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Private Family Wealth Advisors
Form ADV Part 2A
Brochure
PFW Advisors, LLC
3350 Riverwood Parkway SE
Suite 650
Atlanta, Georgia 30339
Phone: (404) 848-0950
Email: scott@pfwadvisors.com
Website: www.pfwadvisors.com
Date: August 8, 2025
This Brochure (Part 2A of Form ADV) provides you with information about the qualifications,
business practices and advisory services of PFW Advisors LLC (the “Firm”). The Firm does business
as Private Family Wealth Advisors and is sometimes referred to herein by that name.
The Firm is an investment adviser registered with the Securities and Exchange Commission.
Registration does not imply a certain level of skill or training, only that we have filed registration
documents in the appropriate jurisdictions and with the respective governmental entities. 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 Private Family Wealth Advisors can be found on the Investment
Adviser Public Disclosure website at adviserinfo.sec.gov by using our identification number
referred to as a CRD number. Private Family Wealth Advisors’ CRD No. is 325119. If you have any
questions about the contact of this brochure, please contact us at the telephone number or email
address shown above.
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ITEM 2: Material Changes
The material changes in this brochure from the annual updating amendment of PFW Advisors LLC
(“Private Family Wealth Advisors”) dated 3/15/2025 are described below. This list summarizes
any material changes to our business, including our policies, practices or conflicts of interests
since our last annual update dated February 20, 2025.
Item 5: Fees and Compensation was updated.
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We may, at any time, update this Brochure and send a copy to you with a summary of material
changes, or send you only a summary of material changes that includes an offer to send you a
copy of the full brochure either by electronic means (email) or in hard copy form at no charge to
you.
If you would like another copy of this Brochure, please download it from the SEC website as
indicated above or contact our Chief Compliance Officer, Scott R. MacKenzie at 404-848-0950 or
via email at Scott@pfwadvisors.com.
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ITEM 3: Table of Contents
Form ADV Part 2A
ITEM 2: Material Changes
ITEM 3: Table of Contents
ITEM 4: Advisory Services
A. Types of Advisory Services:
B. Regulatory Assets Under Management
ITEM 5: Fees and Compensation
A. Fees and Compensation for Investment Management Services
B. Fees for Financial Planning and Consulting Services
C. Retirement Plan Consulting Services
D. Termination and Refunds
ITEM 6: Performance Based Fees and Side-By-Side Management
ITEM 7: Types of Clients
ITEM 8: Methods of Analysis, Investment Strategies, and Risk of Loss
A. Investment Strategies and Method of Analysis
B. Risks of Investing
A. Proprietary Trading
B. Participation or Interest in Client Transactions
ITEM 12: Brokerage Practices
A. The Custodians and Brokers We Use
B. How We Select Brokers/Custodians
C. Your Brokerage and Custody Costs
D. Products and Services Available to Us from Schwab
E. Brokerage for Client Referrals
F. Directed Brokerage
G. Order Aggregation
ITEM 13: Review of Accounts
ITEM 14: Client Referrals and Other Compensation
ITEM 15: Custody
ITEM 16: Investment Discretion
ITEM 17: Voting Client Securities
ITEM 18: Financial Information
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ITEM 9: Disciplinary Information
ITEM 10: Other Financial Industry Activities and Affiliations
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ITEM 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 14
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ITEM 4: Advisory Services
PFW Advisors LLC (referred to herein as “Private Family Wealth Advisors,” “Firm,” “we,” and
“our”) is an independent investment adviser that is registered with the U.S. Securities and
Exchange Commission (“SEC”). The Firm was formed in 2013 as a limited liability company in
Georgia and is currently wholly owned by Scott R. MacKenzie. Mr. MacKenzie is the Managing
Member and Chief Compliance Officer of Private Family Wealth Advisors. For more information
about Mr. MacKenzie, please see his brochure supplement (Form ADV Part 2B).
A. Types of Advisory Services:
The Firm offers the following types of advisory services.
1. Investment Management Services
Investment management services are typically provided on a discretionary basis. Clients will be
asked to grant discretionary authority to the Firm by signing our Investment Advisory Agreement.
Members of our investment team will meet with the client to develop an understanding of the
client’s financial objectives and goals. We will also discuss concepts related to risk, as well as the
client’s ability and willingness to accept risk in the client’s overall investment portfolio. We will
ask the client questions designed to determine the appropriate investment horizon, risk profile,
financial goals, income and other various items we deem necessary (“Suitability Information”).
We ask clients to update us promptly if any Suitability Information changes.
Clients are given the ability to impose reasonable restrictions on the management of their
accounts, including specific investment selections and sectors. However, Private Family Wealth
Advisors will not enter into an investment advisor relationship with a client whose investment
objectives may be considered incompatible with the Firm’s investment philosophy or strategies
or where the prospective client seeks to impose unreasonable investment guidelines.
After we meet with a client, we will develop a portfolio customized to the specific needs of the
client as we understand them based on the Suitability Information and any applicable
restrictions. Each client will be asked to open a trading account at a “qualified custodian,” which
is usually a securities broker-dealer, bank or trust company (“the Custodian”). The transactions
we implement in the client’s account will occur within the client’s account at the Custodian. The
portfolio we implement on the client’s behalf may be comprised of stocks, bonds, preferred
securities, publicly traded partnerships, ETFs, mutual funds, separately managed accounts, listed
options on ETFs and stocks, cash or cash equivalents and other types of investments.
