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Sparrow Wealth Management
6900 Tavistock Lakes Blvd, Suite 400
Orlando, FL 32827
Phone: 877-330-9191
Fax: 877-330-9191
Web Site: www.sparrowwealth.com
February 19, 2026
FORM ADV PART 2A
BROCHURE
This brochure provides information about the qualifications and business practices of
Sparrow Wealth Management. If you have any questions about the contents of this
brochure, please contact us at 877-330-9191. 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 Sparrow Wealth Management is also available on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Sparrow Wealth
Management is 152670.
Sparrow Wealth Management is a Registered Investment Adviser. Registration with the
United States Securities and Exchange Commission or any state securities authority does
not imply a certain level of skill or training.
Sparrow Wealth Management
Form ADV Part 2A Brochure
IARD/CRD No.: 152670
February 19, 2026
Item 2 – Material Changes
Since the last annual filing of Form ADV Part 2A, the following material changes have occurred:
Item 4 – Assets under management and the number of accounts were updated.
•
• Throughout – Sparrow Wealth Management transitioned from state to SEC registration in Q1 2025.
For further information, please see each item below.
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Sparrow Wealth Management
Form ADV Part 2A Brochure
IARD/CRD No.: 152670
February 19, 2026
Item 3 – Table of Contents
Material Changes
2
Advisory Business
4
Fees and Compensation
7
Performance Based Fees
9
Types of Clients
10
Methods of Analysis, Investment Strategies
11
Disciplinary Information
13
Other Financial Industry Activities
14
Code of Ethics, Participation or Interest in Client Transactions
15
Brokerage Practices
16
Review of Accounts
18
Client Referrals and Other Compensation
19
Custody
20
Investment Discretion
21
Voting of Client Securities
22
Financial Information
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Sparrow Wealth Management
Form ADV Part 2A Brochure
IARD/CRD No.: 152670
February 19, 2026
Item 4 - Advisory Business
Sparrow Wealth Management (“SWM” or the “firm”) was organized in January 2010 and is registered with the
U.S. Securities and Commission (“SEC”). Christopher Jones (CRD Number 4549249) is President and Chief
Compliance Officer of the firm. Mr. Jones owns one hundred percent (100%) of the equity of the firm. The firm
is not publicly owned or traded. There are no indirect owners of the firm or intermediaries, which have any
ownership interest in the firm. As of December 31, 2025, the firm managed, on a discretionary basis,
$135,197,184.28 in client assets, which represented 224 accounts. Client assets are managed on an
individualized basis. Clients may impose restrictions on their accounts. The firm does not sponsor any wrap
programs.
SWM is a fee-only financial planning and asset management company. SWM provides a variety of services for
individuals, families, trusts, and businesses as described below.
Financial Planning Services
SWM offers clients its financial planning services as part of a combined service offering with asset
management, as described below. Clients pay a quarterly “base” fee for personal financial planning services,
as described in Item 5. Due to capacity limitations, SWM does not offer “financial planning only engagements.”
The client will generally meet with an adviser several times per year, and these meetings can be in-person, via
telephone, or over the computer.
Financial planning services include updating a client’s profile, reviewing the client’s personal and financial
goals, reviewing the client’s net worth, evaluating the client’s investment portfolio and making
recommendations, doing a cash flow analysis, education planning, retirement planning, tax planning, advising
the client on corporate benefits, reviewing the client’s insurance needs, reviewing the client’s estate plan, and
providing general financial advice on any personal matter that the client has questions about.
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Sparrow Wealth Management
Form ADV Part 2A Brochure
IARD/CRD No.: 152670
February 19, 2026
Clients are under no obligation to act upon SWM’s financial planning recommendations, and clients are under
no obligation to effect any transactions through SWM.
Asset Management Services
SWM offers asset management services for long-term clients. The process for providing asset management
begins with the establishment of the client’s goals, objectives, time horizon, and risk tolerance. SWM works with
the client to understand these critical components. Then, SWM assists the client in developing an Investment
Policy Statement that clearly shows how the client’s assets will be allocated across the various asset classes or
risk factors. In developing the Investment Policy Statement, the first decision that must be made is how much of
the client’s assets to invest in fixed income and how much to invest in equity. Then, SWM allocates the equity
portion of the client’s portfolio across the following asset classes—U.S. and international, small and large, and
value and growth. For the fixed income portion of the portfolio, SWM primarily invests in short-term bonds,
intermediate bonds, and inflation-adjusted bonds. Depending on the client’s specific needs and goals, SWM
may decide to use additional asset classes (not mentioned above), or SWM may exclude some of its standard
asset classes. Clients may impose restrictions on investing in certain securities or types of securities so long as
such restrictions may reasonably be implemented by the adviser.
