acknowledge their fiduciary responsibility toward each client. Clients are not obligated to
implement any recommendation provided by Kolinsky. Any commission-based transactions will
be disclosed to clients prior to the transaction being effected.
Neither Kolinsky nor its Investment Advisor Representatives receive more than 50% of their
revenue from commissions or other compensation from the sale of investment products.
Advisory fees will not be charged to clients on any investment products for which they pay a
commission.
Item 6 Performance-Based Fees and Side-by-Side Management
Kolinsky does not charge performance-based fees.
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Item 7 Types of Clients
The Advisor will offer its services to individuals, pension and profit sharing plans, trusts, estates,
charitable organizations, corporations, and business entities. Except for accounts discussed below,
Advisor does not have any minimum requirements for opening or maintaining an account.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
It is important for clients to know and remember that all investments carry risks. Investing in
securities involves risk of loss that clients should be prepared to bear.
Each client’s portfolio will be invested according to that client’s investment objectives, which are
ascertained through the financial planning process or with a risk assessment questionnaire and
client dialogue. The goal with asset management is to take the financial plan and implement it
while continually updating it as circumstances change. Because the plan is based on information
supplied by you, it is very important that you accurately and completely communicate to us the
information we need. Also, your circumstances and needs may change as your engagement with
us progresses. It is very important that you continually update us with any changes so that if the
updates require changes to your plan, we can make those changes. Otherwise, your plan or risk
assessment may no longer be accurate.
Once we ascertain your objectives for each account, we will develop a set of asset allocation
guidelines, found in one of our investment models. Client portfolios may be invested in one
strategy, or a combination of strategies. For some clients where the investment models may not
be appropriate either based on tax considerations or other unique needs a different strategy or
model may be created based on that client’s unique investment considerations. The strategies are
developed utilizing outside research and investment ideas, combined with Kolinsky’s views on
both individual securities and the markets and economy as a whole.
Kolinsky’s family of portfolios consists of nine investment models targeting the full range of
investor risk profiles. The current models include fixed income, capital preservation, conservative,
income growth, conservative growth, moderate, moderate growth, growth, and aggressive growth.
We also offer our clients a variety of options strategies through a separate account manager. These
strategies are generally designed to provide clients with income that is uncorrelated to the
performance of their underlying investments held as collateral. Alternatively, the options strategies
may be used to enhance the returns of an underlying concentrated position or to protect the
downside of an equity or an index.
Kolinsky’s primary approach is to use both strategic and tactical allocation strategies aimed at
reducing risk and increasing performance. Kolinsky uses exchange listed securities, over-the-
counter securities, foreign securities, corporate debt securities, CDs, municipal securities, mutual
funds, United States government securities, and options in securities to accomplish this objective.
Kolinsky measures and selects mutual funds by using various criteria, such as the fund manager's
tenure, and/or overall career performance. Kolinsky may recommend, on occasion, redistributing
investment allocations to diversify the portfolio in an effort to reduce risk and increase
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performance. Kolinsky may recommend specific stocks to increase sector weighting and/or
dividend potential. Kolinsky may recommend employing cash positions as a possible hedge
against market movement which may adversely affect the portfolio. Kolinsky 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 client, or any risk
deemed unacceptable for the client's risk tolerance.
There are no limits to the types of securities that may be placed in a strategy, or that Kolinsky may
evaluate for a client or for inclusion in a strategy. However, investment types most typically
include mutual funds and exchange traded funds (ETFs).
Kolinsky also offers cash management portfolios customized to each client’s tax status, state of
residence, and cash flow needs. Each portfolio is designed to deliver preservation of capital,
reliable income streams and competitive total return.