If the client elects to have their account managed on a non-discretionary basis, the client grants
the Firm ongoing and continuous non-discretionary authority to make
investment
recommendations in accordance with the client’s investment profile. However, the Firm must
obtain the client’s prior approval of each specific recommendation, as well as for the selection
and retention of sub-advisers for the account (see below), prior to entering into transactions in
the client’s account.
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If the client elects to have their account managed on a discretionary basis, the client grants the
Firm ongoing and continuous discretionary authority to enter into transactions in accordance
with the client’s investment profile without the client’s prior approval of each specific
transaction. The client will also execute instructions regarding the Firm’s trading authority as
required by the Custodian.
We will also monitor the client’s accounts to ensure that they are meeting the client’s investment
objectives and other requirements. If any changes are needed to the client’s investments, we will
either make the changes or recommend the changes to the client. These changes may include,
among other things, buying additional securities, selling a security or group of investments and
buying others, or keeping the proceeds of securities sales in cash or another liquid cash
alternative. The client will receive written or electronic confirmations of all transactions from the
Custodian. The client will also receive statements at least quarterly from the Custodian. Our
Investment Advisory Agreement outlines the responsibilities of both the client and Private Family
Wealth Advisors.
In managing the client’s portfolio, the Firm may utilize the services of various third-party
investment advisory firms, money managers, platform providers, third-party managers, portfolio
specialists, investment model providers, or sub-advisers (collectively, “Sub-Advisers”) for the
management of client accounts. Before selecting a Sub-Adviser, the Firm will ensure that it is
properly licensed or registered if so required by law and will conduct additional due diligence on
the Sub-Adviser’s management style, performance and other relevant factors. If you grant us
discretionary authority, we have the ability to hire and/or fire any such Sub-Adviser without prior
consultation with you, or to allocate or reallocate your investments among or between various
Sub-Advisers. If we use a sub-adviser in the management of a client’s account, we will review
sub-adviser performance on an ongoing basis.
When we recommend the use of a Sub-Adviser, Clients may be requested to execute a separate
client services agreement with the Sub-Adviser that authorizes participation on the platform.
We may also use Sub-Advisers to aid in the implementation of an investment portfolio, allocating
client assets among such managers as appropriate. In some such cases, the Sub-Advisers will be
responsible for continuously monitoring client accounts and making trades in client accounts
when necessary.
2. Financial Planning and Consulting Services
Our Firm may provide stand-alone financial planning and consulting services based upon an
analysis of each client’s current situation, goals, and objectives. Financial planning services will
typically involve preparing and delivering a financial plan after consultation with the client and a
review of relevant client records. Recommendations made in any financial plan are based on the
client’s financial goals and objectives. This planning or consulting may encompass advice
regarding real estate purchases, investment planning, retirement planning, estate planning,
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charitable planning, education planning, corporate and personal tax planning, corporate
structure, mortgage/debt analysis, insurance analysis or business and personal financial planning.
Prior to engaging our Firm to provide planning or consulting services, clients are generally
required to enter into a Financial Planning and Consulting Agreement with Private Family Wealth
Advisors setting forth the terms and conditions of the engagement and describing the scope of
the services to be provided and the fees charged.
Implementation of any recommendations contained in the financial plan will be at the discretion
of the client. Clients are free to implement recommendations through another financial advisor
or firm and are under no obligation to implement the recommendations through us.
3. Retirement Plan Consulting Services
We offer retirement plan consulting services to employer-sponsored retirement plans subject to
the Employee Retirement Income Security Act of 1974 (“ERISA”). Our retirement plan consulting
services include, but are not limited to, the following services:
Fiduciary Consulting Services
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Investment Policy Statement Preparation. Our Firm assists clients in the development or
review of an investment policy statement (“IPS”). The IPS establishes the investment
policies and objectives for the plan. Clients have the ultimate responsibility and authority
to establish such policies and objectives and to adopt and amend the investment policy
statement.
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investment reports that document
• Non-Discretionary Investment Advice. Our Firm provides clients with general, non-
discretionary investment advice regarding asset classes and investment alternatives
available for the plan that are consistent with the plan’s IPS. Our Firm assists clients with
the selection of a broad range of investment options consistent with the investment
option selection provisions of ERISA Section 404(c) and the regulations thereunder.
Clients have the final decision-making authority regarding the selection, retention,
removal and addition of any investment options.
Investment Monitoring and Reports. Our Firm assists clients in monitoring investment
investment
options by preparing periodic
performance, consistency of fund management and conformance to the guidelines set
forth in the IPS and make recommendations to maintain or remove and replace
investment options. The Firm will meet with clients on a periodic basis to discuss the
reports and the investment recommendations.
• Qualified Default Investment Alternative Advice. Our Firm provides clients with non-
discretionary investment advice to assist in developing qualified default investment
alternative(s) (“QDIA”), consistent with ERISA Section 404(c) and the regulations
thereunder, for participants who are automatically enrolled in the plan or who otherwise
fail to make an investment election. Clients retain the ultimate responsibility to comply
with the requirements of Section 404(c), to monitor Section 404(c) compliance, and to
follow the terms of the plan document.
