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ROWLING & ASSOCIATES LLC
DBA PATHVIEW WEALTH ADVISORS
FIRM BROCHURE
(ADV PART 2A)
MARCH 28, 2026
1455 Frazee Road, Suite 700
San Diego, California 92108
Phone: (619) 295-0200
Website: www.pathview.com
Email: juan@pathview.com
This brochure provides information about the qualifications and business practices of Pathview
Wealth Advisors. If you have any questions about the contents of this brochure, please contact
Juan Aguilar at (619) 295-0200. 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.
Pathview Wealth Advisors is a registered investment adviser. Registration of an Investment
Adviser does not imply any level of skill or training. The written communications of an Adviser
provide you with information about which you determine to hire or retain an Adviser.
Additional information about Pathview Wealth Advisors is available on the SEC’s website
www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a
CRD number. The CRD number for the firm is 308292.
ITEM 2. MATERIAL CHANGES
Revised March 28, 2026
The purpose of this page is to inform you, when amending the brochure for the annual update, of
material changes since the previous annual update to the brochure. If you are receiving this
brochure for the first time, this section may not be relevant to you.
Pathview Wealth Advisors reviews and updates this brochure at least annually to confirm that it
remains current. Pathview Wealth Advisors had no material changes since the last annual
updating amendment dated March 26, 2025.
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TABLE OF CONTENTS
Item 2. Material Changes ............................................................................................................... 2
Item 4. Advisory Business ............................................................................................................. 4
Item 5. Fees and Compensation ..................................................................................................... 6
Item 6. Performance-Based Fees and Side by Side Management ................................................. 8
Item 7. Types of Clients ................................................................................................................. 8
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ......................................... 8
Item 9. Disciplinary Information ................................................................................................. 10
Item 10. Other Financial Industry Activities and Affiliations ..................................................... 10
Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 11
Item 12. Brokerage Practices ....................................................................................................... 12
Item 13. Review of Accounts ....................................................................................................... 14
Item 14. Client Referrals and Other Compensation ..................................................................... 14
Item 15. Custody .......................................................................................................................... 15
Item 16. Investment Discretion .................................................................................................... 15
Item 17. Voting Client Securities ................................................................................................. 15
Item 18. Financial Information .................................................................................................... 16
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ITEM 4. ADVISORY BUSINESS
A. OWNERSHIP/ADVISORY HISTORY
Rowling & Associates LLC dba Pathview Wealth Advisors (the “Firm” or “PWA”) is an
investment adviser filing for registration with the Securities and Exchange Commission. The
Firm is a privately owned limited liability company. The Firm is managed and owned as follows:
• Tara Cordato – 33-1/3% Owner, and Managing Member
• Juan Aguilar – 33-1/3% Owner, and Managing Member
• Lorenzo Sanchez – 33-1/3% Owner, and Managing Member
B. ADVISORY SERVICES OFFERED
The Firm offers investment supervisory services, defined as giving continuous advice to a client
or making investments for a client based on the individual needs of the client. The Firm also
provides non-supervisory services. Both types of services are described below.
i.
FINANCIAL PLANNING SERVICES
The Firm offers advice in the form of a Financial Plan. Clients purchasing this service will
receive a written financial plan, providing the client with a detailed financial plan designed to
assist in achieving their stated financial goals and objectives.
In general, the financial plan will address the following areas:
- Personal: Family records, budgeting, personal liability, estate information and financial
goals.
- Tax and Cash Flow: Income tax and spending analysis and planning for current and
future years. The Firm will illustrate the impact of various investments on a client’s
current income tax and future income tax liability.
- Death and Disability: Cash needs at death, income needs of surviving dependents, estate
planning and disability income analysis.
- Retirement: Analysis of current strategies and investment plans to help the client achieve
-
his or her retirement goals.
Investments: Analysis of investment alternatives and their effect on a client’s portfolio.