Most mutual funds offer different share classes with varying fee structures, including share classes
with sales load, sales charges, or 12B-1 fees. Neither Kolinsky, nor any employees thereof receive
any commissions or 12B-1 related fees for the sale of securities to Kolinsky Wealth Management’s
advisory clients. 12B-1 fees are deducted from the mutual funds’ assets on an ongoing basis, and
are paid to broker-dealers and registered representatives whose clients own those shares to cover
fund distribution and shareholder services. This receipt of fees presents a potential conflict of
interest, as advisors have an incentive to recommend more expensive share classes to clients based
on the compensation received, rather than based upon the client’s needs. However, it is Kolinsky’s
policy that when specific funds offer more than one share class, Kolinsky will select the lowest-
cost share class available to the client, absent circumstances that dictate otherwise.
As assets are transitioned from a client’s prior advisers to Kolinsky, there may be securities and
other investments that do not fit within the asset allocation strategy selected for the client.
Accordingly, these investments will need to be sold in order to reposition the portfolio into the
asset allocation strategy selected by Kolinsky. However, this transition process may take some
time to accomplish. Some investments may not be unwound for a lengthy period of time for a
variety of reasons that may include unwarranted low share prices, restrictions on trading,
contractual restrictions on liquidity, or market-related liquidity concerns. In some cases, there may
be securities or investments that are never able to be sold. If a client transitions mutual fund shares
to Kolinsky that are not the lowest-cost share class, and Kolinsky is not recommending disposing
of the security altogether, Kolinsky will attempt to convert such mutual fund share classes into the
lowest-cost share classes the client is eligible for, taking into account any adverse tax consequences
associated with such conversion. In the event an investment in a client account is unable to be
unwound for a period of time, Kolinsky will monitor the investment as part of its services to the
client. Kolinsky may suggest that a given investment be moved to a separate account.
Investing includes the risk that the value of an investment can be negatively affected by factors
specifically related to the investment (e.g., capability of management, competition, new inventions
by other companies, lawsuits against the company, labor issues, patent expiration, etc.), or to
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factors related to investing and the markets in general (e.g., the economy, wars, civil unrest or
terrorism around the world, concern about oil prices or unemployment, etc.).
Risks of fundamental analysis may include risks that market actions, natural disasters, government
actions, world political events or other events not directly related to the price or valuation of a
specific company’s fundamental analysis can adversely impact the stock price of a company
causing a portfolio containing that security to lose value. Risks may also include that the historical
data and projections on which the fundamental analysis is performed may not continue to be
relevant to the operations of a company going forward, or that management changes or the business
direction of management of the company may not permit the company to continue to produce
metrics that are consistent with the prior company data utilized in the fundamental analysis, which
may negatively affect the Advisor’s estimate of the valuation of the company.
Clients are advised that many unexpected broad environmental factors can negatively impact the
value of portfolio securities causing the loss of some or all of the investment, including changes in
interest rates, political events, natural disasters, and acts of war or terrorism. Further, factors
relevant to specific securities may have negative effects on their value, such as competition or
government regulation. Also, the factors for which the company was selected for inclusion in a
client portfolio may change, for example, due to changes in management, new product
introductions, or lawsuits.
Every type of investment, including mutual funds, involves risk. Risk refers to the possibility that
you will lose money (both principal and any earnings) or fail to make money on an investment. A
fund's investment objective and its holdings are influential factors in determining how risky a fund
is. Reading the prospectus will help you to understand the risk associated with that particular
fund.
Generally speaking, risk and potential return are related. This is the risk/return trade-off. Higher
risks are usually taken with the expectation of higher returns at the cost of increased
volatility. While a fund with higher risk has the potential for higher return, it also has the greater
potential for losses or negative returns. The school of thought when investing in mutual funds
suggests that the longer your investment time horizon is the less affected you should be by short-
term volatility. Therefore, the shorter your investment time horizon, the more concerned you
should be with short-term volatility and higher risk.
Below is a list of some but not all of the risks to consider when investing.
• Call Risk. The possibility that falling interest rates will cause a bond issuer to redeem—or
call—its high-yielding bond before the bond's maturity date.
• Country Risk. The possibility that political events (a war, national elections), financial
problems (rising inflation, government default), or natural disasters (an earthquake, a poor
harvest) will weaken a country's economy and cause investments in that country to decline.
