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D I S C L O S U R E B R O C H U R E
Office Address:
10432 Balls Ford Road
Suite 120
Manassas, VA 20109
Tel: 877-650-4738
Alt Tel: 703-457-9940
Fax: 866-255-8789
Email:
jsharifi@lwealthmanagement.com
Website:
www.lwealthmanagement.com
FEBRUARY 14, 2026
This brochure provides information about the qualifications and business practices of Legacy
Wealth Management Inc. Being registered as a registered investment adviser does not imply
a certain level of skill or training. If you have any questions about the contents of this
brochure, please contact us at 703-727-5387. 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 Legacy Wealth Management Inc. (CRD #173453) is available
on the SEC’s website at www.adviserinfo.sec.gov
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Legacy Wealth Management Inc.
Item 2: Material Changes
Annual Update
Material Changes since the Last Update
The Material Changes section of this brochure will be updated annually or when material
changes occur since the previous release of the Firm Brochure.
This update is in accordance with the required annual update for Investment Advisors.
Since the last filing of this brochure on September 15, 2025, the following has been
•
updated:
•
Item 4 has been updated to disclose the firm’s most recent assets under
management calculation.
Full Brochure Available
Financial Planning fees have been updated.
When you would like to receive a complete copy of our Firm Brochure, please contact us
by telephone at: 877 – 650 - 4738 or by email at: jsharifi@lwealthmanagement.com
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Item 3: Table of Contents
Form ADV – Part 2A – Firm Brochure
Item 1: Cover Page
Item 2: Material Changes .................................................................................................................... ii
Annual Update ................................................................................................................................................................... ii
Material Changes since the Last Update.................................................................................................................. ii
Item 3: Table of Contents ................................................................................................................... iii
Full Brochure Available .................................................................................................................................................. ii
Item 4: Advisory Business .................................................................................................................. 1
Firm Description ............................................................................................................................................................... 1
Types of Advisory Services ........................................................................................................................................... 1
Client Tailored Services and Client Imposed Restrictions ............................................................................... 3
Wrap Fee Programs ......................................................................................................................................................... 3
Item 5: Fees and Compensation ....................................................................................................... 3
Client Assets under Management .............................................................................................................................. 3
Method of Compensation and Fee Schedule .......................................................................................................... 3
Client Payment of Fees ................................................................................................................................................... 5
Additional Client Fees Charged ................................................................................................................................... 5
Prepayment of Client Fees ............................................................................................................................................ 5
Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 6
External Compensation for the Sale of Securities to Clients ........................................................................... 5
Item 7: Types of Clients ....................................................................................................................... 6
Sharing of Capital Gains ................................................................................................................................................. 6
Description .......................................................................................................................................................................... 6
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 6
Account Minimums .......................................................................................................................................................... 6
Methods of Analysis ......................................................................................................................................................... 6
Investment Strategy ........................................................................................................................................................ 6
Item 9: Disciplinary Information ..................................................................................................... 8
Security Specific Material Risks .................................................................................................................................. 7
Criminal or Civil Actions ................................................................................................................................................ 8
Administrative Enforcement Proceedings ............................................................................................................. 8
Item 10: Other Financial Industry Activities and Affiliations ............................................... 8
Self-Regulatory Organization Enforcement Proceedings ................................................................................ 8
Broker-Dealer or Representative Registration .................................................................................................... 8
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Legacy Wealth Management Inc.
