Singer Wealth Management

Form ADV Part 2A – Disclosure Brochure Singer Wealth Management, LLC. 1406 Harvard Ave #2 Seattle, WA 98122 206-300-7464 SingerWealthManagement.com June 4, 2026 This Disclosure Brochure provides information about the qualifications and business practices of Singer Wealth Management, LLC. (“SWM” or the “Advisor”). If you have any questions about the contents of this Disclosure Brochure, please contact Alicia Singer at (206) 300-7464 or by email at AliciaSinger@SingerWealthManagement.com. SWM is a Registered Investment Adviser. The information in this Disclosure Brochure has not been approved or verified by the U.S. Securities and Exchange Commission (“SEC”) or by any state securities authority. Registration of an investment adviser does not imply any specific level of skill or training. This Disclosure Brochure provides information about SWM to assist you in determining whether to retain them as an Advisor. Additional information about SWM, and its advisory personnel are available on the SEC’s website at www.adviserinfo.sec.gov. SWM’s CRD No. is 299603.  Item 2 – Material Changes Annual Update When material changes occur, we will amend this Disclosure Brochure to reflect the changes. Annually, a Summary of Material Changes will be provided to each Client and an offer of a complete Disclosure Brochure if a material change occurs in the business practices of SWM. Material Changes since the Last Update Since the Firm’s last annual update brochure of March 5, 2026, there have been no material changes; however, the firm has applied for registration with the Securities and Exchange Commission. Full Brochure Available At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. You may also request a copy of this Disclosure Brochure at any time, by contacting us at (206) 300-7464 or by email at AliciaSinger@SingerWealthManagement.com. ii  Item 3 – Table of Contents ITEM 1 – COVER PAGE ………………………………………………………………………………………………………………….. I ITEM 2 – MATERIAL CHANGES ............................................................................................................................. II ITEM 3 – TABLE OF CONTENTS............................................................................................................................ III ITEM 4 – ADVISORY SERVICES ............................................................................................................................. 4 FIRM INFORMATION .................................................................................................................................................................................................. 4 ADVISORY SERVICES OFFERED .................................................................................................................................................................................. 4 ADVISORY AGREEMENT ............................................................................................................................................................................................. 5 TERMINATION OF AGREEMENTS ................................................................................................................................................................................. 5 WRAP FEE PROGRAMS ............................................................................................................................................................................................... 5 ASSETS UNDER MANAGEMENT ................................................................................................................................................................................... 5 ITEM 5 – FEES AND COMPENSATION .................................................................................................................... 5 FEE BILLING .......................................................................................................................................................................................................................... 5 OTHER FEES AND EXPENSES ...................................................................................................................................................................................... 5 ADVANCE PAYMENT OF FEES AND TERMINATION ........................................................................................................................................................ 6 COMPENSATION FOR SALES OF SECURITIES ............................................................................................................................................................... 7 ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .......................................................... 7 ITEM 7 – TYPES OF CLIENTS ................................................................................................................................. 7 ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ............................................. 7 METHODS OF ANALYSIS ............................................................................................................................................................................................. 7 INVESTMENT STRATEGY ............................................................................................................................................................................................ 7 RISK OF LOSS ............................................................................................................................................................................................................ 8 ITEM 9 – DISCIPLINARY INFORMATION .............................................................................................................. 9 ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ......................................................... 9 ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ............................................................................................................................................................... 9 CODE OF ETHICS ....................................................................................................................................................................................................... 9 PERSONAL TRADING WITH MATERIAL INTEREST ......................................................................................................................................................... 9 PERSONAL TRADING IN SAME SECURITIES AS CLIENTS ............................................................................................................................................... 