• Credit Risk. The possibility that a bond issuer will fail to repay interest and principal in a
timely manner. Also called default risk.
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•
•
•
•
• Currency Risk. The possibility that returns could be reduced for Americans investing in
foreign securities because of a rise in the value of the U.S. dollar against foreign currencies.
Also called exchange-rate risk.
Income Risk. The possibility that a fixed-income fund's dividends will decline as a result
of falling overall interest rates.
Industry Risk. The possibility that a group of stocks in a single industry will decline in
price due to developments in that industry.
Inflation Risk. The possibility that increases in the cost of living will reduce or eliminate
a fund's real inflation-adjusted returns.
Interest Rate Risk. The possibility that a bond fund will decline in value because of an
increase in interest rates.
the fund
is riskier
than alternatives which do not employ
• Leveraged/Inverse ETF Risk Leveraged ETFs seek to deliver multiples of the
performance of the index of benchmark they track whereas Inverse ETFs seek to deliver
the opposite of the performance of the index or benchmark they track. These products are
more volatile than investing in broadly diversified fund and the use of leverage by a fund
means
leverage.
Leveraged/Inverse ETFs carry liquidity risks and are speculative investments, they are not
designed to be used as long-term investments vehicles. These funds tend to carry higher
fees, due to active management, which can also affect performance.
• Manager Risk. The possibility that an actively managed mutual fund's investment adviser
will fail to execute the fund's investment strategy effectively resulting in the failure of
stated objectives.
• Market Risk. The possibility that stock fund or bond fund prices overall will decline over
short or even extended periods. Stock and bond markets tend to move in cycles, with
periods when prices rise and other periods when prices fall.
• Principal Risk. The possibility that an investment will go down in value, or "lose money,"
from the original or invested amount.
• Futures and Options Risks Futures and options may be more volatile than direct
investments in the securities underlying the futures and options, may not correlate perfectly
to the underlying securities, may involve additional costs, and may be illiquid. Futures and
options also may involve the use of leverage which could result in losses greater than if
futures or options had not been used. Futures and options are also subject to the risk that
the other party to the transaction may default on its obligation. Options Writing involves a
contract to purchase/sell a security at a given price, not necessarily at market value,
depending on the market. Options writing can lose value over time because there is an
expiration date; whereas, stocks do not have an expiration date. Options owners also do
not receive the benefits of owning stocks unless a call option is exercised; and conversely,
an owner of a put option that also owns the underlying stock, would have related risks.
• Margin Risk: Margin is an investment strategy with a high level of inherent risk. A margin
transaction occurs when an investor uses borrowed assets to purchase financial
instruments. The investor generally obtains the borrowed assets by using other securities
as collateral for the borrowed sum. The effect of purchasing a security using margin is to
magnify any gains or losses sustained by the purchase of the financial instruments on
margin. Please Note: To the extent that a client authorizes the use of margin, and margin
is thereafter employed in the management of the client’s investment portfolio, the market
value of the client’s account and corresponding fee payable by the client may be increased.
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As a result, in addition to understanding and assuming the additional principal risks
associated with the use of margin, clients authorizing margin are advised of the potential
conflict of interest whereby the client’s decision to employ margin may correspondingly
increase the management fee payable. Accordingly, the decision as to whether to employ
margin is left totally to the discretion of client.
• Cryptocurrency Risk. Cryptocurrency (notably, bitcoin), often referred to as “virtual
currency”, “digital currency,” or “digital assets,” operates as a decentralized, peer-to-peer
financial exchange and value storage that is used like money. Clients may have exposure
to bitcoin, a cryptocurrency, indirectly through an investment such as the Greyscale Bitcoin
Investment Trust (“GBTC”), a privately offered, open-end investment vehicle, or other
investment vehicles. Clients may also have exposure to cryptocurrencies other than
bitcoin. Cryptocurrency operates without central authority or banks and is not backed by
any government. Even indirectly, cryptocurrencies (i.e., bitcoin) may experience very high
volatility and related investment vehicles like GBTC may be affected by such volatility.