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The specific services to be provided will be listed in Our Firm's agreement with each retirement
plan. Our Firm acknowledges that in performing the retirement plan consulting services listed
above it is acting as a “fiduciary” as such term is defined under ERISA Section 3(21)(A)(ii) for
purposes of providing investment advice only. Our Firm acts in a manner consistent with the
requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services
cause Our Firm to be a fiduciary as a matter of law.
4. Retirement Plan Rollovers
Sometimes we will recommend that a client “roll over” assets that are held in an existing tax-
qualified retirement account, such as a 401(K), to be managed by us in an Individual Retirement
Account (“IRA”) or other similar account.
A client or prospective client leaving an employer typically has four options regarding an existing
retirement plan, and may engage in a combination of these options: (i) leave the money in the
former employer’s plan, if permitted; (ii) roll over the assets to the new employer’s plan, if one
is available and rollovers are permitted; (iii) roll over to an Individual Retirement Account (“IRA”);
or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse
tax consequences).
When we provide investment advice to clients regarding their retirement plan account or
individual retirement account, we are “fiduciaries” within the meaning of Title I of the Employee
Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws
governing retirement accounts. If we recommend that a client roll over their retirement assets
into an account to be managed by us, such a recommendation creates a conflict of interest if
we will earn an advisory fee on the rolled-over assets. We address this conflict of interest by
ensuring any such recommendations are in the client’s best interest. No client is under any
obligation to roll over retirement assets to an account to be managed by us.
B. Regulatory Assets Under Management
As of June 4, 2025, Private Family Wealth Advisors had $385,949,930 in client assets under
management, of which $385,119,188 is managed on a discretionary basis, and $830,742 is
managed on a non-discretionary basis.
ITEM 5: Fees and Compensation
This section provides information regarding the Firm’s fees and compensation for the services
described in Item 4. Lower fees for comparable service may be available from other sources. The
exact fees and other terms applicable to each client will be described in the Investment Advisory
Agreement between the client and the Firm.
A. Fees and Compensation for Investment Management Services
Private Family Wealth Advisors charges fees for investment management services based on a
percentage of assets under management. Our standard investment management fees are:
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On assets between $0 and $1 million
On assets between $1 million and $5 million
On assets between $5 million and $25 million
On assets over $25 million
On assets over $100 million
1.25%
0.80%
0.60%
0.50%
Negotiable
Please note these fees have “tiers,” meaning that if your assets exceed the maximum of the first
tier, your overall fee will be a blended percentage rate that is the result of being charged the
corresponding fee for the first level of assets, plus the different corresponding fee for the next
level of assets, and so on. Investment management fees are calculated and paid monthly in
arrears based on the average daily balance in the account. Our investment management fees are
negotiable, depending upon the complexity of the client’s financial situation and the scope of
services rendered.
Investment management fees will be deducted from the client’s account(s) at our request by the
qualified custodian, a process that clients authorize by signing the Investment Advisory
Agreement. We may, at a client’s request, make other arrangements for payment of the
investment management fee.
Any transaction fees imposed by the Custodian for trades executed in the client’s account are
included within the Advisory Fee paid to the Firm. These transaction fees will be disclosed by the
Custodian. Generally, this only applies to a client’s portfolio if sub-adviser is not used.
Client agrees to be responsible for all additional fees, expenses and charges for which client
becomes obligated under any separate agreement with the Custodian. Said fees, expenses or
charges will be paid out of the assets in the Account(s) or billed separately to the client. Mutual
funds and similar investment vehicles pay managers to manage the assets of the fund, and the
expenses of the fund, including said management fees, are deducted from all of the fund assets,
are chargeable against the net asset value of fund shares owned by the client, and are therefore
borne separately by the client. Other fees and expenses that the client may be responsible for
paying include retirement plan fees, mutual fund sales loads, contingent deferred sales charges,
annuity fees including mortality and expense charges, and surrender charges.
The Custodian will deliver an account statement, at least quarterly, directly to the client, showing
all disbursements from the account. The client is encouraged to review all account statements
for accuracy. Private Family Wealth Advisors will receive access to a duplicate copy of the
statement that was delivered to the client.
For the initial period of portfolio management services, the first period’s fees will be calculated
on a pro-rata basis at the end of the initial month.
Our receipt of an asset-based fee presents a conflict of interest. This is because the more assets
there are in the client’s account, the more the client will pay in fees. Therefore, we have an
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incentive to encourage clients to increase the assets in their accounts. We address this conflict
of interest by ensuring any such recommendations are in the client’s best interest.
If the client is to be charged a Sub-Adviser’s fee will be added to PFW’s advisory to our fee, that
fee will be described in the Sub-Adviser’s Brochure (Form ADV, Part 2A), in separate agreement
between the client and the Sub-Adviser, or in a special disclosure document delivered to the
client.
If Adviser elects to use a Third-Party Manager to manage Clients’ accounts, the Client will be
charged a “supplemental advisory fee.” Attached hereto as Schedule D is the list of third-party
managers we typically employ to provide services to your Account and the annual fees they will
charge. Please note that this list of third-party managers and their fees may change over time.