Futures or Commodity Registration ......................................................................................................................... 8
Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................... 8
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ................ 8
Trading ..................................................................................................................................................... 9
Code of Ethics Description ............................................................................................................................................ 9
Investment Recommendations Involving a Material Financial Interest and Conflict of Interest.... 9
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest ... 9
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Item 12: Brokerage Practices ......................................................................................................... 10
Transactions and Conflicts of Interest .................................................................................................................. 10
Factors Used to Select Broker-Dealers for Client Transactions ................................................................. 10
Item 13: Review of Accounts ........................................................................................................... 11
Aggregating Securities Transactions for Client Accounts ............................................................................. 11
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons
Involved ............................................................................................................................................................................. 11
Review of Client Accounts on Non-Periodic Basis ........................................................................................... 11
Item 14: Client Referrals and Other Compensation ................................................................ 11
Content of Client Provided Reports and Frequency ........................................................................................ 11
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of
Interest ............................................................................................................................................................................... 11
Item 15: Custody .................................................................................................................................. 11
Advisory Firm Payments for Client Referrals .................................................................................................... 11
Item 16: Investment Discretion ..................................................................................................... 11
Account Statements ...................................................................................................................................................... 11
Item 17: Voting Client Securities ................................................................................................... 12
Discretionary Authority for Trading...................................................................................................................... 11
Item 18: Financial Information ...................................................................................................... 12
Proxy Votes ...................................................................................................................................................................... 12
Balance Sheet .................................................................................................................................................................. 12
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments
to Clients ............................................................................................................................................................................ 12
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 14
Bankruptcy Petitions during the Past Ten Years .............................................................................................. 12
Principal Executive Officer - Jay Sharifi ................................................................................................................ 14
Item 2 Educational Background and Business Experience .......................................................................... 14
Item 3 Disciplinary Information .............................................................................................................................. 14
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Item 4 Other Business Activities ............................................................................................................................. 14
Item 5 Additional Compensation ............................................................................................................................ 14
Item 6 Supervision ........................................................................................................................................................ 14
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Item 4: Advisory Business
Firm Description
Types of Advisory Services
Legacy Wealth Management Inc. (“Advisor”) was founded in May 2014 by Jamshid “Jay”
Sharifi and began offering investment advisory services in November 2014.
Investment strategies,
ASSET MANAGEMENT
Advisor offers both discretionary and non-discretionary direct asset management services
to advisory clients. Advisor will offer clients ongoing portfolio management services
through determining individual investment goals, time horizons, objectives, and risk
tolerance.
investment selection, asset allocation, portfolio
monitoring and the overall investment program will be based on the above factors.
Discretionary
When the client provides Advisor discretionary authority Advisor has the authority to
execute selected investment program transactions as stated within the Investment
Advisory Agreement.
Non-discretionary
When the client elects to use Advisor on a non-discretionary basis, Advisor will
determine the securities to be bought or sold and the amount of the securities to be
bought or sold. However, Advisor will obtain prior client approval on each and every
transaction before executing any transactions.
When deemed appropriate for the client, Advisor will utilize programs through SEI
SIMC is available for non-North Carolina residents ONLY.
Investments Management Corporation (“SIMC”), an SEC registered investment advisor.
Advisor is solely responsible
for selecting suitable clients to participate in the program(s) offered through SIMC. Advisor
will also select which program(s) are best suited for those applicable clients. The
Unified Managed Account Program
program(s) will be detailed in the client agreement(s).
The UMA Program is available for
We also offer discretionary investment management services in a managed account program
non-North Carolina residents only.
through an Overlay Manager (the “UMA Program”).
This UMA Program may consist of using model
portfolio advisers, model portfolios or other investment options such as mutual funds
and/or exchange-traded funds (“ETFs”) to represent different investment strategies for
managing your account. Each of these investment strategies is designed to meet a specific
goal.
Prior to investing in the UMA Program, you will execute a discretionary investment
management agreement with us setting forth the terms and conditions of our management
of your investments within the UMA Program. Depending on the management services the
client selects, the client will grant us limited discretionary authority to manage the client
account through selection of an overlay manager (“Overlay Manager”), third party strategist
(“Strategist”) and/or third party managers (“Managers”; collectively, “Third-Party Service
Providers”). In addition, the client will authorize the custodian to follow our instructions as
well as instructions given by Overlay Manager to effect transactions, deliver securities,
deduct fees and take other actions with respect to the client account. The client will not have
a direct contractual relationship with the Overlay Manager or any other Third-Party Service
Provider.
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The timing of trades in the client account will primarily depend upon the model or changes
in the model and, generally, will not take into consideration how long a client may have held
the position indicated by the model.
We will retain the right to replace any Strategist or Manager on a discretionary basis.
Depending on the service a client has selected, we will separately provide the client with the
firm brochure (Part 2 of Form ADV) for the applicable Third-Party Service Provider(s)
which includes information about their services, model portfolios, and investment strategies
at or before the execution of our discretionary investment management agreement.
FINANCIAL PLANNING AND CONSULTING
Our firm also provides financial planning and consulting services. Depending on your
particular circumstance, such services could include a comprehensive evaluation of your
financial situation by using currently known facts and variables, or it might focus on a few
items of particular importance to you. Generally, such financial planning services will
involve preparing a financial plan or rendering a financial consultation for clients based on
the client's current situation, financial goals and objectives. For financial consulting clients,
we will usually not provide a written summary of our observations and recommendations,
as the process is a less formal engagement. Regardless of the nature of the service, the
implementation of all recommendations will be at the client's discretion.