Certain Crypto-related investments held by Clients may also trade at a significant premium
to NAV. Cryptocurrency is also not legal tender. Federal, state or foreign governments may
restrict the use and exchange of cryptocurrency, and regulation in the U.S. is still
developing. The SEC has issued a public report stating U.S. federal securities laws require
treating some digital assets as securities. Cryptocurrency exchanges may stop operating or
permanently shut down due to fraud, technical glitches, hackers or malware. Due to its
relatively recent launch, bitcoin has a limited trading history, making it difficult for
investors to evaluate investments in this cryptocurrency. It is also possible that a
cryptocurrency other than bitcoin, including cryptocurrencies in which Clients have limited
or no exposure to, could become materially popular and have a negative impact on the
demand for and price of bitcoin. It is possible that another entity could manipulate the
blockchain in a manner that is detrimental to the bitcoin network. Bitcoin transactions are
irreversible such that an improper transfer can only be undone by the receiver of the bitcoin
agreeing to return the bitcoin to the original sender. Digital assets are highly dependent on
their developers and there is no guarantee that development will continue or that developers
will not abandon a project with little or no notice. Third parties may assert intellectual
property claims relating to the holding and transfer of digital assets, including
cryptocurrencies, and their source code. Any threatened action that reduces confidence in
a network’s long-term ability to hold and transfer cryptocurrency may affect investments
in cryptocurrencies.
• Market Disruption, Health Crisis, Terrorism and Geopolitical Risk. Investments are
subject to the risk that war, terrorism, global health crises or similar pandemics, and other
related geopolitical events increase short-term market volatility and may have adverse
long-term effects on world economics and markets generally. These risks have previously
led and may lead in the future to adverse effects on the value of client’s investments.
In addition, in many circumstances Kolinsky may recommend a portion of the client’s account be
allocated to real estate investment trusts, otherwise known as “REITs” and/or other private
investments.
• REITs: A REIT is an entity, typically a trust or corporation that accepts investments from
a number of investors, pools the money, and then uses that money to invest in real estate
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through either actual property purchases or mortgage loans. While there are some benefits
to owning REITs, which include potential tax benefits, income and the relatively low
barrier to invest in real estate as compared to directly investing in real estate, REITs also
have some increased risks as compared to more traditional investments such as stocks,
bonds, and mutual funds. First, real estate investing can be highly volatile. Second, the
specific REIT chosen may have a focus such as commercial real estate or real estate in a
given location. Such investment focus can be beneficial if the properties are successful,
but lose significant principal if the properties are not successful. REITs may also employ
significant leverage for the purpose of purchasing more investments with fewer investment
dollars, which can enhance returns but also enhances the risk of loss. The success of a
REIT is highly dependent upon the manager of the REIT. Clients should ensure they
understand the role of the REIT in their portfolio.
• Risks specific to private placements, sub-advisors and other managers. If we invest some of
your assets with another advisor, including a private placement, there are additional risks.
These include risks that the other manager is not as qualified as we believe them to be, that
the investments they use are not as liquid as we would normally use in your portfolio, or
that their risk management guidelines are more liberal than we would normally employ.
• Structured Products. Structured products are securities derived from another asset, such
as a security or a basket of securities, an index, a commodity, a debt issuance, or a foreign
currency. Structured products frequently limit the upside participation in the reference
asset. Structured products are senior unsecured debt of the issuing bank and subject to the
credit risk associated with that issuer. This credit risk exists whether or not the investment
held in the account offers principal protection. The creditworthiness of the issuer does not
affect or enhance the likely performance of the investment other than the ability of the
issuer to meet its obligations. Any payments due at maturity are dependent on the issuer’s
ability to pay. In addition, the trading price of the security in the secondary market, if there
is one, may be adversely impacted if the issuer’s credit rating is downgraded. Some
structured products offer full protection of the principal invested, others offer only partial
or no protection. Investors may be sacrificing a higher yield to obtain the principal
guarantee. In addition, the principal guarantee relates to nominal principal and does not
offer inflation protection. An investor in a structured product never has a claim on the
underlying investment, whether a security, zero coupon bond, or option. There may be little
or no secondary market for the securities and information regarding independent market
pricing for the securities may be limited. This is true even if the product has a ticker symbol
or has been approved for listing on an exchange. Tax treatment of structured products may
be different from other investments held in the account (e.g., income may be taxed as
ordinary income even though payment is not received until maturity). Structured CDs that
are insured by the FDIC are subject to applicable FDIC limits.