SWM will manage the client’s assets on a discretionary basis. SWM will retain the discretion to buy, sell, or
otherwise transact in securities and other investments in the client’s account(s) without first receiving the
client’s specific approval for each transaction. Such discretionary authority is granted by the client in the
Financial Planning & Asset Management Agreement with SWM.
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Sparrow Wealth Management
Form ADV Part 2A Brochure
IARD/CRD No.: 152670
February 19, 2026
ERISA Accounts
When SWM provides investment advice to clients regarding their retirement plan account or individual
retirement account (“IRA”), we are fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act (“ERISA”) and/or the Internal Revenue Code (the “Code”), as applicable, which are laws governing
retirement accounts. The way SWM makes money creates some conflicts with client’s interests, so we operate
under a special rule that requires us to act in our client’s best interest and not put our interest ahead of our
client’s.
Under this special rule’s provisions, SWM must:
● Meet a professional standard of care when making investment recommendations (give prudent advice);
● Never put our financial interests ahead of our clients’ when making recommendations (give loyal
advice);
● Avoid misleading statements about conflicts of interest, fees, and investments;
● Follow policies and procedures designed to ensure that we give advice that is in our client’s best
interest;
● Charge no more than is reasonable for our services; and
● Give clients basic information about conflicts of interest.
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Sparrow Wealth Management
Form ADV Part 2A Brochure
IARD/CRD No.: 152670
February 19, 2026
Item 5 - Fees and Compensation
The “base” fee for personal financial planning services ranges between $250 and $350 per month, depending
on the complexity of the client’s situation. This fee is negotiable. The “base” fee is paid quarterly, in advance. If
a client wants to have the “base” fee debited directly from their brokerage account, along with the asset
management fee (see paragraph below), the client must provide a written authorization to do so. The client may
terminate these services at any time and a pro-rata refund (by day) of any fees paid will be made to the client.
While the “base” fee is designed to cover most personal financial matters that the client may need help with,
SWM reserves the right to charge its hourly fee, which is $350 / hour, for matters that are outside the scope of
SWM’s personal financial planning services, such as providing consulting for a client’s business. Hourly
charges, in this case, are billed monthly, in arrears, at the rate stated above. Lower fees for comparable
services may be available from other sources.
The annual charge for asset management is .75% of assets under management for amounts up to $3,000,000,
.50% for amounts between $3,000,000 and $5,000,000, and .25% for amounts over $5,000,000. The term,
assets under management, generally refers to assets that are held in one or more brokerage account(s) where
SWM has a Limited Power of Attorney on the account(s). Assets under management may also include the
Client’s retirement plans with their employer, such as 401(k) or 403(b) plans, if the Client wants SWM to
manage these accounts. This fee schedule is negotiable based upon portfolio size and other business
considerations. No fee shall be based upon capital gains or capital appreciation of assets. Fees will be paid
quarterly, in advance, and they will be based on the market value of the account(s) as of the last business day
of the prior quarter. No fee shall be paid more than six months in advance. There is no minimum fee for asset
management. Fees for the first quarter will be prorated for the number of days that services are to be provided.
Lower fees for comparable services may be available from other sources.
If a client wants to have these fees debited directly from their brokerage account, the client must provide a
written authorization to do so. The client may terminate SWM’s asset management services at any time and a
pro-rata refund (by day) of any fees paid will be made to the client.
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Sparrow Wealth Management
Form ADV Part 2A Brochure
IARD/CRD No.: 152670
February 19, 2026
In addition to the above fees charged for SWM’s services, each mutual fund and exchange traded fund (“ETF”)
charges on-going management fees for the operations of the fund. These management fees should not be
confused with “loads” or commissions. SWM primarily utilizes “no load” funds for its clients, except in rare
circumstances. Finally, clients pay transaction fees to their brokerage firm for purchases and sales of mutual
funds and other securities.
Neither SWM nor any supervised persons accept compensation for the sale of securities or other investment
products.