Income Plan for Retirement
A financial plan or financial consultation will address one or more of the following areas:
1)
Investment Strategy
- Assessing retirement needs to help a client determine
how much to accumulate, as well as distribution strategies designed to create a
source of income during retirement years.
2)
- Evaluating clients current investment strategy and suggesting
Tax Planning
alternatives if they do not match the clients goals.
Insurance & Debt Management
3)
- Evaluating the current tax situation to help minimize a client's taxes.
4)
- Evaluating the client's insurance needs, reviewing
insurance policies and the like. While also analyzing client's current mortgage debt,
Review of Employee Benefit Plans
home equity, and financing alternatives.
5)
Estate Planning-
-Reviewing the client's investment options,
allocation models and historical performance of client assets held through employee
benefit plans.
g
6)
Reviewing the client's cash needs at death, income needs of
goals.
surviving dependents and estate plannin
future goals,
investment objectives, risk
tolerance and
We gather information at a Discovery meeting which includes interviews and a review of
documents provided by the client. Information gathered includes the client's current
family
financial status,
circumstances. Typical financial planning or financial consultation services include one or
more of each of the service components. A financial plan could require the services of a
specialist such as an insurance specialist, attorney or tax accountant. We will recommend
third-party service providers if we feel it is appropriate and in your best interest, but the
client is under no obligation to use any service provider recommended by us. Likewise, the
client is under no obligation to act on our financial planning recommendations. We do not
receive referral or other fees from third-party service providers.
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Financial plans and/or consulting are based on your financial situation at the time Advisor
presents the plan to you, and on the financial information you provided to Advisor. You
must promptly notify Advisor if your financial situation, goals, objectives, or needs change.
You are under no obligation to act on our financial planning recommendations. Should you
choose to act on any of our recommendations, you are not obligated to implement the
financial plan through any of our other investment advisory services. Moreover, you may
act on our recommendations by placing securities transactions with any brokerage firm.
Financial plans will be completed and delivered inside of ninety (90) days. Clients may
terminate their account within five (5) business days of signing the Investment Advisory
Agreement with no obligation and without penalty. After the initial five (5) business days,
the agreement may be terminated by Advisor with thirty (30) days written notice to Client
and by the Client at any time with written notice to Advisor. Services are considered
complete when the plan and/or recommendations are rendered.
Client Tailored Services and Client Imposed Restrictions
SEMINARS
Advisor holds seminars to educate the public on different types of investments and the
different services they offer. The seminars are educational in nature and no specific
investment or tax advice is given. Advisor does not charge a fee for attendance to these
seminars.
The goals and objectives for each client are documented in our client files. Investment
strategies are created that reflect the stated goals and objective. Clients may impose
restrictions on investing in certain securities or types of securities.
Wrap Fee Programs
Agreements may not be assigned without client consent.
Client Assets under Management
Advisor does not offer or participate in a wrap fee program.
Advisor has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts:
$251,046,073
$0
Date Calculated:
December 31 2025
Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
ASSET MANAGEMENT
Advisor offers discretionary and non-discretionary direct asset management services to
advisory clients. Advisor charges an annual investment advisory fee based on the total
assets under management as follows:
Assets Under Management
$0 - $499,999
$500,000 - $999,999
$1,000,000 - $2,999,999
$3,000,000 - $4,999,999
$5,000,000 - $9,999,999
Annual Fee
1.25%
1.00%
0.90%
0.80%
0.70%
Quarterly Fee
.3125%
.2500%
.2250%
.2000%
.1750%
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$10,000,000 and Above
0.60%
.1500%
The annual fee may be negotiable. Accounts within the same household may be combined for
a reduced fee. Fees are billed quarterly in arrears based on an average daily balance of the
account for the previous quarter. The calculation for the average daily balance is based on
the formula (A/D) x (F/P).
A = the sum of the daily balances in the billing period
D = number of days in the billing period
F = annual management fee
For example (based on quarterly billing period)
P = number of billing periods per year
: the first step taken using the average-
daily-balance calculation method would be to take the average of the values of the Client’s
account over the course of the entire quarter. For instance, 85 days at $1 million plus 6
days at $500,000 averages out to approximately $967,032. Based on the formula (A/D) x
(F/P), the example would be: (88,000,000/91) x (.01/4) = $2,418. Initial fees for partial
quarters are pro-rated. Quarterly advisory fees deducted from the clients' account by the
custodian will be reflected in a provided fee invoice as fees are withdrawn.