Adviser will periodically send you updates to this list. In some cases, the Third-Party Manager will
deduct the supplemental advisory fee directly from the Client’s account. In other cases, the Third-
Party Manager will charge the supplemental advisory fee to the Adviser, and the Adviser will then
deduct the fee from the Client’s account to reimburse the Adviser.
Fees and compensation for using a Third-Party Manager or a platform that provides Us access to
such managers are described in more detail in the platform provider’s disclosure brochure or, if
applicable, in a separate disclosure Private Family Wealth Advisors delivers to you describing
customized pricing. Clients are responsible for any transaction charges imposed by the custodian
for trades executed in their accounts by a sub-adviser.
B. Fees for Financial Planning and Consulting Services
For clients who have entered into a Financial Planning and Consulting Agreement with Our Firm,
we will charge clients on a flat fee basis for any financial planning and/or consulting services to
be provided. Flat fees are a minimum of $12,000. The total estimated fee, as well as the ultimate
fee charged, is negotiable and will be based on the scope and complexity of our engagement with
the client. Private Family Wealth Advisors reserves the right to waive the financial planning fee
or include financial planning services for asset management clients in its sole discretion.
C. Retirement Plan Consulting Services
Our Firm charges an annual investment advisory fee for retirement plan consulting services. Fees
do not usually exceed 1.25% of the total plan assets placed under our advisement. The exact
annual fee and method of payment will be specified in the Retirement Plan Consulting
Agreement. Fees are negotiable.
D. Termination and Refunds
Either party may terminate the Investment Advisory Agreement for our investment management
service in writing at any time. Because fees are typically paid in arrears, there is normally not a
circumstance in which the client will be due a refund for services that have not been rendered.
Should a situation occur where a refund is warranted (potentially due to error or miscalculations
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of fees) refunds will be processed in the most timely and prudent manner available given the
circumstances under which a refund is warranted.
Financial Planning clients may terminate their agreement at any time before the delivery of a
financial plan by providing written notice. For purposes of calculating refunds, all work performed
by us up to the point of termination shall be calculated at the flat rate currently in effect. Clients
will receive a pro-rata refund of unearned fees based on the time and effort expended by Our
Firm.
ITEM 6: Performance Based Fees and Side-By-Side Management
Performance-based fees are fees based on a share of capital gains on or capital appreciation of
the client’s assets. Side-by-side management occurs when advisers manage both accounts that
are charged a performance-based fee and accounts that are charged another type of fee, such as
an hourly or flat fee or an asset-based fee. We do not charge performance-based fees, nor do we
engage in side-by-side management.
ITEM 7: Types of Clients
Private Family Wealth Advisors generally provides investment advisory services to the following
types of clients:
Individuals
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• High net worth individuals
• Trusts
• Estates
• Charitable organizations
• 401(K) and/or 403(B) Plans
• 529 Plans
• Corporations or other businesses
For individual accounts, our minimum relationship opening balance is $2 million, which may be
negotiated or waived based upon certain circumstances.
ITEM 8: Methods of Analysis, Investment Strategies, and Risk of Loss
A. Investment Strategies and Method of Analysis
We recommend and implement various investment strategies, such as long-term growth, growth
and income, income-generating strategies, asset allocation strategies and hedging strategies.
We use different methods of analysis in formulating and executing our investment strategies,
including:
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• Macroeconomic Analysis: looking at long-term trends and relationships across wide
sectors of the economy and financial markets.
• Fundamental Analysis: researching the financial variables of the investment to
identify whether or not it is a good value at the current price.
• Cyclical Analysis: looking at historical relationships between various groupings of
assets and how they are affected by the economic business cycle.
• Technical Analysis: applying established “techniques” to the price history of an asset
in order to identify potential future price movement based on historical patterns.
Some of the factors we use to evaluate equity investment opportunities include:
• Business Opportunity: analyzing the main story driving the investment’s ability to
grow and, ultimately, its return to shareholders.
• Risk Factors: considering any potential news, events, or trends which may undermine
the opportunity.
• Current Financial Valuation: calculating how the company is valued by the market
compared to its reported business performance relative to its peers.
• Special Situations: short term events or trends that may indicate an opportunity to
acquire an investment at a favorable price.
• Competition: whether the company has competitors and/or how difficult its business
is to replicate by new entrants to the industry.
• Leadership: judging the temperament and ability of the management team.
We base our analysis predominantly on publicly available research such as regulatory filings,
press releases, competitor analyses, and in some cases research we receive from the custodian
or other sources.
B. Risks of Investing
There are always risks to investing. Investing in securities involves risk of loss that all clients
should be prepared to bear. Clients are encouraged to discuss specific investment decisions and
the risks of particular investments with the Firm.
It is impossible to describe all possible types of risks which may affect investments. Among the
risks are the following:
• Concentration Risk. To the extent a portfolio is concentrated in assets related to a
particular industry or geographic region, the portfolio will be subject to additional
volatility risks associated with such industry or region. In addition, concentrating in a
single industry or group of industries may be more susceptible to any single economic,
market, political or regulatory occurrence affecting that industry or group of
industries.