• Excess Cash Balance Risk. Client accounts may have cash balances in excess of
$250,000, which is the insurance limit of the Federal Deposit Insurance Corporation. For
cash balances in excess of that amount, there is an enhanced risk that operation related
counterparty risk related to the account custodian could cause losses in the account. We
mitigate this risk by carrying cash balances in amounts either subject to protection or as
limited as you, the client, directs.
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Item 9 Disciplinary Information
In this Item Kolinsky is required to disclosure certain disciplinary history material to a client’s
evaluation of the firm and its supervised persons. There are currently no disciplinary matters to
report.
Item 10 Other Financial Industry Activities and Affiliations
A.
Broker-dealer
Please refer to Item 5E with regards to individuals registered in their capacities with broker-
dealers.
KWM Securities, LLC an affiliated company that is under common ownership and control of
Kolinsky is a FINRA member broker-dealer.
B.
Futures Commission Merchant/Commodity Trading Advisor
Neither the principal of Kolinsky nor any of its management persons are registered or have an
application pending to register, as a futures commission merchant, commodity pool operator, a
commodity trading advisor, or an associated person of the foregoing entities.
C.
Relationship with Related Persons
Investment Advisor Representatives for Kolinsky are also licensed and registered as insurance
agents to sell life or other lines of insurance for various insurance companies, and do so through a
related entity, Kolinsky Financial Group, Inc. Therefore, they will be able to purchase insurance
products for any client in need of such services and will receive separate, yet typical compensation
in the form of commissions or referral fees. A conflict of interest exists because of the receipt of
additional compensation by the Investment Advisor Representatives. Clients are not obligated to
use Kolinsky Financial Group, Inc. for insurance products services. In such instances, there is no
advisory fee associated with these insurance products.
Anthony Picinich, an investment adviser representative of Kolinsky, is a partner in Gosen &
Picinich Inc., a public accounting firm. Advisory clients needing assistance with accounting
matters and tax preparation may be referred to Mr. Picinich and his firm. Clients are not obligated
to use Mr. Picinich for accounting matters. If they do, accounting fees are billed separately from
advisory fees charged by Kolinsky. In addition, Mr. Picinich may refer accounting clients needing
assistance with investment advisory matters to Kolinsky. Mr. Picinich may receive compensation
for this referral. This arrangement presents a potential conflict of interest because Mr. Picinich
may receive fees from both companies in his separate capacities as an accountant and an
investment advisor representative.
While Kolinsky endeavors at all times to put the interests of its clients first as part of their fiduciary
duty, clients should be aware that the receipt of additional compensation itself creates a conflict of
interest. Kolinsky attempts to mitigate this conflict through administration of the Code of Ethics,
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disclosure to clients, and an affirmation of all representatives to commit to place clients interest
ahead of their own.
Kolinsky is under common ownership and control with KWM TPA Services, LLC, an entity that
provides retirement plan sponsors with administrative support and related services. Kolinsky
clients engaging KWM TPA Services will do so under a separate agreement requiring an additional
fee. Kolinsky clients receiving investment management services are under no obligation to engage
KWM TPA Services and may do business with any unrelated third party of their choosing.
Recommendations of other Advisers
Kolinsky does recommend or select other investment advisors for clients. For more specific detail
see the response to Item 4 above.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
A.
