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Summit Wealth Management LLC
Firm Brochure – Form ADV Part 2A
This brochure provides information about the qualifications and business practices of Summit Wealth
Management LLC. If you have any questions about the contents of this brochure, please contact us at
(330) 659-5985 or by email at: rich@swm1.us. 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 Summit Wealth Management LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov.
Summit Wealth Management LLC’s CRD number is: 226722.
2150 N Cleveland-Massillon Rd
Akron, OH, 44333
(330) 659-5985
https://swm1.us/
rich@swm1.us
Version Date 3/30/2026
Registration does not imply a certain level of skill or training.
Item 2: Material Changes
Since our last annual amendment filed on 02/06/2025, we have the following material changes to
disclose:
Updated Item 15 to clarify the firm’s Custody disclosures.
Removed Item 19 to support our conversion from a State of Ohio Registered Investment Advisor
to a Securities and Exchange Commission (SEC) Registered Investment Advisor.
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Item 3: Table of Contents
Item 1: Cover Page
Item 2: Material Changes ....................................................................................................................................................... i
Item 3: Table of Contents ...................................................................................................................................................... ii
Item 4: Advisory Business ..................................................................................................................................................... 1
A. Description of the Advisory Firm .................................................................................................................................. 1
B. Types of Advisory Services ........................................................................................................................................... 1
C. Client Tailored Services and Client Imposed Restrictions .............................................................................................. 2
D. Wrap Fee Programs ..................................................................................................................................................... 2
E. Assets Under Management ........................................................................................................................................... 2
Item 5: Fees and Compensation ............................................................................................................................................ 3
A. Fee Schedule ............................................................................................................................................................... 3
B. Payment of Fees ........................................................................................................................................................... 4
C. Client Responsibility For Third Party Fees .................................................................................................................... 4
D. Prepayment of Fees ..................................................................................................................................................... 4
E. Outside Compensation For the Sale of Securities to Clients ........................................................................................... 4
Item 6: Performance-Based Fees and Side-By-Side Management ............................................................................................ 4
Item 7: Types of Clients ........................................................................................................................................................ 5
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ..................................................................................... 5
Methods of Analysis and Investment Strategies ..................................................................................................... 5
A.
Material Risks Involved ......................................................................................................................................... 5
B.
Risks of Specific Securities Utilized....................................................................................................................... 6
C.
Item 9: Disciplinary Information ........................................................................................................................................... 8
Criminal or Civil Actions ....................................................................................................................................... 8
A.
Administrative Proceedings .................................................................................................................................. 8
B.
Self-regulatory Organization (SRO) Proceedings .................................................................................................... 8
C.
Item 10: Other Financial Industry Activities and Affiliations ................................................................................................... 8
Registration as a Broker/Dealer or Broker/Dealer Representative .......................................................................... 8
A.
Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor ....... 8
B.
Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests ........................... 8
C.
Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections .................... 9
D.
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................................ 9
Code of Ethics ...................................................................................................................................................... 9
A.
Recommendations Involving Material Financial Interests ....................................................................................... 9
B.
Investing Personal Money in the Same Securities as Clients ................................................................................... 9
C.
Trading Securities At/Around the Same Time as Clients’ Securities ....................................................................... 10
D.
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Item 12: Brokerage Practices .................................................................................................................................................. 10
Factors Used to Select Custodians and/or Broker/Dealers ....................................................................................... 10
A.
Research and Other Soft-Dollar Benefits ............................................................................................................. 10
1.
Brokerage for Client Referrals ............................................................................................................................ 10
2.
Clients Directing Which Broker/Dealer/Custodian to Use .................................................................................... 10
3.
Aggregating (Block) Trading for Multiple Client Accounts ......................................................................................... 11
B.
Item 13: Reviews of Accounts ................................................................................................................................................. 11
Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ............................................................. 11
A.
Factors That Will Trigger a Non-Periodic Review of Client Accounts ........................................................................ 11
B.