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Sparrow Wealth Management
Form ADV Part 2A Brochure
IARD/CRD No.: 152670
February 19, 2026
Item 6 - Performance-Based Fees and Side-By-Side Management
Neither SWM nor any of its supervised persons accepts performance-based fees (fees based on a share of
capital gains or capital appreciation of the assets of a client) or engage in side-by-side management.
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Sparrow Wealth Management
Form ADV Part 2A Brochure
IARD/CRD No.: 152670
February 19, 2026
Item 7 - Types of Clients
SWM offers its services to individuals (primarily high net worth), businesses, pension plans, profit sharing
plans, trusts, estates, and charitable organizations. SWM does not require a minimum amount of client assets
to provide its services.
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Sparrow Wealth Management
Form ADV Part 2A Brochure
IARD/CRD No.: 152670
February 19, 2026
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
SWM’s basic investment philosophy is firmly rooted in the conviction that securities markets are generally
efficient and that investment returns are primarily determined by asset allocation rather than by market timing or
stock picking. Therefore, asset class investments are mostly implemented through the use of no-load, passively
structured mutual funds, conventional index funds, and ETFs. Most of the funds that SWM uses are only
available to institutional investors and approved investment advisers. In rare cases, SWM will use actively
managed funds. With regards to selecting mutual funds and ETFs, SWM is primarily concerned with the fund’s
management style, consistency, and expense ratios.
SWM does not analyze individual securities through charting methods, fundamental analysis, technical
analysis, or any other type of stock picking methodology. As stated previously, SWM’s basic investment
philosophy is firmly rooted in the conviction that securities markets are generally efficient and that investment
returns are primarily determined by asset allocation rather than by market timing or stock picking. SWM’s
investment strategy is to develop globally diversified portfolios composed of passively structured mutual funds
and ETFs that represent specific asset classes in the global markets. These portfolios, which range in risk from
conservative to aggressive, are specifically designed to meet the unique needs of each client.
Like any investment strategy, investing in mutual funds involves material risks and does not guarantee a return
on investment. Shareholders of a mutual fund may lose the principal that they’ve invested into a particular
mutual fund. Mutual funds invest into underlying securities that comprise the mutual fund, and as such clients
are exposed to the risks arising from such underlying securities. Mutual funds charge internal expenses to their
shareholders (which can include management fees, administration fees, shareholder servicing fees, sales
loads, redemption fees, and other fund fees and expenses, e.g.), and such internal expenses subtract from
their potential for market appreciation. Shares of mutual funds may only be traded at their stated net asset
value (“NAV”), calculated at the end of each day upon the market’s close.
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Sparrow Wealth Management
Form ADV Part 2A Brochure
IARD/CRD No.: 152670
February 19, 2026
Investing in ETFs bears similar risks and incurs similar costs to investing in mutual funds as described above.
However, shares of an ETF may be traded like stocks on the open market and are not redeemable at an NAV.
As such, the value of an ETF may fluctuate throughout the day and investors will be subject to the cost
associated with the bid-ask spread (the difference between the price a buyer is willing to pay (bid) for an ETF
and the seller's offering (asking) price).
Clients are encouraged to carefully read the prospectus of any mutual fund or ETF to be purchased for
investment to obtain a full understanding of its respective risks and costs. Investing in securities involves risk of
loss that clients should be prepared to bear.
Investing for the long term means that a client’s account will be exposed to short-term fluctuations in the market
and the behavioral impulse to make trading decisions based on such short-term market fluctuations. SWM does
not condone short-term trading in an attempt to “time” the market, and instead coaches clients to remain
committed to their financial goals. However, investing for the long term can expose clients to risks borne out of
changes to interest rates, inflation, general economic conditions, market cycles, geopolitical shifts, and
regulatory changes.
Past performance of a mutual fund or ETF is no indication of its future return potential.
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Sparrow Wealth Management
Form ADV Part 2A Brochure
IARD/CRD No.: 152670
February 19, 2026
Item 9 - Disciplinary Information
There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of
SWM’s advisory business or the integrity of SWM’s management.
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Sparrow Wealth Management
Form ADV Part 2A Brochure
IARD/CRD No.: 152670
February 19, 2026
Item 10 - Other Financial Industry Activities and Affiliations
Neither SWM nor any of its management persons are registered, or have an application pending to register, as
a broker-dealer or a registered representative of a broker-dealer.