A copy of our Code of Ethics is available upon request. Our Code of Ethics includes
discussions of our fiduciary duty to clients, political contributions, gifts, entertainment, and trading
guidelines.
Not applicable. Kolinsky does not recommend to clients that they invest in any security in
B.
which Kolinsky or any principal thereof has any financial interest.
C.
On occasion, an employee of Kolinsky may purchase for his or her own account securities
which are also recommended for clients. Our Code of Ethics details rules for employees regarding
personal trading and avoiding conflicts of interest related to trading in one’s own account. To
avoid placing a trade before a client (in the case of a purchase) or after a client (in the case of a
sale), all employee trades are reviewed by the Compliance Officer. All employee trades must
either take place in the same block as a client trade or sufficiently apart in time from the client
trade so the employee receives no added benefit. Employee statements are reviewed to confirm
compliance with the trading procedures.
D.
On occasion, an employee of Kolinsky may purchase for his or her own account securities
which are also recommended for clients at the same time the clients purchase the securities. Our
Code of Ethics details rules for employees regarding personal trading and avoiding conflicts of
interest related to trading in one’s own account. To avoid placing a trade before a client (in the
case of a purchase) or after a client (in the case of a sale), all employee trades are reviewed by the
Compliance Officer. All employee trades must either take place in the same block as a client trade
or sufficiently apart in time from the client trade so the employee receives no added benefit.
Employee statements are reviewed to confirm compliance with the trading procedures.
Item 12 Brokerage Practices
A. Recommendation of Broker-Dealer
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Kolinsky does not maintain custody of client assets; though Kolinsky may be deemed to have
custody if a client grants Kolinsky custody if a client grants Kolinsky authority to debit fees
directly from their account (see Item 15 below). Assets will be held with a qualified custodian,
which is typically a bank or broker-dealer. Kolinsky recommends that investment accounts be
held in custody by Schwab Advisor Services (“Schwab”), and Pershing Advisor Solutions
(“Pershing”) which are both qualified custodians. Kolinsky is independently owned and operated
and is not affiliated with Schwab or Pershing. Schwab and/or Pershing will hold your assets in a
brokerage account and buy and sell securities when Kolinsky instructs them to, which Kolinsky
does in accordance with its agreement with you. While Kolinsky recommends that you use Schwab
or Pershing as a custodian/broker, you will decide whether to do so and will open your account
directly with Schwab or Pershing by entering into an account agreement directly with them.
Kolinsky does not open the account for you, although Kolinsky may assist you in doing so. Even
though your account is maintained at Schwab or Pershing, we may use other brokers to execute
trades for your account as described below (see “Your brokerage and custody costs”).
How we select brokers/custodians
We seek to recommend a custodian/broker that will hold your assets and execute transactions on
terms that are, overall, most advantageous when compared with other available providers and their
services. We consider a wide range of factors, including both quantitative (Ex: costs) and
qualitative (execution, reputation, service) factors. We do not consider whether Schwab, Pershing
or any other broker-dealer/custodian, refers clients to Kolinsky as part of our evaluation of these
broker-dealers.
As mentioned, Kolinsky is independently owned and operated and is not affiliated with Schwab.
Schwab will hold your assets in a brokerage account and buy and sell securities when Kolinsky
instructs them to, which Kolinsky does in accordance with its agreement with you. While Kolinsky
recommends that you use CS&Co. as custodian/broker, you will decide whether to do so and will
open your account with CS&Co. by entering into an account agreement directly with them.
Kolinsky does not open the account for you, although Kolinsky may assist you in doing so.
Your brokerage and custody costs
For our clients’ accounts that Schwab and/or Pershing maintain, the custodian generally does not
charge you separately for custody services but is compensated by charging you commissions or
other fees on trades that it executes or that settle into your account. In addition to commissions,
the custodian charges you a flat dollar amount as a “prime broker” or “trade away” fee for each
trade that we have executed by a different broker-dealer but where the securities bought or the
funds from the securities sold are deposited (settled) into your account. These fees are in addition
to the commissions or other compensation you pay the executing broker-dealer. Because of this,
in order to minimize your trading costs, we have Schwab and/or Pershing execute most trades for
your accounts. We have determined that having Schwab and Pershing execute most trades it is
consistent with our duty to seek “best execution” of your trades. Best execution means the most
favorable terms for a transaction based on all relevant factors, including those listed above (see
“How we select brokers/custodians”).