10 ITEM 12 – BROKERAGE PRACTICES………………………………………………………………………………………………….10 RECOMMENDATION OF CUSTODIAN[S] .................................................................................................................................... 10 AGGREGATING AND ALLOCATING TRADES .................................................................................................................................................................. 11 ITEM 13 – REVIEW OF ACCOUNTS……………………………………………………………………………………………………11 FREQUENCY OF REVIEWS ........................................................................................................................................................................................... 11 CAUSES FOR REVIEWS ............................................................................................................................................................................................... 11 REVIEW REPORTS ...................................................................................................................................................................................................... 11 ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION…………………………………………………………………11 COMPENSATION RECEIVED BY SWM ...................................................................................................................................... 11 CLIENT REFERRALS FROM SOLICITORS....................................................................................................................................................................... 11 ITEM 15 – CUSTODY……………………………………………………………………………………………………………………...11 ITEM 16 – INVESTMENT DISCRETION……………………………………………………………………………………………….12 ITEM 17 – VOTING CLIENT SECURITIES…………………………………………………………………………………………….12 ITEM 18 – FINANCIAL INFORMATION.……………………………………………………………………………………………...12  Item 4 – Advisory Services Firm Information Singer Wealth Management, LLC (“SWM” or the “Advisor”), which is organized as a limited liability company under the laws of the State of Washington was founded in October 2018, and is solely owned and operated by Alicia Singer, Managing Member and Founder. When SWM provides investment advice to a client 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. The way SWM makes money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Advisory Services Offered Singer Wealth Management, LLC offers investment management and financial planning services to individuals, families, trusts, estates, and small businesses, including their retirement plans (each referred to as a “Client”). The following describes SWM’s engagements with its clients. Personal Financial Planning Services Singer Wealth Management, LLC will typically provide a variety of financial planning services to individuals, and families, pursuant to a written Investment Advisory Agreement. Services are customized to a client’s financial situation, their goals, and objectives. In general, the financial planning services will address any or all of the following areas of concern: • • PERSONAL: Family records, budgeting, personal liability, estate information and financial goals. TAX & CASH FLOW: Income tax and spending analysis and planning for past, current and future years. SWM will illustrate the impact of various investments on a client’s current income tax and future tax liability. • DEATH & 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. • SWM gathers required information through in-depth personal interviews. Information gathered includes a client’s current financial status, future goals and attitudes towards risk. Related documents supplied by the client are carefully reviewed, including a questionnaire completed by the client. A financial plan developed for or financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. For certain financial planning engagements, the Advisor will provide a written summary of client’s financial situation, observations, and recommendations. Implementation of SWM’s financial planning recommendations is entirely at the client’s discretion. All recommendations are based on the best interest of the client. The client is under no obligation to effect transactions through SWM. Should a client choose to implement SWM’s investment recommendations the client will separately engage SWM for investment management services. Investment Management Services SWM will provide investment management and ongoing oversight of a client’s account held at an independent custodian. SWM works with each client to identify their investment goals and objectives as well as risk tolerance and  financial situation in order to create a portfolio strategy. SWM will then primarily use a portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the client’s investment goals. Advisor may include legacy positions and other types of investments as appropriate. Initial public offerings (IPOs) and non- traded REITS are not available through SWM. Clients grant SWM discretionary authority to manage client’s cash and securities in the account(s). In granting this discretionary authority, SWM has the full power to direct, manage, and supervise the investment and reinvestment of assets in a client’s account without prior consultation with client. SWM does not provide securities custodial services. At no time will SWM accept or maintain custody of a client’s funds or securities, except as to the authorized deduction of the Advisor’s fees. All client assets will be managed within their designated brokerage account or pension account, pursuant to the client investment advisory agreement. Advisory Agreement Prior to engaging SWM to provide investment advisory services, each client is required to enter into an investment advisory agreement with SWM that defines the terms, conditions, authority and responsibilities of SWM and the Client. Termination of Agreements If a client does not receive a Brochure at least 48 hours prior to entering into an advisory agreement, the client has a right to terminate the contract without penalty within five business days after entering into the contract. Although investment management contemplates an ongoing agreement, the length of service is at the client’s discretion. The Client or SWM may terminate the agreement at any time by written notice to the other party upon thirty (30) days written notice. Wrap Fee Programs SWM does not manage or place client assets into a wrap fee program. Assets Under Management As of December 31, 2025, SWM had $118,997,543, in discretionary assets under management. Item 5 – Fees and Compensation The following details the fee structure and compensation methodology for services provided by SWM. The specific manner in which fees are charged by SWM is established in each client’s written agreement with SWM. Fees may be