Lower fees for comparable services may be available from other sources. The combination
of fees for LWM and third-party managers will not exceed the industry standard of
excessive fees, which is 3%. Clients may terminate their account within five (5) business
days of signing the Investment Advisory Agreement for a full refund. Clients may terminate
advisory services with thirty (30) days written notice. For accounts closed mid-quarter, the
client will be entitled to a pro rata refund for the days service was not provided in the final
quarter. Client shall be given thirty (30) days prior written notice of any increase in fees,
and client will acknowledge, in writing, any agreement of increase in said fees.
SIMC is available for non-North Carolina residents
When utilizing the programs offered through SIMC, the fees charged by Advisor are in
ONLY.
addition to the fees charged by SIMC.
For clients utilizing SIMC’s programs, SIMC’s fund advisory fee varies, but it typically
ranges from .10% - 1.25% of the portfolio’s average daily net assets for its advisory
services. Lower fees for comparable services may be available from other sources. Clients
may terminate their account within five (5) business days of signing the Investment
Advisory Agreement with no obligation and without penalty. After the initial five (5)
business days, the agreement may be terminated by Advisor with thirty (30) days written
notice to Client and by the Client at any time with written notice to Advisor.
Unified Managed Account Program
The UMA Program is available for non-North Carolina
When using the UMA program, any fees charged by the Overlay Manager will be in addition
residents only.
to the charges we charge.
For clients utilizing the UMA Program, UMA’s fund advisory fee varies, but
it typically ranges from 0.21% - 0.63%. The fees will be outlined in each Overlay Manager’s
Form ADV Part 2A.
FINANCIAL PLANNING AND CONSULTING
For clients who retain our firm for its investment advisory services, there is generally no
charge for financial planning services. Other clients who retain the firm solely for financial
planning or financial consultation will be charged fees based on the nature of the services
being provided, who is providing the services and the complexity of the client's
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Client Payment of Fees
circumstances. Financial planning fees are due upon execution of the agreement and are
calculated and charged on a flat fee basis from $2,500 to $7,500 per engagement for clients
whose assets we manage or based on 0.5% of the client’s liquid net worth if we do not
manage their assets. If a client terminates financial planning services after we have begun
the work but before completion, the client will receive a full refund via a check mailed to
the address of record. We provide you with an exact fee quote before you authorize us to
begin our work. The specific financial planning fee being charged to the client will be set
forth and identified in the financial planning agreement between us and each client.
Financial planning fees are billed separately with invoices being mailed to the address of
record. Your financial professional will update your financial plan upon request or when
your objectives or financial situation change. If a financial plan is updated, the fee will be
dependent on the nature of the update. Again, this fee will be set forth and identified in an
agreement between yourself and the firm.
Investment management fees are billed quarterly in arrears, meaning we bill you after the
three-month period has finished. Payment in full is expected upon invoice presentation.
Fees are usually deducted from a designated client account to facilitate billing. The client
must consent in advance to direct debiting of their investment account.
Additional Client Fees Charged
Fees for financial plans are due upon executing the agreement.. Advisor reserves the right
to waive the planning fee.
Custodians may charge transaction fees on purchases or sales of certain mutual funds,
equities and exchange-traded funds.
These charges may include mutual fund transactions
fees, postage and handling and miscellaneous fees (fee levied to recover costs associated
with fees assessed by self-regulatory organizations). The selection of the security is more
important than the nominal fee that the custodian charges to buy or sell the security.
Prepayment of Client Fees
Advisor, in its sole discretion, may waive its minimum fee and/or charge a lesser
investment advisory fee based upon certain criteria (e.g., historical relationship, type of
assets, anticipated future earning capacity, anticipated future additional assets, dollar
amounts of assets to be managed, related accounts, account composition, negotiations with
clients, etc.). For more details on the brokerage practices, see Item 12 of this brochure.
External Compensation for the Sale of Securities to Clients
Fees for financial planning and consulting services are due 50% in advance with the
remaining portion due upon the completion of the services rendered.
Advisor does not receive any external compensation for the sale of securities to clients, nor
do any of the investment advisor representatives of Advisor.
However, President Jamshid Sharifi has a financial affiliated business as an insurance agent.
Approximately 25% of Mr. Sharifi’s time is spent in this practice. From time to time, he will
offer clients advice or products from those activities.