Products and services available to us from Schwab and Pershing
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Schwab Advisor Services™ (formerly called Schwab Institutional®) is Schwab’s business serving
independent investment advisory firms like Kolinsky. Pershing Advisor Solutions, LLC
(“Pershing”) is Pershing’s business serving investment advisors. They both provide Kolinsky and
our clients with access to its institutional brokerage services (trading, custody, reporting, and
related services), many of which are not typically available to retail customers. They also make
available various support services. Some of those services help Kolinsky manage or administer
our clients’ accounts, while others help Kolinsky manage and grow our business. These support
services are generally available on an unsolicited basis (we don’t have to request them) and at no
charge to Kolinsky/ The following is a more detailed description of Schwab’s support services:
Services that benefit you.
Schwab and Pershing’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of client assets. The
investment products available through these custodians include some to which we might not
otherwise have access or that would require a significantly higher minimum initial investment by
our clients. The services described in this paragraph generally benefit you and your account.
Services that may not directly benefit you.
Schwab and Pershing also makes available to us other products and services that benefit us but
may not directly benefit you or your account. These products and services assist us in managing
and administering our clients’ accounts. They include investment research, both proprietary and
that of third parties. We may use this research to service all or a substantial number of our clients’
accounts, including accounts not maintained at Schwab or Pershing. In addition to investment
research, Schwab and Pershing also make available software and other technology that:
•Provide access to client account data (such as duplicate trade confirmations and account
statements)
•Facilitate trade execution and allocate aggregated trade orders for multiple client
accounts
•Provide pricing and other market data
•Facilitate payment of our fees from our clients’ accounts
•Assist with back-office functions, recordkeeping, and client reporting
Services that generally benefit only us.
Schwab and Pershing may also offers other services intended to help us manage and further
develop our business enterprise. These services include:
• Educational conferences and events
• Consulting on technology, compliance, legal, and business needs
• Publications and conferences on practice management and business succession
• Access to employee benefits providers, human capital consultants, and insurance
providers
• Assistance related to the transition of client assets from prior firms
Both Schwab and Pershing may provide some of these services and in other cases, it will arrange
for third-party vendors to provide the services to us. Both may also discount or waive its fee for
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some of these services or pay all or a part of a third party’s fees. They may also provide us with
other benefits, such as occasional business entertainment of our personnel.
B.
Aggregating Trades
Commission costs per client may be lower on a particular trade if all clients in whose accounts the
trade is to be made are executed at the same time. This is called aggregating trades. Instead of
placing a number of trades for the same security for each account, we will, when appropriate,
executed one trade for all accounts and then allocate the trades to each account after execution. If
an aggregate trade is not fully executed, the securities will be allocated to client accounts on a pro
rata basis, except where doing so would create an unintended adverse consequence (For example,
¼ of a share, or a position in the account of less than 1%.)
Directed Brokerage
Kolinsky does not allow clients to direct brokerage. “Directing” brokerage means choosing to
maintain all or some of their assets with a broker-dealer that is not recommended by Kolinsky.
Kolinsky may be unable to achieve most favorable execution of client transactions if clients choose
to direct brokerage. This may cost clients’ money because without the ability to direct brokerage
Kolinsky may not be able to aggregate orders to reduce transactions costs resulting in higher
brokerage commissions and less favorable prices. Not all investment advisers allow their clients
to direct brokerage.
Item 13 Review of Accounts
All accounts and corresponding financial plans will be managed on an ongoing basis, with formal
reviews with the client by the client’s investment advisor representative on at least an annual basis
given the availability of the client. However, it is expected that market conditions, changes in a
particular client’s account, or changes to a client’s circumstances will trigger a review of accounts.