Neither SWM nor any of its management persons are registered, or have an application pending to register, as
a futures commission merchant, commodity pool operator, a commodity trading adviser, or an associated
person of the foregoing entities.
Neither SWM nor any of its management persons have any relationship or arrangement with any related
persons.
SWM does not select other investment advisers for the management of its clients’ accounts.
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Sparrow Wealth Management
Form ADV Part 2A Brochure
IARD/CRD No.: 152670
February 19, 2026
Item 11 - Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
SWM has adopted a written Code of Ethics in accordance with SEC Rule 204A-1. Such Code of Ethics
addresses, among other things, the standards of business conduct that SWM requires of its supervised
persons, which is reflective of SWM’s fiduciary obligations to act in the best interests of its clients. The Code of
Ethics also includes sections related to personal securities transaction practices and prohibitions imposed upon
access persons of the firm, as well as provisions related to the handling of material nonpublic information and
insider trading. A copy of the Code of Ethics is available upon request to all clients and prospective clients.
Neither SWM nor any of its related persons recommends to clients, or buys or sells for client accounts,
securities in which SWM or any of its related persons has a material financial interest.
From time to time, SWM or its related persons will invest in the same securities (or related securities such as
warrants, options or futures) that SWM or a related person recommends to clients. This has the potential to
create a conflict of interest because it affords SWM or its related persons the opportunity to profit from the
investment recommendations made to clients. SWM’s policies and procedures and code of ethics address this
potential conflict of interest by prohibiting such trading by SWM or its related persons if it would be to the
detriment of any client and by monitoring for compliance through the reporting and review of personal securities
transactions. In all instances SWM will act in the best interests of its clients.
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Sparrow Wealth Management
Form ADV Part 2A Brochure
IARD/CRD No.: 152670
February 19, 2026
Item 12 - Brokerage Practices
SWM suggests that clients use a discount brokerage/custodial firm that provides access to no-load mutual
funds, excellent customer service, leading-edge technology, and is cost effective. The commissions and/or
transaction fees charged by the various brokerage/custodian firms that SWM suggests may be higher or lower
than those charged by other firms. In seeking “best execution” for clients, the key factor is not the lowest
possible cost, but whether the transaction represents the best qualitative execution, taking into account the full
range of services, including the execution capability, the technological processes used for submitting trades,
and other valuable services. Based on these factors, SWM generally recommends Fidelity Institutional Wealth
Services (“Fidelity”), referred to as our “Custodian.”
It is customary for a Custodian to provide certain products and services to investment advisers. These products
and services are intended to directly benefit SWM, clients, or both. Such products and services include (a) an
online platform through which SWM can monitor and review client accounts, (b) access to proprietary
technology that allows for order entry, (c) duplicate statements for client accounts and confirmations for client
transactions, (d) deduction of SWM's asset management fees, (e) invitations to the Custodian's educational
conferences, (f) practice management consulting, and (g) occasional business meals and entertainment. The
products and services received by SWM or its personnel through our Custodian do not depend on the amount
of brokerage transactions directed to the Custodian.
The receipt of these products and services does create a conflict of interest. To address this, on a periodic
basis, SWM evaluates the pricing and services offered by our Custodian with those offered by other reputable
firms. In addition, SWM fully discloses the conflict of interest in this brochure and by evaluating the Custodian
based on the value and quality of their services as realized by clients. SWM has sought to make a good-faith
determination that our Custodian provide clients with good services at competitive prices. However, clients
should be aware that this determination could have been influenced by SWM’s receipt of products and services
from our Custodian. Historically, SWM has concluded that our Custodian is as good as, or better than, the other
firms that have been considered. SWM would notify its clients if it were to determine that another firm offered
better pricing and services than the Custodian they have selected.
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Sparrow Wealth Management
Form ADV Part 2A Brochure
IARD/CRD No.: 152670
February 19, 2026
SWM does not consider, in selecting or recommending custodial broker-dealers, whether SWM or a related
person receives client referrals from a custodial broker-dealer or third-party.
SWM does not routinely recommend, request, or require that a client direct SWM to execute transactions
through a specified custodial broker-dealer other than Fidelity.
SWM does not aggregate the purchase or sale of securities for various client accounts. This can result in higher
transaction costs due to clients’ not participating in volume trading discounts that may be available to
aggregated trades through certain custodial broker-dealers.