These practices represent conflicts of interest because it gives Mr. Sharifi an incentive to
recommend products based on the commission amount received. This conflict is mitigated
by disclosures, procedures, and the firm’s Fiduciary obligation to place the interests of the
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Item 6: Performance-Based Fees and Side-by-Side Management
client first and clients are not required to purchase any products. Clients have the option to
purchase these products through another insurance agent of their choosing.
Sharing of Capital Gains
Fees are not based on a share of the capital gains or capital appreciation of managed
securities.
Item 7: Types of Clients
Advisor does not use a performance-based fee structure because of the conflict of interest.
Performance-based compensation may create an incentive for the adviser to recommend
an investment that may carry a higher degree of risk to the client.
Description
Account Minimums
Advisor generally provides investment advice to individuals, high net worth individuals
and businesses. Client relationships vary in scope and length of service.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Advisor does not require a minimum to open an account.
Methods of Analysis
Security analysis methods may include fundamental analysis, technical analysis, and
cyclical analysis. Investing in securities involves risk of loss that clients should be prepared
to bear. Past performance is not a guarantee of future returns.
Fundamental analysis involves evaluating a stock using real data such as company
revenues, earnings, return on equity, and profits margins to determine underlying value
and potential growth. Technical or Charting analysis involves evaluating securities based
on past prices and volume. Cyclical analysis involves analyzing the cycles of the market.
Investment Strategy
When creating a financial plan, Advisor utilizes fundamental analysis to provide review of
insurance policies for economic value and income replacement. Technical or Charting
analysis is used to review mutual funds and individual stocks. Cyclical analysis is sensitive
to economy cycles. For example, revenues are generally higher in periods of economic
prosperity and expansion and lower in periods of economic downturn and contraction.
The main sources of information include financial newspapers and magazines, research
materials prepared by others, corporate rating services, annual reports, prospectuses, and
filings with the Securities and Exchange Commission.
The investment strategy for a specific client is based upon the objectives stated by the
client during consultations. The client may change these objectives at any time. Each client
executes an Investment Policy Statement or Risk Tolerance that documents their objectives
and their desired investment strategy.
Other strategies may include long-term purchases, short-term purchases, trading, and
option writing (including covered options, uncovered options or spreading strategies).
Long-term purchases, short-term purchases and option transactions may not be suitable
for all persons and clients should be aware of the risks involved.
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Risks involved with long-term purchases are interest rate risk, business risk and financial
risk. Clients also run the risk of losing the money initially invested.
Risks involved with short-term purchases are downside risk, risk of financial loss, marginal
risk, and risk of lower returns on investments.
Security Specific Material Risks
Risks involved with option transactions are credit risk, market risk, funding risk, and
operational risk. Clients will receive a separate disclosure from the custodian on the risks
associated with standardized options.
All investment programs have certain risks that are borne by the investor. Fundamental
analysis may involve interest rate risk, market risk, business risk, and financial risk. Risks
involved in technical analysis are inflation risk, reinvestment risk, and market risk. Cyclical
analysis involves inflation risk, market risk, and currency risk.
Interest-rate Risk
•
Our investment approach constantly keeps the risk of loss in mind. Investors face the
following investment risks and should discuss these risks with Advisor:
• Market Risk
: Fluctuations in interest rates may cause investment prices to
fluctuate. For example, when interest rates rise, yields on existing bonds become less
attractive, causing their market values to decline.
•
: The price of a security, bond, or mutual fund may drop in reaction to
tangible and intangible events and conditions. This type of risk is caused by external
factors independent of a security’s particular underlying circumstances. For example,
Inflation Risk
political, economic and social conditions may trigger market events.
: When any type of inflation is present, a dollar today will buy more than
• Currency Risk
a dollar next year, because purchasing power is eroding at the rate of inflation.
• Reinvestment Risk
: Overseas investments are subject to fluctuations in the value of the
dollar against the currency of the investment’s originating country. This is also
referred to as exchange rate risk.
• Business Risk
: This is the risk that future proceeds from investments may have to
be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily
relates to fixed income securities.
• Liquidity Risk
: These risks are associated with a particular industry or a particular
company within an industry. For example, oil-drilling companies depend on finding
oil and then refining it, a lengthy process, before they can generate a profit. They
carry a higher risk of profitability than an electric company which generates its
income from a steady stream of customers who buy electricity no matter what the
economic environment is like.
• Financial Risk
: Liquidity is the ability to readily convert an investment into cash.
Generally, assets are more liquid if many traders are interested in a standardized
product. For example, Treasury Bills are highly liquid, while real estate properties are
not.