• Market Risk. Markets can, as a whole, go up or down on various news releases or for
no understandable reason at all. This sometimes means that the price of specific
securities could go up or down without real reason and may take some time to recover
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any lost value. Adding additional securities does not help to minimize this risk since
all securities may be affected by market fluctuations.
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• Currency 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.
Interest Rate Risk. Movements in interest rates may directly cause prices of fixed
income securities to fluctuate. For example, rising interest rates can cause “high
quality, relatively safe” fixed income investments to lose principal value.
• Credit Risk. If debt obligations held by an account are downgraded by ratings agencies
or go into default, or if management action, legislation or other government action
reduces the ability of issuers to pay principal and interest when due, the value of those
obligations may decline, and an account’s value may be reduced. Because the ability
of an issuer of a lower-rated or unrated obligation (including particularly “junk” or
“high yield” bonds) to pay principal and interest when due is typically less certain than
for an issuer of a higher-rated obligation, lower rated and unrated obligations are
generally more vulnerable than higher-rated obligations to default, to ratings
downgrades and to liquidity risk.
• Purchasing Power Risk. Purchasing power risk is the risk that an investment’s value
will decline as the price of goods rises (inflation). The investment’s value itself does
not decline, but its relative value does. Inflation can happen for a variety of complex
reasons, including a growing economy and a rising money supply.
• Liquidity Risk. Liquidity is the ability to readily convert an investment into cash. For
example, Treasury Bills are highly liquid, while real estate properties are not. Some
securities are highly liquid while others are highly illiquid. Illiquid investments carry
more risk because it can be difficult to sell them.
• Political Risk. Most investments have a global component, even domestic stocks.
Political events anywhere in the world may have unforeseen consequences to markets
around the world.
• Regulatory Risk. Changes in laws and regulations from any government can change
the value of a given company and its accompanying securities. Certain industries are
more susceptible to government regulation. Changes in zoning, tax structure or laws
impact the return on these investments.
• Risks Related to Investment Term. If the client requires a liquidation of their portfolio
during a period in which the price of the security is low, the client will not realize as
much value as they would have had the investment had the opportunity to regain its
value, as investments frequently do, or had it been able to be reinvested in another
security.
• Business Risk. Many investments contain interests in operating businesses. Business
risks are risks 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
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stream of customers who buy electricity no matter what the economic environment
is like.
• Financial Risk. Many investments contain interests in operating businesses. Excessive
borrowing to finance a business’ operations decreases the risk of profitability,
because the company must meet the terms of its obligations in 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.
• Default Risk. This risk pertains to the ability of a company to service their debt. Ratings
provided by several rating services help to identify those companies with more risk.
Obligations of the U.S. government are said to be free of default risk.
In addition, there is no assurance that a mutual fund, an ETF or any security will achieve its
investment objective. The principal risks of investing in any mutual fund or ETF are market risk,
diversification risk and style risk (growth investing risk and mid-cap company risk). To the extent
that a mutual fund or ETF invests in foreign securities or debt securities, a fund would be subject
to foreign exposure risk, interest rate risk and credit risk. A fund may invest in derivative
instruments that carry derivative instruments risk. A principal risk is the risk that the value of
equity securities may decline. Although a mutual fund or ETF may be a diversified fund, it may
invest in securities of a limited number of issuers to achieve a potentially greater investment
return than a fund that invests in a larger number of issuers. As a result, price movements of a
single issuer’s securities will have a greater impact on this fund’s net asset value causing it to
fluctuate more than that of a more widely diversified fund. These and other risk considerations
are discussed in a fund’s prospectus. Past performance of investments is no guarantee of future
results.
Mutual fund investing involves risk including the possible loss of principal. Non-diversified funds
are more susceptible to financial, market and economic events affecting the particular issuers
and industry sectors in which they invest and therefore may be more volatile or risky than less
concentrated investments. There can be no assurance that any fund will be able to achieve its
investment objective. For more information on a particular fund’s associated risks, please refer
to that fund’s prospectus or equivalent disclosure document.
Due to the volatile nature and risks involved when investing in certain types of strategies and/or
securities, clients should be aware that the actual return and value of their account(s) may
fluctuate and at any point in time be worth more or less than the amount originally invested. We
do not represent, guarantee or imply that the services or methods of analysis employed by us
can or will predict future results, successfully identify market tops or bottoms, or insulate clients
from losses due to market corrections or declines.
ITEM 9: Disciplinary Information
Private Family Wealth Advisors is required to disclose the facts of any legal or disciplinary events
that are material to a client’s evaluation of our advisory business or the integrity of our
management. We do not have any required disclosures to report in response to this Item.
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ITEM 10: Other Financial Industry Activities and Affiliations
Private Family Wealth Advisors does not have a related person that is:
• A broker/dealer, municipal securities dealer or government securities dealer or broker
• An investment company or other pooled investment vehicle (including a mutual fund,
closed-end investment company, unit investment trust, private investment company
or “hedge fund” and offshore fund)
• An investment adviser or financial planner
• A futures commission merchant, commodity pool operator or commodity trading
advisor
• A banking or thrift institution
• An accountant or accounting firm
• A lawyer or law firm
• An insurance company or agency
• A pension consultant
• A real estate broker or dealer
• A sponsor or syndicator of limited partnerships
ITEM 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Private Family Wealth Advisors,
its management and supervised persons (collectively
“personnel”) subscribe to a strict Code of Ethics. The Code of Ethics is designed to comply with
the investment advisory laws and regulations that require firms to act as fiduciaries in
transactions with their clients. The Firm’s inherent fiduciary duty requires that the Firm act solely
in its clients’ best interest and adhere to standards of utmost integrity in its communications and
transactions. These standards ensure that clients’ interests are preeminent.