The Firm gathers the required information through in-depth personal interviews. Information
gathered includes client’s current financial status, future goals and attitudes towards risk. Related
documents supplied by the client are reviewed, including a questionnaire completed by the
client, and a written report prepared. Should a client choose to implement the recommendations
contained in the plan, the Firm suggests the client work with his/her attorney, accountant,
insurance agent, and stockbroker or financial advisor. Implementation of any financial plan
recommendation is entirely at the client’s discretion.
ii. CONSULTING
Clients can receive investment advice on a limited basis. This may include advice on only an
isolated area(s) of concern such as estate planning, retirement planning, or any other specific
topic. The Firm provides specific consultation and administrative services regarding investment
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ADV Part 2A March 28, 2026
and financial concerns of the client. Additionally, the Firm provides advice on non-securities
matters. Generally this is in connection with the rendering of estate planning, insurance and/or
annuity advice.
A conflict of interest exists between the interest of this Firm or any associated persons and the
interests of the client when the Firm, as part of a financial plan, recommends the investment
supervisory services of the Firm. The client is under no obligation to act upon this Firm’s or
associated person’s recommendations. If the client elects to act on any of the recommendations,
the client is under no obligation to effect the transaction through the Firm.
iii.
INVESTMENT SUPERVISORY SERVICES
Through personal discussions in which goals and objectives based on a client’s particular
circumstances are established, the Firm develops a client’s personal investment policy and
creates and manages a portfolio based on that policy. The Firm manages client portfolios on a
discretionary basis.
The Firm’s investment strategies and methods of analysis are discussed under Item 8 – Methods
of Analysis, Investment Strategies and Risk of Loss, below. Our investment strategies involve
certain degrees of risk and they will be recommended when consistent with the client’s stated
tolerance for risk. Each client is advised that investing in securities involves risk of loss that they
should be prepared to bear. It is the Firm’s general practice to invest cash balances in client
accounts in short-term money market mutual funds.
iv.
OTHER SERVICES
The Firm offers other services in connection with the use of TRX software by unaffiliated RIAs,
in which the Firm assists the unaffiliated RIAs with portfolio rebalancing, such as portfolio
structuring research services and model portfolios, for a fixed fee paid in advance.
C. TAILORED SERVICES
The Firm generally does not allow clients to impose restrictions on the management of their
accounts i.e., to avoid certain asset classes or industries. However, the Firm may allow
restrictions at its discretion.
WRAP PROGRAM
The Firm does not sponsor a wrap program.
D. CLIENT ASSETS MANAGED
The Firm manages client assets on a discretionary and nondiscretionary basis. As of 12/31/2025,
the total amount of assets under the Firm’s management was:
Discretionary Assets
$ 545,819,017
Non-Discretionary Assets $ 37,154,231
$ 582,973,248
Total Assets
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ITEM 5. FEES AND COMPENSATION
A. FINANCIAL PLANNING
Fees for financial planning are based on time spent at standard billing rates, which range from
$90-$500 per hour, plus expenses.
Financial reviews and other financial planning services may also be provided at fixed fees
negotiated in advance. These fixed fees generally range from $1,500 to $6,000. An initial
retainer of 50% of the estimated fee will be due upon signing the advisory agreement. The
remaining balance is due upon presentation of the plan to the client.
The Firm requires an initial retainer of 50% of the estimated fees for Financial Planning. The fee
may be negotiated under certain circumstances.
Bills are sent upon completion of the project and progress bills may be sent on a monthly basis.
Bills are due and payable upon receipt unless other arrangements are made in advance. Fees are
refundable to the extent that services have not been provided or as provided in the specific
engagement agreement. Earned fees will be determined using the hourly fee schedule as
indicated above.
B. CONSULTING
Fees for specific administrative and consulting services will be billed at standard billing rates
which generally range from $90-500 per hour, plus expenses. Bills are sent upon completion of
the consulting project and are due and payable upon receipt unless other arrangements are made
in advance.