: Excessive borrowing to finance a business’ operations increases the
risk of profitability, because the company must meet the terms of its obligations in
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• Funding Risk
good times and bad. During periods of financial stress, the inability to meet loan
obligations may result in bankruptcy and/or a declining market value.
• Operational Risk
: The risk that, as a result of mismatches or delays in the timing of cash
flows due from or to the client or counterparty in the transactions, the client or
counterparty may not have adequate cash available to fund current obligations.
• Credit Risk
: The risk of loss to the client arising from inadequacies in or failures
of system and controls for, monitoring and quantifying the risks and contractual
obligations associated the transactions, for recording and valuing the transactions, or
for detecting human errors or systems failures.
: The risk of loss of principal stemming from a borrower’s failure to repay a
Item 9: Disciplinary Information
loan or otherwise meet a contractual obligation.
Criminal or Civil Actions
Administrative Enforcement Proceedings
The firm and its management have not been involved in any criminal or civil action.
Self-Regulatory Organization Enforcement Proceedings
The firm and its management have not been involved in administrative enforcement
proceedings.
Item 10: Other Financial Industry Activities and Affiliations
The firm and its management have not been involved in legal or disciplinary events related
to past or present investment clients.
Broker-Dealer or Representative Registration
Futures or Commodity Registration
Neither Advisor nor any of its employees are registered representatives of a broker-dealer.
Material Relationships Maintained by this Advisory Business and Conflicts of Interest
Neither Advisor nor its employees are registered or has an application pending to register
as a futures commission merchant, commodity pool operator, or a commodity trading
advisor.
President Jamshid Sharifi has a financial affiliated business as an insurance agent.
Approximately 25% of Mr. Sharifi’s time is spent in this practice. From time to time, he will
offer clients advice or products from those activities.
These practices represent conflicts of interest because it gives Mr. Sharifi an incentive to
recommend products based on the commission amount received. This conflict is mitigated
by disclosures, procedures, and the firm’s Fiduciary obligation to place the interests of the
client first and clients are not required to purchase any products. Clients have the option to
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest
purchase these products through another insurance agent of their choosing.
Advisor may at times utilize programs offered through SIMC to assist in the management of
client accounts and/or the UMA Program through our custodian. Prior to introducing any
clients to another investment advisor, LWM will be responsible in determining if the Firm
is properly licensed, notice filed or exempt from registration. In such circumstances,
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Legacy Wealth Management Inc.
Advisor fees are in addition to any custodial or management fees charged by the other
investment advisors. This situation does not create a conflict of interest because Advisor
charges the same fees for clients utilizing the SIMC and UMA programs and those who do
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
not. Fees for these services will be based on a percentage of assets under management.
Code of Ethics Description
The employees of Advisor have committed to a Code of Ethics (“Code”). The purpose of our
Code is to set forth standards of conduct expected of Advisor employees and addresses
conflicts that may arise. The Code defines acceptable behavior for employees of Advisor.
The Code reflects Advisor and its supervised persons’ responsibility to act in the best
interest of their client.
One area the Code addresses is when employees buy or sell securities for their personal
accounts and how to mitigate any conflict of interest with our clients. We do not allow any
employees to use non-public material information for their personal profit or to use
internal research for their personal benefit in conflict with the benefit to our clients.
Advisor’s policy prohibits any person from acting upon or otherwise misusing non-public
or inside information. No advisory representative or other employee, officer or director of
Advisor may recommend any transaction in a security or its derivative to advisory clients
or engage in personal securities transactions for a security or its derivatives if the advisory
representative possesses material, non-public information regarding the security.
Advisor’s Code is based on the guiding principle that the interests of the client are our top
priority. Advisor’s officers, directors, advisors, and other employees have a fiduciary duty
to our clients and must diligently perform that duty to maintain the complete trust and
confidence of our clients. When a conflict arises, it is our obligation to put the client’s
interests over the interests of either employees or the company.
to clients, or who have access
The Code applies to “access” persons. “Access” persons are employees who have access to
non-public information regarding any clients' purchase or sale of securities, or non-public
information regarding the portfolio holdings of any reportable fund, who are involved in
making securities recommendations
to such
recommendations that are non-public.
The firm will provide a copy of the Code of Ethics to any client or prospective client upon
Investment Recommendations Involving a Material Financial Interest and Conflict of
request.