Accordingly, Private Family Wealth Advisors has implemented extensive policies, guidelines and
procedures that promote ethical practices and conduct by all of the Firm’s personnel. The Firm’s
Code of Ethics specifies and prohibits certain types of transactions deemed to create conflicts of
interest (or perceived conflicts of interest), as well as to establish reporting requirements and
enforcement procedures relating to personal transactions by its personnel. The Code of Ethics,
which specifically deals with professional standards, insider trading, personal trading, gifts and
entertainment, and fiduciary duties, establishes the Firm’s ideals for ethical conduct based upon
fundamental principles of openness, integrity, honesty and trust. The Firm will provide a copy of
the complete Code of Ethics to any client or prospective client upon request.
A. Proprietary Trading
Private Family Wealth Advisors and its representatives are permitted to buy or sell securities for
their own accounts that the Firm also recommends to clients, consistent with the Firm’s policies
and procedures. This presents a conflict of interest because it may be possible for us or our
representatives to receive more favorable prices than our clients. We will always document any
transactions that could be construed as a conflict of interest. To mitigate this conflict of interest,
we will monitor trading reports for adherence to our Code of Ethics.
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Private Family Wealth Advisors
B. Participation or Interest in Client Transactions
The Firm does not recommend that clients buy or sell securities issued by companies in which
the Firm or its supervised persons may have a material financial interest.
ITEM 12: Brokerage Practices
A. The Custodians and Brokers We Use
We typically recommend that our clients use Charles Schwab & Co., Inc. (“Schwab”), a registered
broker-dealer, member SIPC, as the Custodian.
We are independently owned and operated and are not affiliated with Schwab. Schwab will hold
your assets in a brokerage account and buy and sell securities when we instruct them to. While
we recommend that you use Schwab as the Custodian, you will decide whether to do so and will
open your account with Schwab by entering into an account agreement directly with them.
Conflicts of interest associated with this arrangement are described below as well as in Item 14
(Client Referrals and Other Compensation). You should consider these conflicts of interest when
selecting your custodian.
We do not open the account for you, although we may assist you in doing so. Not all advisers
require their clients to use a particular broker-dealer or other custodian selected by the adviser.
Even though your account is maintained at Schwab, and we anticipate that most trades will be
executed through Schwab, we can still use other brokers to execute trades for your account as
described below see (“Your brokerage and custody costs”).
B. How We Select Brokers/Custodians
In recommending a Custodian, we take into account a wide range of factors, including:
• Combination of transaction execution services and asset custody services (generally
without a separate fee for custody)
• Capability to execute, clear and settle trades (buy and sell securities for your account)
• Capability to facilitate transfers and payments to and from accounts (wire transfers,
check requests, bill payment, etc.)
• Breadth of available investment products (stocks, bonds, mutual funds, exchange-
traded funds (ETFs), etc.)
• Availability of investment research and tools that assist us in making investment
decisions
• Quality of services
• Competitiveness of the price of those services (commission rates, margin interest
rates, other fees, etc.) and willingness to negotiate the prices
• Reputation, financial strength, security and stability
• Prior service to use and our clients
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Private Family Wealth Advisors
• Services delivered or paid for by the Custodian
• Availability of other products and services that benefit us.
C. Your Brokerage and Custody Costs
For our clients’ accounts that Schwab maintains, Schwab generally does not charge you
separately for custody services but is compensated by charging you commissions or other fees
on trades that it executes or that settle into your Schwab account. Certain trades (for example,
mutual funds and ETF) do not incur Schwab commissions or transaction fees. Schwab is also
compensated by earning interest on the uninvested cash in your account in Schwab’s Cash
Features Program. Schwab’s commission rates were negotiated based on the expectation that
our clients collectively maintain a total of at least $550 million in assets in accounts at Schwab.
This commitment benefits you because the overall commission rates you pay are lower than they
would be otherwise. In addition, Schwab charges you a flat dollar amount as a “prime broker” or
“trade away” fee for each trade that we have executed by a different broker-dealer but where
the securities bought or the funds from the securities sold are deposited (settled) into your
Schwab account. These fees are in addition to the commissions or other compensation you pay
the executing broker-dealer. Because of this, in order to minimize your trading costs, we have
Schwab execute most trades for your account.
We are not required to select the broker or dealer that charges the lowers transaction cost, even
if that broker provides execution quality comparable to other brokers or dealers. Although we
are not required to execute all trades through Schwab, we have determined that having Schwab
execute most trades is consistent with our duty to seek “best execution” of your trades. Best
execution means the most favorable terms for a transaction based on all relevant factors,
including those listed above (see “How We Select Brokers/Custodians”). By using another broker
or dealer you may pay lower transaction costs.
You will incur other charges from Schwab for certain types of transactions and services. These
prices may change over time. You can request a complete list of such charges in effect at any
time from us or from Schwab.