C. INVESTMENT STRATEGIES
The annual fee for investment supervisory services will be charged as a percentage of assets
under management, according to the following schedule:
Assets Under Management
First $500,000
Next $500,000
Next $1,000,000
Next $1,000,000
Next $1,000,000
Next $1,000,000
$5,000,000 or More
Annual fee
1.25%
1.00%
.90%
.80%
.70%
.60%
Flat .60%
Quarterly
0.3125%
0.2500%
0.2250%
0.2000%
0.1750%
0.1500%
Flat 0.1500%
The Firm will quote an exact percentage to clients based on both the nature and total dollar value
of that account. However, the Firm, in its sole discretion, may reduce its assets under
management minimum and/or charge a lesser investment management fee based upon certain
criteria (e.g., anticipated future earning capacity, anticipated future additional assets, dollar
amount of assets to be managed, related accounts, account composition, negotiations with client,
etc.). The Firm does not charge management fees on cash balances in new accounts until such
time that the investment strategy is implemented.
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Client accounts are subject to a minimum quarterly fee that is reset at the beginning of each year
and is equal to the higher of (1) the minimum quarterly fee in force for the previous year, or (2)
the minimum quarterly fee resulting from the calculation set forth below. The minimum fees are
updated each quarter to account for client withdrawals and deposits during the most recent
quarter. The minimum fee calculation is as follows:
Minimum Fee =
[1st Quarter Fee x 95% x (Portfolio Value – Withdrawals + Deposits)]/Portfolio Value
Multiply the 1st Quarter Fee for the current year by 95%, then multiply such amount by the sum
of the Portfolio Value minus Withdrawals plus Deposits during the time period between 1st
Quarter fee and the current quarter. Once such sum is calculated then divide this sum by the
Portfolio Value; provided, however, that the ratio of [(Portfolio Value – Withdrawals +
Deposits)/Portfolio Value] cannot be greater than 1.00.
Portfolio Value = Value on the date used to calculate the 1st Quarter Fee (typically December
20th of the previous year).
Clients will be invoiced in advance, at the beginning of each calendar quarter, based upon the
custodian reported value of assets under management as of the 20th day of the last month of the
previous quarter, or, if later, the first business day after the 20th day of the last month of the
previous quarter. Fees may be rounded to the nearest whole dollar. The client may direct the
Firm to deduct quarterly fees from their asset account or to bill them for fees incurred.
The Firm may reduce or waive fees for employees of the firm, and their family members or other
parties, at our sole discretion.
D. Other Services
The Firm’s fees for services to unaffiliated RIAs using a TRX software subscription, such as
portfolio rebalancing, are provided at a negotiated annual fixed fee due and payable in advance.
These fixed fees generally begin at $6,000.
E. OTHER FEES AND EXPENSES
The Firm’s fees are exclusive of brokerage commissions, transaction fees, and other related costs
and expenses that are incurred by the client. Clients may incur certain charges imposed by
custodians, brokers, third party investment managers and other third parties, such as fees charged
by managers, custodial fees, 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. Mutual funds and exchange traded funds also charge internal management fees,
which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of
and in addition to the Firm’s fee, and it will not receive any portion of these commissions, fees,
and costs. For more information about the Firm’s brokerage practice please see Item 12.A.
A client could invest in a mutual fund directly, without the Firm’s services. In that case, the
client would not receive the services provided by the Firm that are designed, among other things,
to assist the client in determining which mutual fund or funds are most appropriate to each
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client’s financial conditions and objectives. Accordingly, the client is advised to review both the
fees charged by the funds and the fees charged by the Firm to fully understand the total amount
of fees to be paid by the client and to thereby evaluate the advisory services being provided.
F. TERMINATION OF ADVISORY SERVICES
A client agreement may be cancelled at any time, by either party, for any reason, upon receipt of
written notice. Upon termination of any account, any prepaid, unearned fess will be promptly
refunded and any earned, unpaid fees will be due and payable.