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Sparrow Wealth Management
Form ADV Part 2A Brochure
IARD/CRD No.: 152670
February 19, 2026
Item 13 - Review of Accounts
SWM conducts account reviews on a monthly basis. The purpose of the review is to determine if the current
asset allocation for the portfolio is significantly out of tolerance with the desired allocation, which is based upon
the client’s Investment Policy Statement. When a client portfolio is significantly out of tolerance, the assets may
be reallocated to keep the portfolio allocation consistent with the client’s Investment Policy Statement. Also,
client accounts may be reviewed more often depending on market conditions. Accounts are reviewed by
Christopher Jones, the President of the firm.
SWM provides quarterly investment reports to asset management clients. These reports will show the client’s
current account holdings (by account and by asset class) and the actual performance of the portfolio since
SWM started to manage the account. In addition to the reports that the clients receive from SWM, they will also
receive monthly statements and trade confirmations directly from their custodial/brokerage firm.
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Sparrow Wealth Management
Form ADV Part 2A Brochure
IARD/CRD No.: 152670
February 19, 2026
Item 14 - Client Referrals and Other Compensation
Client Referrals
SWM does not pay for client referrals.
Fidelity as Custodian
As discussed in Item 12 above, SWM receives certain products and services from Fidelity (our “Custodian”) in
connection with the custodial and brokerage services that they provide to SWM and its clients. Such products
and services could be considered an economic benefit to SWM, which creates a conflict of interest. To address
this, on a periodic basis, SWM evaluates the pricing and services offered by our Custodian with those offered
by other reputable firms. SWM has sought to make a good-faith determination that they provide clients with
good services at competitive prices. In addition, SWM fully discloses the conflict of interest in this brochure and
by evaluating our Custodian based on the value and quality of their services as realized by clients.
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Sparrow Wealth Management
Form ADV Part 2A Brochure
IARD/CRD No.: 152670
February 19, 2026
Item 15 - Custody
SWM maintains the authority to debit its fees directly from clients’ brokerage accounts, but at no time will SWM
accept custody of client funds or securities in the capacity of a Custodian or broker-dealer. At all times client
funds and securities will be held by a third-party qualified Custodian as described in Item 12, above.
Clients will receive monthly statements from their Custodian and quarterly investment reports from SWM.
Clients are urged to carefully review and compare these statements.
SWM has obtained written authorization from each client in the Financial Planning & Asset Management
Agreement to deduct fees from the account held by their Custodian. Each time the fee is to be deducted from a
client account, SWM concurrently sends the Custodian an invoice or statement of the amount of the fee to be
deducted from the client’s account. The Custodian sends monthly statements to clients showing all
disbursements from the client’s account(s), including the amount of fees.
Clients are urged to compare their Custodian account statements against any reports provided by SWM, and to
advise SWM of any discrepancies between them.
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Sparrow Wealth Management
Form ADV Part 2A Brochure
IARD/CRD No.: 152670
February 19, 2026
Item 16 - Investment Discretion
SWM establishes a discretionary relationship with all asset management clients solely with respect to trading in
the account. This type of relationship helps to facilitate the investment process. For example, it allows SWM to
rebalance client portfolios when necessary. SWM’s discretionary authority is set forth in the Financial Planning
& Asset Management Agreement, and includes the authority to buy, sell, and otherwise transact in securities
and other investment products in the client’s account(s) without necessarily consulting with the client in
advance. Clients may place reasonable limitations on this discretionary authority so long as it is agreed to in
writing by SWM.
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Sparrow Wealth Management
Form ADV Part 2A Brochure
IARD/CRD No.: 152670
February 19, 2026
Item 17 - Voting Client Securities
SWM does not have and will not accept authority to vote client securities. Clients will receive their proxies or
other solicitations directly from their custodial broker-dealer or a transfer agent, as applicable, and should direct
any inquiries regarding such proxies or other solicitations directly to the sender.
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Sparrow Wealth Management
Form ADV Part 2A Brochure
IARD/CRD No.: 152670
February 19, 2026
Item 18 - Financial Information
SWM does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in
advance.
SWM retains discretionary trading authority over client accounts, but it does not have custody of client funds or
securities other than for purposes of fee deduction as described above.
SWM has not been subject to a bankruptcy petition in the past ten years.
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