D. Products and Services Available to Us from Schwab
Schwab Advisor ServicesTM is Schwab’s business serving independent investment advisory firms
like us. They provide our clients and us with access to their institutional brokerage services
(trading, custody, reporting and related services), many of which are not typically available to
Schwab retail customers. However, certain retail investors may be able to get institutional
brokerage services from Schwab without going through us. Schwab also makes available various
support services. Some of the services help us manage or administer our clients’ accounts, while
others help us manage and grow our business. Schwab’s support services are generally available
on an unsolicited basis (we don’t have to request them) and at no charge to us. Following is a
more detailed description of Schwab’s support services:
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Private Family Wealth Advisors
Services that benefit you. Schwab’s institutional brokerage services include access to a broad
range of investment products, execution of securities transactions and custody of client assets.
The investment products available through Schwab include some to which we might not
otherwise have access or that would require a significantly higher minimum initial investment by
our clients. Schwab’s services described in this paragraph generally benefit you and your
accounts.
Services that do not directly benefit you. Schwab also makes available to us other products and
services that benefit us but do not directly benefit you or your accounts. These products and
services assist us in managing and administering our clients’ accounts and operating our firm.
They include investment research, both Schwab’s own and the of third parties. We use this
research to service all or a substantial number of our clients’ accounts, including accounts not
maintained at Schwab. In addition to investment research, Schwab also makes available software
and other technology that:
• Provide access to client account data (such as duplicate trade confirmations and
accounts statements)
• Facilitate trade execution and allocated aggregated trade orders for multiple client
accounts
• Provide pricing and other market data
• Facilitate payment of our fees from our clients’ accounts
• Assist with back-office functions, recordkeeping, and client reporting
Services that generally benefit only us. Schwab also offers other services intended to help us
manage and further develop our business enterprise. These services include:
• Educational conferences and events
• Consulting on technology and business needs
• Consulting on legal and compliance related needs
• Publications and conferenced on practice management and business succession
• Access to employee benefits providers, human capital consultants, and insurance
providers
• Marketing consulting and support
• Recruiting and custodial search consulting
Schwab provides some of these services itself. In other cases, it will arrange for a third-party
vendor to provide the services to us. Schwab also discounts or waives its fees for some of these
services or pays all or a part of a third party’s fees. Schwab also provides us with other benefits,
such as occasional business entertainment of our personnel. If you did not maintain your account
with Schwab, we would be required to pay for those services from our own resources.
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Private Family Wealth Advisors
Our Interest in Schwab’s Services
The availability of these services from Schwab benefits us because we do not have to produce or
purchase them. We don’t have to pay for Schwab’s services. Schwab has also agreed to pay for
certain technology, research, marketing, and compliance consulting products on our behalf.
These services are not contingent upon us committing any specific amount of business to Schwab
in trading commission or assets in custody. The fact that we receive these benefits from Schwab
is an incentive for us to recommend the use of Schwab rather than making such a decision based
exclusively on your interest in receiving the best value in custody services and the most favorable
execution of your transactions. This is a conflict of interest. We believe, however, that taken in
the aggregate our recommendation of Schwab as custodian and broker is in the best interests of
our clients. Our selection is primarily supported by the scope, quality and price of Schwab’s
services (see “How we Select Brokers/Custodians”) and not Schwab’s services that benefit only
us.
In order to develop relationships with clients by making the transition to Schwab smooth, we
executed a Client Benefit Agreement with Schwab. Pursuant to the Client Benefit Agreement, we
receive reimbursement from Schwab for Transfer of Account Exit Fees for an approximate value
not to exceed $62,500, which is based on 500 client accounts at an average rate of $125 per
account. To be eligible for the reimbursement, the client accounts must be transferred to Schwab
within twelve (12) months from the benefit start date described below. These reimbursement
funds will be used toward the fees your clients’ accounts will bear if the assets of those accounts
are transferred to Schwab.
Schwab also provided payment for eligible third-party vendor services and services provided by
Schwab affiliates not to exceed $200,000 for marketing, technology, consulting or research
expenses. The payments will be distributed as noted in the table below based on transferred
assets held at Schwab during the next twelve (12) months beginning on the benefit start date.
Assets on Deposit
$200,000,000 in Net New Assets at Schwab
$400,000,000 in Net New Assets at Schwab
$500,000,000 in Net New Assets at Schwab
Amount of Support
$70,000 in initial support
$70,000 in additional support
$60,000 in additional support
These arrangements create conflicts of interest, as we have an incentive to recommend Schwab
because of the benefits received. We mitigate this conflict by disclosing the client benefit
arrangement to our clients and by conducting best execution reviews to assure that the
continued recommendation of Schwab is in our clients’ best interests.
E. Brokerage for Client Referrals
Private Family Wealth Advisors does not receive client referrals or compensation of any kind from
broker-dealers or other third parties in exchange for using any particular broker-dealer.
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Private Family Wealth Advisors
F. Directed Brokerage
We routinely recommend that the client direct the Firm to execute transactions through broker-
dealers with which we have a business relationship. As such, we may be unable to achieve the
most favorable execution of the client’s transactions and the client may pay higher brokerage
commissions than the client might otherwise pay through another broker-dealer that offers the
same types of services.