ITEM 6. PERFORMANCE-BASED FEES AND SIDE BY SIDE MANAGEMENT
The Firm does not accept performance-based fees or participate in side-by-side management.
Side-by-side management refers to the practice of managing accounts that are charged
performance-based fees while at the same time managing accounts that are not charged
performance-based fees.
Performance-based fees are fees that are based on a share of capital gains or capital appreciation
of a client’s account. The Firm’s fees are calculated as described in Item 5 above and are not
charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in your
advisory account.
ITEM 7. TYPES OF CLIENTS
The Firm’s services are offered to individuals, pension and profit sharing plans, trusts, estates,
charities and corporations or other business entities.
ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
A. METHODS OF ANALYSIS AND INVESTMENT STRATEGIES
The Firm’s methods of analysis primarily include Asset Allocation and Fundamental Analysis.
Asset Allocation – Asset Allocation is an investment strategy that aims to balance risk and
reward by apportioning a portfolio's assets according to an individual's goals, risk tolerance and
investment horizon among various asset classes. The asset classes typically include equities,
fixed-income, and cash and equivalents. Each class has different levels of risk and return, so each
will behave differently over time.
Fundamental Analysis - Fundamental analysis is a technique that attempts to determine a
security’s value by focusing on underlying factors that affect a company's actual business and its
future prospects. The analysis is performed on historical and present data. On a broader scope,
one can perform fundamental analysis on industries or the economy as a whole. The term refers
to the analysis of the economic well-being of a financial entity as opposed to only its price
movements.
The Firm may use other investment strategies when handling special situations for clients in
order to diversify concentrated positions or reduce tax implications. Because these investment
strategies involve certain degrees of risk, they will be recommended when consistent with the
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client’s stated tolerance for risk. Each client is advised that investing in securities involves risk of
loss that they should be prepared to bear.
The Firm uses various sources of information to help it manage client’s investment account(s).
These include:
• Computer software that performs statistical analysis
• Financial newspapers and magazines
• Research materials prepared by others
• Corporate rating services
• Annual reports, company financial statements, prospectuses and filings with the
Securities and Exchange Commission
• Company press releases
• Financial news media, including televised and Web-based
• Contact with investment company representatives
B. INVESTMENT RISKS/RISK OF LOSS
The Firm uses mutual funds to implement investment strategies in its clients’ accounts. The Firm
may also occasionally offer advice regarding additional types of investments if they are
appropriate to address the individual needs, goals, and objectives of the client or in response to
client inquiry. The Firm may offer investment advice on any investment held by the client at the
start of the advisory relationship.
All investments bear different types and degrees of risk, and investing in securities involves
risk of loss that clients should be prepared to bear. While the Firm uses investment strategies
that are designed to provide appropriate investment diversification, some investments have
significantly greater risks than others. Obtaining higher rates of return on investments entails
accepting higher levels of risk. Recommended investment strategies seek to balance risks and
rewards to achieve investment objectives. A client needs to ask questions about risks he/she does
not understand; the Firm and its associates would be pleased to discuss them.
The Firm strives to render its best judgment on behalf of its clients. Still, it cannot assure or
guarantee clients that investments will be profitable or assure that no losses will occur in an
investment portfolio. Past performance is an important consideration with respect to any
investment or investment adviser but is not a reliable predictor of future performance. The Firm
continuously strives to provide outstanding long-term investment performance, but many
economic and market variables beyond its control can affect the performance of an investment
portfolio.
An investment could lose money over short or even long periods. A client should expect his/her
account value and returns to fluctuate within a wide range, like the fluctuations of the overall
stock and bond markets. A client’s account performance could be hurt by:
• Stock market risk: The chance that stock prices overall will decline. Stock markets tend
to move in cycles, with periods of rising stock prices and periods of falling stock prices.
• Interest rate risk: The chance that bond prices overall will decline because of rising
interest rates.