Interest
Advisor and its employees do not recommend to clients securities in which we have a
material financial interest.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest
Advisor and its employees may buy or sell securities that are also held by clients.
Employees may not trade their own securities ahead of client trades.
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Client Securities Recommendations or Trades and Concurrent Advisory Firm
Securities Transactions and Conflicts of Interest
Advisor does not maintain a firm proprietary trading account and does not have a material
financial interest in any securities being recommended and therefore no conflicts of
interest exist. However, employees may buy or sell securities at the same time they buy or
sell securities for clients. In order to mitigate conflicts of interest such as front running,
employees are required to disclose all reportable securities transactions as well as provide
Advisor with copies of their brokerage statements.
The Chief Compliance Officer of the firm is Jay Sharifi. He reviews all employee trades each
quarter. The personal trading reviews ensure that the personal trading of employees does
not affect the markets and that clients of the firm receive preferential treatment over
Item 12: Brokerage Practices
employee transactions.
Factors Used to Select Broker-Dealers for Client Transactions
• Directed Brokerage
Advisor will select appropriate brokers based on a number of factors including but not
limited to their relatively low transaction fees and reporting ability. Advisor currently has
relationships with SEI Private Trust Company and Charles Schwab as its custodial broker-
dealers. Advisor relies on its broker to provide its execution services at the best prices
available. Lower fees for comparable services may be available from other sources. Clients
pay for any and all custodial fees in addition to the advisory fee charged by Advisor..
• Best Execution
Advisor does not allow clients to direct brokerage. Not all advisors require their
clients to direct brokerage. By directing brokerage, Advisor may be unable to achieve
the most favorable execution of client transactions, and that this practice may cost the
client more money.
Investment advisors who manage or supervise client portfolios on a discretionary
basis have a fiduciary obligation of best execution. Advisor reviews the execution of
trades at each custodian each quarter. Advisor may have an incentive to select or
recommend a broker-dealer based on our interest in receiving the research or other
products and services, rather than on the clients’ interests in receiving the most
• Soft Dollar Arrangements
favorable execution
The Securities and Exchange Commission defines soft dollar practices as arrangement
under which products or services other than execution services are obtained by
Advisor from or through a broker-dealer in exchange for directing client transactions
to the broker-dealer. As permitted by Section 28(e) of the Securities Exchange Act of
1934, Advisor receives economic benefits as a result of commissions generated from
securities transactions by the broker-dealer from the accounts of Advisor. These
benefits include both proprietary research from the broker and other research
written by third parties.
A conflict of interest exists when Advisor receives soft dollars because Advisor does
not have to produce or pay for these benefits. This conflict is mitigated disclosures,
procedures, and the firm’s Fiduciary obligation to act in the best interest of its clients
and the services received are beneficial to all clients.
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Legacy Wealth Management Inc.
Aggregating Securities Transactions for Client Accounts
Item 13: Review of Accounts
Advisor is authorized in its discretion to aggregate purchases and sales and other
transactions made for the account with purchases and sales and transactions in the same
securities for other Clients of Advisor. All clients participating in the aggregated order shall
receive an average share price with all other transaction costs shared on a pro-rated basis.
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved
Account reviews are performed quarterly by Jay Sharifi, Chief Compliance Officer. Mr.
Sharifi will review accounts for such things as:
•
•
•
client objectives are in line with the investments;
securities held in the accounts are performing to Advisor and client’s expectations;
and
asset allocation is balanced in the correct proportion with the strategy.
Review of Client Accounts on Non-Periodic Basis
Account reviews are performed more frequently when market conditions dictate.
Content of Client Provided Reports and Frequency
Other conditions that may trigger a review of clients’ accounts are changes in the tax laws,
new investment information, and changes in a client's own situation.
Item 14: Client Referrals and Other Compensation
Clients receive written account statements from the custodian no less than quarterly for
managed accounts. Client receives confirmations of each transaction in account from
Custodian and an additional statement during any month in which a transaction occurs.
Advisor does not provide clients additional reports.
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts
of Interest
Advisory Firm Payments for Client Referrals
Advisor does not receive any economic benefits from external sources.
Item 15: Custody
Advisor does not compensate for client referrals.
Account Statements
All assets are held at qualified custodians, which means the custodians provide account
statements directly to clients at their address of record at least quarterly. Clients are urged
to carefully review account statements.
Item 16: Investment Discretion
Advisor is deemed to have constructive custody solely because advisory fees are directly
deducted from client’s account by the custodian on behalf of Advisor.