waived in certain circumstances and are negotiable in SWM’s sole discretion based on such factors as the complexity of the client’s situation, the composition of the client’s account, and the relationship of the client with SWM. Personal Financial Planning Fees Singer Wealth Management, LLC offers financial planning services on an hourly basis for $400 per hour, with a minimum fee of $4,000. For any time spent in the engagement beyond ten hours the hourly fee is incurred and charged in addition to the minimum fee. Investment Management Fee SWM’s investment management fees are based on the market value of assets under management at the end of each calendar quarter. Fees for investment management services are charged according to the following schedule on the assets under management applied on a cumulative basis: Assets Under Management Annual Rate  $0 to $1,999,999 1.00% Next $2,000,000 to $4,999,999 0.70% Next $5,000,000 to $9,999,999 0.50% Next $10,000,000 to $24,999,999 0.40% $25,000,000 and above negotiable Example of a fee calculation for an account with $2,500,000: 1% on the first $1,999,999 is $19,999 .70% on next $500,000 is $3,500 Total Fee: $22,499 The investment management fee in the first quarter of services is prorated from the inception date of the account to the end of the first quarter. All securities held in accounts managed by SWM will be independently valued by the designated Custodian. Minimum account size of $500,000 is generally needed. Clients receiving ongoing asset management services will be assessed a $5,000 minimum annual fee. Because SWM has a minimum fee of $5,000 there may be times when SWM's fees in this instance may be higher than normally charged in the industry and that similar services may be offered by another adviser at a lower fee. Fee Billing Investment Management Fee Investment management fees are billed quarterly, in advance, pursuant to the terms of the client’s investment advisory agreement with SWM. Clients provide written authorization permitting SWM to be paid directly from their accounts held at the custodian as part of the investment management agreement and separate account forms provided by the Custodian. Investment management fees will be automatically deducted from the client’s account by the Custodian. SWM will send a notice to the account’s custodian indicating the amount of the fees to be deducted from the account at the respective quarter’s end date. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with SWM at the end of each quarter. Clients will be provided with a statement, at least quarterly, from the account’s custodian reflecting deductions of the Advisor’s advisory fee. In all instances, SWM will send the client a written invoice, including the fee, the formula used to calculate the fee, the fee calculation itself, the time period covered by the fee, and, if applicable, the amount of assets under management on which the fee was based and the name of the custodian(s). Financial Planning Services At the time of the signing of the agreement SWM provides an estimate of the total fee for the scope of requested services. SWM collects half of the total estimated fee at the time of signing the engagement and the remaining fee upon presentation of the financial plan. Fees may be paid by ACH, credit card, or deduction from the Client’s taxable brokerage account. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than SWM, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custodial and securities execution fees charged by the custodian and executing broker-dealer. The investment management fee charged by SWM is separate and distinct from these custodian and execution fees. In addition, all fees paid to SWM for investment advisory services are separate and distinct from the expenses charged by mutual funds and exchange-traded funds to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees  for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client could invest in these products directly, without the services of SWM, but would not receive the services provided by SWM which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by SWM to fully understand the total fees to be paid. Advance Payment of Fees and Termination Investment Management SWM is compensated for its services in advance of the quarter in which investment advisory services are rendered. Clients may request to terminate their Investment Advisory Agreement with SWM, in whole or in part, by providing advance written notice. The Client shall be responsible for investment management fees up to and including the effective date of termination. Upon termination, the Advisor will promptly refund any unearned, prepaid Investment Advisory Fees from the effective date of termination to the end of the quarter. If the Client has not received SWM’s Brochure at least 48 hours prior to entering into an investment advisory agreement, the Client has the right to terminate the agreement without penalty within five business days after entering into the contact. Compensation for Sales of Securities SWM does not buy or sell securities and does not receive any compensation for securities transactions in any Client account, other than the Investment Advisory Fees noted above. Item 6 – Performance-Based Fees and Side-By-Side Management SWM does not charge performance-based fees for its investment advisory services. SWM does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Singer Wealth Management, LLC offers investment advisory services to individuals, families, trusts, estates, and small businesses, including their retirement plans. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis SWM, through Wealth Management, LLC, will primarily employ fundamental analysis methods in developing investment strategies for its Clients accounts. Research and analysis is derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria are generally ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps evaluate a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. SWM may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting  of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Investment Strategy SWM’s investment strategy is primarily long-term focused, but SWM may buy, sell or re-allocate positions that have been held less than one year to meet the objectives of the Client or due to market conditions. SWM will monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by SWM. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. SWM will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. Each Client engagement will entail a review of the Client’s investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client’s account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client’s account. SWM shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. The Client is responsible for informing SWM of any changes in financial condition, goals or other factors that may affect this analysis. SWM will work with each Client to determine their tolerance for risk as part of the portfolio construction process. However, all investment programs have certain risks that are borne by the investor. Investors face the following investment risks:  Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline.  Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic and social conditions may trigger market events.  Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation.  Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities.  Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like.  Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not.  Financial Risk: Excessive borrowing to finance a business’ operations increases 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.  Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information Singer Wealth Management, LLC is required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of our firm or the integrity of our management. We have no information applicable to this Item. Item 10 – Other Financial Industry Activities and Affiliations Neither Singer Wealth Management, LLC nor any affiliated person is registered as or have a pending application as a broker-dealer, futures commission merchant, commodity pool operator, or commodity trading advisor or as a representative of any of the foregoing entities. The Firm does not have a relationship or an arrangement with any related person that provides or acts as any of the following: a broker-dealer, municipal securities dealer, or government securities dealer or broker; an investment company or other pooled investment vehicle (e.g. mutual fund, private fund, etc.); another 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; or a sponsor or syndicator of limited partnerships. SWM does not recommend or select other advisors. We are not involved in any other financial industry activities. Upon client request, we may provide referrals to various professionals, such as a mortgage broker, insurance agent or attorney or they may make a referral of a client to SWM. We do not have an agreement with or receive fees from these professionals for our referrals nor do we compensate any individual for referrals made to SWM. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading contact us at (206) 300-7464 or Code of Ethics Singer Wealth Management, LLC has implemented a Code of Ethics that defines our fiduciary commitment to each Client. This Code of Ethics applies to all persons associated with Singer Wealth Management, LLC (our “Supervised Persons”). The Code of Ethics was developed to provide general ethical guidelines and specific instructions regarding our duties to our Clients. Singer Wealth Management, LLC and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Singer Wealth Management, LLC associates to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code of Ethics covers a range of topics that address ethics and conflicts of interest. To request a copy of our Code of Ethics, please via email at AliciaSinger@SingerWealthManagement.com. Personal Trading with Material Interest SWM does not purchase or sell the same securities that SWM has a material interest in. SWM does not act as principal in any transactions. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). In addition, the Advisor does not act as the general partner of a fund or advise an investment company. SWM does not have a material interest in any securities traded in Client accounts. Personal Trading in Same Securities as Clients SWM allows our employees to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities, we recommend (purchase or sell) to you presents a potential conflict of interest that, as fiduciaries, we must disclose to you and mitigate through policies and procedures. The fiduciary duty  to act in the best interest of its Clients can potentially be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by the fact that most trades in a Client’s account are mutual funds and ETFs that present little to no likelihood of a material conflict when purchasing the same securities. Item 12 – Brokerage Practices Recommendation of Custodian[s] SWM does not have discretionary authority to select the broker-dealer/custodian for custodial and execution services. The Client retains the right to select the broker-dealer or custodian (herein the “custodian”) to safeguard Client assets and authorize SWM to direct trades to this custodian as agreed to in the Investment Advisory Agreement. Further, SWM does not have the discretionary authority to negotiate commissions on behalf of our Clients on a trade-by-trade basis. Any custodial recommendations are based on the Client’s need for such services. Singer Wealth Management, LLC will generally recommend that Clients establish their account[s] at Charles Schwab, a FINRA-registered broker-dealer and member SIPC. Charles Schwab will serve as the Client’s “qualified custodian.” Singer Wealth Management, LLC maintains an institutional relationship with Charles Schwab, whereby Charles Schwab provides various economic benefits (Please see Item 14 below.). Following are additional details regarding the brokerage practices of SWM: 1. Soft Dollars -Singer Wealth Management, LLC participates in Charles Schwab’s institutional customer program and the Advisor may recommend Charles Schwab to Clients for custody and brokerage services. There is no direct link between the Advisor’s participation in the program and the investment advice it gives to its Clients, although the Advisor receives economic benefits through its participation in the program that are typically not available to Charles Schwab retail investors. These benefits include the following products and services (provided without cost or at a discount): receipt of duplicate Client statements and confirmations; research related products and tools; consulting services; access to a trading desk serving the Advisor participants; access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to Client accounts); the ability to have advisory fees deducted directly from Client accounts; access to an electronic communications network for Client order entry and account information; access to mutual funds with no transaction fees and to certain institutional money managers; and discounts on compliance, marketing, research, technology, and practice management products or services provided to the Advisor by third party vendors. Charles Schwab may also have paid for business consulting and professional services received by the Advisor’s related persons. Some of the products and services made available by Charles Schwab through the program may benefit the Advisor but may not benefit its Client accounts. These products or services may assist the Advisor in managing and administering Client accounts, including accounts not maintained at Charles Schwab. Other services made available by Charles Schwab are intended to help the Advisor manage and further develop its business enterprise. The benefits received by the Advisor or its personnel through participation in the program do not depend on the amount of brokerage transactions directed to Charles Schwab. As part of its fiduciary duties to clients, Singer Wealth Management, LLC endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by Singer Wealth Management, LLC or its related persons in and of itself creates a conflict of interest and may indirectly influence the Advisor’s choice of Charles Schwab for custody and brokerage services. 