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• Manager risk: The chance that the proportions allocated to the various securities will
cause the client’s account to underperform relative to benchmarks or other accounts with
a similar investment objective.
• International investing risk: Investing in the securities of non-U.S. companies involves
special risks not typically associated with investing in U.S. companies. Foreign securities
tend to be more volatile and less liquid than investments in U.S. securities, and may lose
value because of adverse political, social or economic developments overseas or due to
changes in the exchange rates between foreign currencies and the U.S. dollar. In addition,
foreign investments are subject to settlement practices, as well as regulatory and financial
reporting standards, that differ from those of the U.S.
• Margin Risk: The Firm does not recommend using margin to increase investment
leverage; however, clients may maintain margin accounts for personal borrowing
purposes. Margin accounts can be very risky and they are not suitable for everyone.
Before opening a margin account, you should fully understand that:
o A client can lose more money than he/she has invested;
o A client may have to deposit additional cash or securities in his/her account on
short notice to cover market losses;
o A client may be forced to sell some or all of his/her securities when falling stock
prices reduce the value of your securities; and
o A client’s brokerage firm may sell some or all of your securities without
consulting him/her to pay off the loan it made to him/her. For example, if a
client’s account falls below the maintenance requirement, the brokerage firm
generally will make a margin call to ask the client to deposit more cash or
securities into his/her account. If the client is unable to meet the margin call, the
brokerage firm will sell the client’s securities to increase the equity in the client’s
account up to or above the brokerage firm's maintenance requirement.
ITEM 9. DISCIPLINARY INFORMATION
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events within the past 10 years that would be material to your evaluation of the
Adviser or the integrity of its management.
The Firm and its management have no information applicable to this Item because they have not
been the subject of any administrative, civil, criminal, regulatory (SEC or State) or self-
regulatory proceedings.
ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
A. BROKER-DEALER AFFILIATIONS
The Firm is not affiliated with a broker-dealer.
B. FUTURES/COMMODITIES FIRM AFFILIATION
The Firm is not affiliated with a futures or commodities broker.
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C. OTHER INDUSTRY AFFILIATIONS
An owner of the Firm, Tara Cordato, is a licensed CPA who supervises the provision of tax
preparation services to the Firm’s investment advisory clients. The Firm may recommend tax
preparation services to the Firm’s investment advisory clients or its investment advisory services
to tax preparation clients. With the ability of the Firm to provide tax preparation and investment
advisory services, this could be viewed as a conflict of interest because clients pay a separate fee
for each service. However, the Firm attempts to mitigate any conflicts of interest to the best of its
ability by placing the client’s interests ahead of its own and through the implementation of
policies and procedures that address the conflict.
ITEM 11. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND
PERSONAL TRADING
A. DESCRIPTION
The Firm’s Code of Ethics establishes ideals for ethical conduct based upon fundamental
principles of openness, integrity, honesty, and trust. The Code of Ethics is available free of
charge upon request by any client or prospective client.
The Firm’s Code of Ethics covers all supervised persons, and it describes the Firm’s high
standard of business conduct and fiduciary duty to clients. The Code of Ethics includes
provisions relating to the confidentiality of client information, a prohibition on insider trading, a
prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the
reporting of certain gifts and business entertainment items, and personal securities trading
procedures, among other things. All supervised persons must acknowledge the terms of the Code
of Ethics annually, or as amended.
B. MATERIAL INTEREST IN SECURITIES
The Firm does not have a material interest in any securities. Additionally, it is the Firm’s policy
to not effect any principal or agency cross securities transactions for client accounts. Principal
transactions are generally defined as transactions where an adviser, acting as principal for its
own account or the account of an affiliated broker-dealer, buys from or sells any security to any
advisory client. A principal transaction may also be deemed to have occurred if a security is
crossed between an affiliated hedge fund and another client account. An agency cross transaction
is defined as a transaction where a person acts as an investment adviser for a client in a
transaction in which the investment adviser, or any person controlled by or under common
control with the investment adviser, also acts as broker for another person on the other side of the
transaction. Agency cross transactions may arise where an adviser is dually registered as a
broker-dealer or has an affiliated broker-dealer.