In limited circumstances, our Firm will permit clients to utilize their own broker-dealer. The Firm
may be unable to achieve the most favorable execution of client transactions when we allow
clients to direct brokerage. Client-directed brokerage may cost clients more money. For example,
in a directed brokerage account, clients may pay higher brokerage commissions because our Firm
may not be able to aggregate orders to reduce transaction costs, or the client will not receive the
benefit of preferential pricing that we receive from our preferred broker-dealers.
G. Order Aggregation
We may enter trades as a block where possible and when advantageous to clients whose
accounts have a need to buy or sell shares of the same security. If a block trade occurs, the client
will receive a price that represents the average of the prices at which all of the transactions in
the block were executed. This blocking of trades permits the trading of aggregate blocks of
securities composed of assets from multiple client accounts, and on a pro-rata basis between all
accounts included in any such block. Block trades will include employee transactions in the same
security. Block trading allows us to execute equity trades in a timelier, equitable manner, and
may reduce overall costs to clients.
ITEM 13: Review of Accounts
Client accounts are monitored on a continuing basis.
We review accounts with clients on at least an annual basis. The nature of these reviews is to
learn whether client accounts continue to be aligned with the client’s investment objectives,
appropriately positioned based on market conditions and investment policies, if applicable. We
will inquire at the time of such reviews whether Suitability Information has changed. We attempt
to understand anything that may have changed in our clients’ personal, professional or financial
situations.
Private Family Wealth Advisors may review client accounts more frequently than described
above. Among the factors which may trigger an off-cycle review are major market or economic
events, the client’s life events, requests by the client, etc.
Financial Planning or Consulting clients will receive reviews of their written plans at their request.
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Private Family Wealth Advisors
ITEM 14: Client Referrals and Other Compensation
We receive an economic benefit from Schwab in the form of the support products and services
it makes available to us and other independent investment advisers whose clients maintain their
accounts at Schwab. These benefits create conflicts of interests. The benefits and conflicts are
discussed above in Item 12, subsection D of this Brochure.
Private Family Wealth Advisors does not receive referral compensation. The Firm does not
compensate others for referrals.
ITEM 15: Custody
We are deemed to have custody of your assets if you have executed our standard Investment
Advisory Agreement, which contains authorization for us to deduct investment management fees
directly from your account. We are also deemed to have custody if you grant us authority to
move your money to another person’s account. This authority is granted to us by the client
through the use of a standing letter of authorization (“LOA”) established by the client with his or
her qualified custodian. The standing LOA authorizes our Firm to disburse funds to one or more
third parties specifically designated by the client pursuant to the terms of the LOA and can be
changed or revoked by the client at any time. We have implemented the safeguard requirements
of SEC regulations by requiring safekeeping of your funds and securities by a qualified custodian.
We have further implemented procedures to comply with the requirements outlined by the SEC
in its February 21, 2017 No-Action Letter to the Investment Adviser Association. Schwab
maintains actual custody of your assets.
You will receive account statements directly from Schwab at least quarterly. They will be sent to
the email or postal mailing address you provided to Schwab or other Custodian. This statement
shall disclose to the client the amount of the fee and the client’s assets upon which the fee was
based. The Custodian does not verify the accuracy of Private Family Wealth Advisors’ advisory
fee calculation. Clients are advised to review these statements carefully, comparing asset values,
holdings, and advisory fees on account statements to that in previously received statements,
confirmations and fee invoices. We also urge you to compare Schwab’s accounts statements with
the periodic account statements/portfolio reports you will receive from us.
ITEM 16: Investment Discretion
Clients provide Private Family Wealth Advisors with investment discretion under our standard
Investment Advisory Agreement By virtue of our having been granted investment discretion, the
Firm is authorized to execute securities transactions, determine which securities are bought and
sold, and the total amount to be bought and sold. Limitations may be imposed by the client in
the form of specific constraints on any of these areas of discretion with the Firm’s written
acknowledgement.
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Private Family Wealth Advisors
ITEM 17: Voting Client Securities
As a policy and in accordance with Private Family Wealth Advisor’s client agreement, PFWA is
designated as voting proxies related to securities held in client accounts, unless the Client
specifically reserves the right to vote his or her own proxies by written notice delivered to
PFWA. The custodian of the account will provide proxy materials directly to us. This service is
offered primarily as a convenience to our Clients. Historically, PFWA has voted all proxies,
however effective July 2025 the firm will only be appointed as having this authority as a
convenience to the Client and PFWA will not be voting them. If Clients wish to retain voting
authority, please let us know. Proxy materials must go to the Client or to PFWA, and there is
not an “opt out” provision of receiving proxy materials from the custodian.
If Clients choose to retain proxy voting authority, Clients may contact PFWA with questions
relating to proxy procedures and proposals; however, PFWA generally does not research
particular proxy proposals.
ITEM 18: Financial Information
Private Family Wealth Advisors does not require or solicit the prepayment of more than $1,200
in fees six months or more in advance of services rendered. We do not have a financial condition
that is reasonably likely to impair our ability to meet contractual commitments to clients, and we
have not been the subject of a bankruptcy petition at any time during the past ten years.
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