Item 14 Client Referrals and Other Compensation
A.
Economic Benefit Provided by Third Parties for Advice Rendered to Client
Please refer to Item 12, where we discuss recommendation of Broker-Dealers.
Kolinsky receives an economic benefit from Schwab in the form of the support products and
services it makes available to us. These products and services, how they benefit us, and the related
conflicts of interest are described above under Item 12 Brokerage Practices. The availability to us
of Schwab’s products and services is not based on us giving particular investment advice, such as
buying particular securities for our clients.
Kolinsky may from time to time receive compensation from the mutual fund companies that are
available to our customers. These payments are made in connection with programs that support
our marketing, education, and client service efforts. Kolinsky does not receive any part of these
payments rather they are made to sponsor or reimburse expenses for these events.
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B.
Compensation to Non-Advisory Personnel for Client Referrals
Clients may be introduced to Kolinsky via other third parties. In the event that Kolinsky
compensates any party for the referral of a client to Kolinsky, any such compensation will be paid
by Kolinsky, and not the client. If the client is introduced to Kolinsky by an unaffiliated third
party, that third party will disclose to the client the referral arrangement with Kolinsky, including
the compensation for the referral, their status as a client of Kolinsky, and any material conflicts of
interest the client may need to be made aware of.
Item 15 Custody
There are two avenues through which Kolinsky has custody of client funds; by directly debiting
its fees from client accounts pursuant to applicable agreements granting such right, and potentially
by permitting clients to issues standing letters of authorization (“SLOAs”). SLOAs permit a client
to issue one document that directs Kolinsky to make distributions out of the client’s account(s).
Clients whose fees are directly debited will provide written authorization to debit advisory fees
from their accounts held by a qualified custodian chosen by the client. Each quarter, clients will
receive a statement from their account custodian showing all transactions in their account,
including the fee.
We encourage clients to carefully review the statements and confirmations sent to them by their
custodian, and to compare the information on your quarterly report prepared by Kolinsky against
the information in the statements provided directly from their account custodian. Please alert us
of any discrepancies.
In addition to the account custodian’s custody procedures, clients issuing SLOAs will be requested
to confirm, in writing, that the accounts to which funds are distributed are parties unrelated to
Kolinsky.
Item 16 Investment Discretion
When Kolinsky is engaged to provide asset management services on a discretionary basis, we will
monitor your accounts to ensure that they are meeting your asset allocation requirements. If any
changes are needed to your investments, we will make the changes. These changes may involve
selling a security or group of investments and buying others or keeping the proceeds in cash. You
may at any time place restrictions on the types of investments we may use on your behalf, or on
the allocations to each security type. You may receive at your request written or electronic
confirmations from your account custodian after any changes are made to your account. You will
also receive quarterly statements from your account custodian. Clients engaging us on a
discretionary basis will be asked to execute a Limited Power of Attorney (granting us the
discretionary authority over the client accounts) as well as an Investment Management Agreement
that outlines the responsibilities of both the client and Kolinsky.
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Item 17 Voting Client Securities
From time to time, shareholders of stocks, mutual funds, exchange traded funds or other securities
may be permitted to vote on various types of corporate actions. Examples of these actions include
mergers, tender offers, or board elections. Clients are required to vote proxies related to their
investments, or to choose not to vote their proxies. Kolinsky will not accept authority to vote client
securities. Clients will receive their proxies directly from the custodian for the client account.
Kolinsky will not give clients advice on how to vote proxies.
Item 18 Financial Information
Kolinsky does not require or solicit prepayment of more than $1,200 in fees per client, six months
or more in advance, and therefore has not provided a balance sheet with this brochure.
Kolinsky has discretionary authority over client accounts and is not aware of any financial
condition that will likely impair its ability to meet contractual commitments to clients. If Kolinsky
does become aware of any such financial condition, this brochure will be updated and clients will
be notified. Kolinsky has never been subject to a bankruptcy petition.
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