C. INVESTING IN OR RECOMMENDING THE SAME SECURITIES
The Firm or individuals associated with us may buy or sell – for their personal account(s) -
investment products identical or opposite to those recommended to clients. It is the Firm’s
general policy that no person employed by it may purchase or sell any security prior to a
transaction(s) being implemented for an advisory account. On occasion, circumstances may arise
where different goals, trading programs or time horizons could have the Firm or individuals
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associated with the Firm assuming a trading position before or after the client(s), transaction that
may or may not be the same or is counter to those of advisory accounts. All positions are
reviewed in an effort to prevent such employees from benefiting from transactions placed on
behalf of advisory accounts. The Firm will always act in the client’s best interest.
ITEM 12. BROKERAGE PRACTICES
A. RECOMMENDATION CRITERIA
Clients’ accounts are maintained at a “qualified custodian,” generally a broker-dealer or bank.
The custodian will hold the client’s assets and will usually act as the broker to effect transactions
as well. The Firm participates in the Schwab Advisor Services (formerly called Schwab
Institutional) program offered to independent investment advisers by Charles Schwab &
Company, Inc., a FINRA registered Broker/Dealer. The Firm generally recommends that clients
use discount brokers and custodians. The services of Charles Schwab & Company, Inc. are
recommended for ease of administration and efficiency. In choosing to recommend this
custodian, the Firm considered a variety of factors including its financial strength, reputation,
execution, discount commission rates, trading and technology support, research and the quality
of customer service. All clients are free to select any custodian/broker of his or her choice. The
Firm is not affiliated with Charles Schwab & Company, Inc. nor does it receive commissions or
fees for recommending this provider.
Additionally, the services of Shareholder Services Group (“SSG”), a local area brokerage firm,
are generally recommended to clients, as applicable, using the same variety of factors as noted
above. The Firm is not affiliated with the brokerage firm. SSG does not supervise the Firm, its
agents or activities.
Recommended custodians/brokers may charge brokerage commissions and/or transaction fees
for effecting securities transactions. In addition to the Firm’s investment management fee,
brokerage commissions and/or transaction fees, the client will also incur, relative to all mutual
fund purchases, charges imposed at the mutual fund level (e.g., management fees and other fund
expenses).
The recommended custodians/brokers charge commission rates that are generally considered
discounted from customary retail commission rates. The commissions and/or transaction fees
charged by the recommended custodians/brokers may be higher or lower than those charged by
other custodians/brokers. The Firm does not receive any portion of the commissions and/or
transaction fees charged to its clients.
Although the commissions/transaction fees paid by the Firm’s clients shall comply with the
Firm’s duty to obtain best execution, a client may pay a commission or transaction fee that is
higher than another qualified custodian/broker might charge to effect the same transaction where
the Firm determines, in good faith, that the commission is reasonable in relation to the value of
the brokerage services received.
In seeking best execution, the determinative factor is not the lowest possible cost, but whether
the transaction represents the best qualitative execution, taking into consideration the full range
of a custodian/broker services, including execution capability, commissions rates and
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responsiveness. Accordingly, although the Firm will seek competitive rates, it may not
necessarily obtain the lowest possible commissions/transaction fees rates for client account
transactions.
i. RESEARCH AND OTHER BENEFITS
The Firm participates in Charles Schwab & Company’s Schwab Advisor Services program
(“Program”). The Firm may recommend that clients establish brokerage accounts with the
Program to maintain custody of clients' assets and to effect trades for their accounts. The Firm is
independently owned and operated and not affiliated with the Program. The Program provides
the Firm with access to its institutional trading and custody services, which are typically not
available to the Program’s retail investors. These services generally are available to independent
investment advisors on an unsolicited basis, at no charge to them so long as a total of at least $10
million of the advisor's clients' assets are maintained in accounts at the Program, and are not
otherwise contingent upon the Firm’s committing to the Program any specific amount of
business. The Program's services include brokerage, custody, research, and access to mutual
funds and other investments that are otherwise generally available only to institutional investors
or would require a significantly higher minimum initial investment.