2. Brokerage Referrals – Singer Wealth Management, LLC does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage – All Clients are serviced on a “directed brokerage basis”, where Singer Wealth Management, LLC will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective brokerage account[s]. Singer Wealth Management, LLC will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian.  Aggregating and Allocating Trades The Advisor does not aggregate a Client’s trades with other clients. The Advisor will allocate trade opportunities in a fair and equitable manner. Item 13 – Review of Accounts Frequency of Reviews Financial planning engagements are complete after the financial plan is presented so no further reviews are conducted. Investment management accounts are monitored on a regular and continuous basis. Reviews of clients’ account are conducted by Alicia Singer and are generally conducted no less than annually. Reviews may be performed more frequently depending upon the needs of the Client. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more or less frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account. The Client is encouraged to notify SWM if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. Review Reports The Client will receive account statements no less than quarterly from the custodian. These statements are sent directly from the custodian to the Client. The Client may also establish electronic access to the custodian’s website so that the Client may view these reports and their account activity. Client statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor will also provide Clients with periodic reports regarding their holdings, allocations, and performance. Clients are responsible for reviewing their accounts. Item 14 – Client Referrals and Other Compensation Compensation Received by SWM SWM is a fee-only advisory firm, who, in all circumstances, is compensated solely by the Client. SWM does not receive commissions or other compensation from product sponsors, broker-dealers or any un-related third party. SWM may refer Clients to various third parties to provide certain financial services necessary to meet the goals of its Clients. Likewise, SWM may receive referrals of new Clients from a third-party. But no compensation is either paid or received for a referral. Client Referrals from Solicitors SWM does not engage paid solicitors for Client referrals. Item 15 – Custody All Clients assets are held at an independent qualified custodian. We may provide you with periodic reports from our firm that includes investment performance information. You are urged to carefully review and compare your account statements that you have received directly from your service provider with any report you receive from our firm. SWM does not accept or maintain physical custody of any Client accounts; however, the firm is deemed to have constructive custody because of its authority to make withdrawals from client accounts to pay its advisory fee. When SWM directly deducts its fee from clients’ accounts, SWM follows the following safeguards: SWM has written authorization from the client to deduct advisory fees from the account held with the   qualified custodian; and Each time a fee is directly deducted from a client account, SWM concurrently:  1. Sends the qualified custodian an invoice or statement of the amount of the fee to be deducted from the client's account; and 2. Sends the client an invoice or statement itemizing the fee. Itemization includes the formula used to calculate the fee, the value of the assets under management on which the fee is based, and the time period covered by the fee. SWM is also deemed to have constructive custody resulting from the use of Standing Letters of Authorization (“SLOA”) for money transfer between a client’s account and a third-party account as designated by the client. The Firm follows the guidance set forth in the SEC No Action Letter of February 21, 2017, and maintains records to avoid the surprise audit requirement in those accounts that would otherwise be required of advisers with custody. Item 16 – Investment Discretion SWM has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by SWM. The granting of such authority will be evidenced by the Client’s execution of an investment management services agreement containing all applicable limitations to such authority. All discretionary trades made by SWM will be in accordance with each Client’s investment objectives and goals. Item 17 – Voting Client Securities Clients will receive proxy statements directly from the Custodian. SWM does not accept proxy-voting responsibility for any Client but will assist in answering questions relating to proxies. However, the Client retains the sole responsibility for proxy decisions and voting. You will receive proxies or other similar solicitations directly from your selected custodian or transfer agent. Further, SWM will have no power, authority, responsibility, or obligation to take any action with regard to any claim or potential claim in any bankruptcy proceeding, class action securities litigation or other litigation or proceeding relating to securities held at any time in a client account, including, without limitation, to file proofs of claim or other documents related to such proceeding, or to investigate, initiate, supervise or monitor class action or other litigation involving client assets. Item 18 – Financial Information Neither SWM, nor its management, have any adverse financial situations that would reasonably impair the ability of SWM to meet all obligations to its Clients. Neither SWM, nor any of its advisory persons, has been subject to a bankruptcy or financial compromise. SWM is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect fees $1200 or more for services to be performed six months or more in advance.