Discretionary Authority for Trading
Advisor requires discretionary authority to manage securities accounts on behalf of Clients.
Advisor has the authority to determine, without obtaining specific Client consent, the
securities to be bought or sold, and the amount of the securities to be bought or sold.
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Legacy Wealth Management Inc.
Advisor allows Client’s to place certain restrictions, as outlined in the Client’s Investment
Policy Statement or similar document. Such restrictions could include only allowing
purchases of socially conscious investments. These restrictions must be provided to
Advisor in writing.
Item 17: Voting Client Securities
The Client approves the custodian to be used and the commission rates paid to the
custodian. Advisor does not receive any portion of the transaction fees or commissions
paid by the Client to the custodian.
Proxy Votes
Advisor does not vote proxies on securities. Clients are expected to vote their own proxies.
The client will receive their proxies directly from the custodian of their account or from a
transfer agent.
Item 18: Financial Information
When assistance on voting proxies is requested, Advisor will provide recommendations to
the client. If a conflict of interest exists, it will be disclosed to the client.
Balance Sheet
A balance sheet is not required to be provided because Advisor does not serve as a
custodian for client funds or securities and Advisor does not require prepayment of fees of
more than $1200 per client and six months or more in advance.
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
Commitments to Clients
Bankruptcy Petitions during the Past Ten Years
Advisor has no condition that is reasonably likely to impair our ability to meet contractual
commitments to our clients.
Neither Advisor nor its management has had any bankruptcy petitions in the last ten years.
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Legacy Wealth Management Inc.
S U P E R V I S E D P E R S O N B R O C H U R E
F O R M A D V P A R T 2 B
Jamshid “Jay” Sharifi
Office Address:
10432 Balls Ford Road
Suite 120
Manassas, VA 20109
Tel: 877-650-4738
Alt Tel: 703-457-9940
Fax: 866-255-8789
Email:
jsharifi@lwealthmanagement.com
FEBRUARY 14, 2026
This brochure supplement provides information about Jay Sharifi and supplements the Legacy
Wealth Management Inc.’s brochure. You should have received a copy of that brochure. Please
contact Jay Sharifi if you did not receive the brochure or if you have any questions about the
contents of this supplement.
Additional information about Jay Sharifi (CRD #6411375) is available on the SEC’s website at
www.adviserinfo.sec.gov.
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Legacy Wealth Management Inc.
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Principal Executive Officer - Jay Sharifi
•
Item 2 Educational Background and Business Experience
Year of birth: 1981
Educational Background:
•
•
•
Georgetown University; Certificate of Financial Planning; 2016
Keller Devry Graduate School; Master of Business Administration; 2012
Dickinson College; Bachelor of Science in Biochemistry and Molecular Biology; 2003
•
Business Experience:
•
•
•
•
Item 3 Disciplinary Information
Legacy Wealth Management Inc.; Investment Advisor Representative; 10/2014 -
Present
Legacy Wealth Management Inc.; President; 05/2014 – Present
Legacy Associates Inc.; President/Insurance Agent; 11/2004 – Present
LANS; Owner; 03/2014 - Present
Bankers Life & Casualty; Insurance Agent; 04/2004 – 11/2004
Item 4 Other Business Activities
None to report.
Jamshid Sharifi has a financial industry affiliated business as an insurance agent. From time
to time, he offers clients advice or products from this activity. Approximately 25% of Mr.
Sharifi’s time is spent in this practice. Clients are not required to purchase any products.
These practices represent conflicts of interest because it gives Mr. Sharifi an incentive to
recommend products based on the commission amount received. This conflict is mitigated
by disclosures, procedures, and the firm’s Fiduciary obligation to place the interests of the
client first and clients are not required to purchase any products. Clients have the option to
purchase these products through another insurance agent of their choosing.
Item 5 Additional Compensation
Jamshid Sharifi is also a silent owner of LANS, a non-investment related family owned retail
gas/convenience store. Mr. Sharifi spends approximately five hours per month in this
activity to assist with growth and development of the business. This business does not pose
any conflict of interest.
Item 6 Supervision
Mr. Sharifi receives additional compensation in his capacity as an insurance agent. He does
not receive any performance-based fees.
Since Mr. Sharifi is the sole owner of Legacy Wealth Management Inc.; he is solely
responsible for all supervision and formulation and monitoring of investment advice
offered to clients. He will adhere to the policies and procedures as described in the firm’s
Compliance Manual.
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Legacy Wealth Management Inc.