For the Firm’s client accounts maintained in its custody, the Program generally does not charge
separately for custody but is compensated by account holders through commissions or other
transaction-related fees for securities trades that are executed through the Program or that settle
into the Program’s accounts.
The Program also makes available to the Firm other products and services that benefit the Firm
but may not benefit its clients' accounts. Some of these other products and services assist the
Firm in managing and administering clients' accounts. These include software and other
technology that provide access to client account data (such as trade confirmations and account
statements), facilitate trade execution (and allocation of aggregated trade orders for multiple
client accounts), provide research, pricing information and other market data, facilitate payment
of the Firm’s fees from its clients' accounts, and assist with back-office functions, recordkeeping
and client reporting. Many of these services generally may be used to service all or a substantial
number of the Firm’s accounts, including accounts not maintained at the Program. The Program
also makes available to the Firm other services intended to help it manage and further develop its
business enterprise. These services may include consulting, publications and conferences on
practice management, information technology, business succession, regulatory compliance, and
marketing. In addition, the Program may make available, arrange and/or pay for these types of
services rendered to the Firm by independent third parties. The Program may discount or waive
fees it would otherwise charge for some of these services or pay all or part of the fees of a third-
party providing these services to the Firm. While as a fiduciary the Firm endeavors to act in its
clients' best interests, the Firm’s recommendation that clients maintain their assets in accounts at
the Program may be based in part on the benefit to the Firm and the availability of some of the
foregoing products and services and not solely on the nature, cost or quality of custody and
brokerage services provided by the Program, which may create a potential conflict of interest.
The Firm’s clients do not pay more for investment transactions effected and/or assets maintained
at the Program as a result of this arrangement. There is no corresponding commitment made by
the Firm to the Program or any other entity to invest any specific amount or percentage of client
assets in any specific mutual funds, securities or other investment products as a result of these
arrangements.
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ii. BROKERAGE FOR CLIENT REFERRALS
The Firm does not receive client referrals or any other incentive from any broker/dealer.
iii. DIRECTED BROKERAGE
Some clients may direct the Firm to a specific broker-dealer to execute securities transactions for
their accounts. When so directed, the Firm may not be able to effectively negotiate lower
brokerage commissions, aggregate orders with trades placed through other broker-dealers, or
achieve best execution on clients’ transactions. This can result in substantially higher fees,
charges or dealer concessions in one or more transactions for the clients’ account because the
Firm cannot negotiate favorable prices.
B. TRADING POLICIES
On occasions when selling the same security for multiple accounts, the Firm may aggregate
orders to a single block order against an average price account. The average price account will
allocate proportionate shares to each client’s account.
ITEM 13. REVIEW OF ACCOUNTS
A. PERIODIC REVIEWS
The Firm reviews the general holdings of clients’ portfolios on an ongoing basis. All clients (in
person or via telephone) are encouraged to comprehensively review financial planning,
investment objectives, and account performance with us on an annual basis.
B. OTHER REVIEWS
All investment supervisory clients are advised that it remains their responsibility to advise us of
any changes in their investment objectives and/or financial situation.
C. REPORTS
The Firm provides quarterly written reports to each investment management client. The reports
contain the client’s portfolio balances and returns for the quarter. In addition, all clients will
receive at least quarterly statements from their custodian. The Firm urges clients to carefully
review such statements.
ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION
A. OTHER COMPENSATION
We receive an economic benefit from Charles Schwab & Company in the form of the support
products and services they make available to us and other independent investment advisors
through the Schwab Advisor Services program. These products and services, how they benefit
us, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices).
We do not base particular investment advice, such as buying particular securities for our clients,
on the availability of Schwab’s products and services to us. The Firm does not receive any other
compensation for providing investment advice to clients.
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B. CLIENT REFERRALS
The Firm does not use the services of solicitors or pay for client referrals.
ITEM 15. CUSTODY
All client funds, securities and accounts are held at third-party custodians. The Firm is not
affiliated with the third-party custodians, such as Charles Schwab & Company and SSG.
Custodians do not supervise the Firm, its agents or activities. The Firm does not take possession
of a client’s securities. However, the Firm has limited custody when the client authorizes the
Firm with the ability to deduct fees directly from the client’s account. The Firm follows the
guidelines established by the Securities and Exchange Commission for directly debiting advisory
fees from client custodial accounts.
The Firm is also deemed to have custody of a client’s funds or securities when the client has a
written standing letter of authorization with their custodian to move money from the client’s
account to designated third parties (“SLOA”), and under that SLOA authorizes PWA to
designate the amount or timing of transfers to those third parties with the custodian. The SEC
staff has published a set of standards intended to protect client assets in such situations, which
PWA follows.
Clients should receive at least quarterly statements from the broker dealer, bank or other
qualified custodian that holds and maintains client’s investment assets. The statements will show
the fee withdrawn. The Firm urges each client to carefully review such statements and compare
them to the reports provided by the Firm. Clients with any questions about their statements
should contact the Firm at the address or phone number on the cover of this brochure. Clients
who do not receive a statement from their qualified custodian at least quarterly should also notify
the Firm.
ITEM 16. INVESTMENT DISCRETION
The Firm manages client accounts on a discretionary basis, which is granted when the client
signs its discretionary investment management agreement. The Agreement grants the Firm’s
discretionary trading authority as to the type, price, time and amount of securities to be bought
and sold. The Firm will be allowed to place trades without first obtaining the client’s consent to
each trade. Directions will be given to the account custodian to complete the transaction.
ITEM 17. VOTING CLIENT SECURITIES
A. PROXY VOTING
The Firm will not be responsible for responding to proxies for securities held in clients’
accounts. Proxy solicitation materials will be forwarded to clients for response and voting. In the
event a client has a question about a proxy solicitation, the client should contact his or her
investment adviser representative.
B. CLASS ACTIONS
In cases where the Firm is responsible for filing class actions on behalf of clients, we have
selected an unaffiliated third party vendor to provide class action litigation monitoring and
securities claim filing services on behalf of our clients. This vendor will monitor class actions for
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which our clients may be eligible. Upon learning of any such class actions the vendor will collect
the applicable documentation, interpret the terms of each settlement, file the appropriate claim
form, interact with the administrators and distribute the award to applicable clients. The vendor
charges clients a contingency fee which is subtracted from the award at the time of payment.
Clients may opt-out entirely or may list specific companies against which claims should not be
filed on their behalf. Clients may change their opt-out election at any time by notifying the Firm
in writing. Because the Firm provides this service to our Clients through a third party vendor, we
will not monitor class action suits or process any claim forms on clients’ behalf, whether or not
they opt-out of this service. If a client chooses to opt-out, the vendor also will not monitor any
class action suits from which the client may be entitled to awards, and the vendor will not
process any claim forms on the client’s behalf. Clients who opt-out are entitled to pursue
securities claims on their own.
ITEM 18. FINANCIAL INFORMATION
A. BALANCE SHEET
The Firm does not require or solicit prepayment of more than $1,200 in fees per client, six
months or more in advance. Therefore, it does not have to provide a balance sheet.
B. FINANCIAL CONDITION
Registered investment advisers are required in this Item to provide clients with certain financial
information or disclosures about the Firm’s financial condition. The Firm does not have a
financial commitment that impairs its ability to service its clients.
C. BANKRUPTCY
The Firm has not been the subject of a bankruptcy proceeding.
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