Content and Frequency of Regular Reports Provided to Clients ................................................................................ 11
C.
Item 14: Client Referrals and Other Compensation .................................................................................................................. 11
Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) .. 11
A.
Compensation to Non – Advisory Personnel for Client Referrals .............................................................................. 12
B.
Item 15: Custody .................................................................................................................................................................... 12
Item 16: Investment Discretion ............................................................................................................................................... 12
Item 17: Voting Client Securities (Proxy Voting) ....................................................................................................................... 12
Item 18: Financial Information ................................................................................................................................................ 13
Balance Sheet ........................................................................................................................................................ 13
A.
Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ..................... 13
B.
C.
Bankruptcy Petitions in Previous Ten Years ............................................................................................................ 13
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Item 4: Advisory Business
A. Description of the Advisory Firm
Summit Wealth Management LLC (hereinafter “SWM”) is a Limited Liability Company organized in
the State of Ohio.
The firm was formed in July 2003, became licensed as an investment adviser in 2015, and the
principal owner is Richard Andrew Weidrick.
B. Types of Advisory Services
Portfolio Management Services
SWM offers ongoing portfolio management services based on the individual goals, objectives, time
horizon, and risk tolerance of each client. Portfolio management services include, but are not
limited to, the following:
Investment strategy
Asset allocation
Risk tolerance
•
•
•
Personal investment policy
Asset selection
Regular portfolio monitoring
•
•
•
SWM evaluates the current investments of each client with respect to their risk tolerance levels and
time horizon. SWM will request discretionary authority from clients in order to select securities and
execute transactions without permission from the client prior to each transaction. Risk tolerance
levels are documented in the client’s investment files.
is
to seek
fair and equitable allocation of
SWM seeks to provide investment decisions that are made in accordance with the fiduciary duties
owed to its accounts and without consideration of SWM’s economic, investment or other financial
interests. To meet its fiduciary obligations, SWM attempts to avoid, among other things, investment
or trading practices that systematically advantage or disadvantage certain client portfolios, and
investment
accordingly, SWM’s policy
opportunities/transactions among its clients to avoid favoring one client over another over time. It is
SWM’s policy to allocate investment opportunities and transactions it identifies as being appropriate
and prudent among its clients on a fair and equitable basis over time.
Pension Consulting Services
SWM offers ongoing consulting services to pension or other employee benefit plans (including but
not limited to 401(k) plans) based on the demographics, goals, objectives, time horizon, and/or risk
tolerance of the plan’s participants.
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Services Limited to Specific Types of Investments
SWM generally limits its investment advice to mutual funds, fixed income securities, insurance
products including annuities, equity securities and ETFs. SWM may use other securities as well to
help diversify a portfolio when applicable.
C. Client Tailored Services and Client Imposed Restrictions
SWM offers the same suite of services to all of its clients. However, specific client investment
strategies and their implementation are dependent upon the client investment directives (income, tax
levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or
types of securities in accordance with their values or beliefs. However, if the restrictions prevent
SWM from properly servicing the client account, or if the restrictions would require SWM to
deviate from its standard suite of services, SWM reserves the right to end the relationship.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that includes
management fees, transaction costs, fund expenses, and other administrative fees. SWM does not
participate in any wrap fee programs.
Assets Under Management
SWM has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$108,495,417
$11,594,498
12/31/2025
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Item 5: Fees and Compensation
A. Fee Schedule
Asset-Based Fees for Portfolio Management
Total Assets Under Management
Annual Fee
All assets
1.00%
These fees may be negotiable, and the final fee schedule is attached as Exhibit II of the Investment
Advisory Contract. Clients may terminate the agreement without penalty for a full refund of SWM's
fees within five business days of signing the Investment Advisory Contract. Thereafter, clients
may terminate the Investment Advisory Contract generally with 30 days' written notice.
SWM uses the value of the account as of the last business day of the prior billing period, after taking
into account deposits and withdrawals, for purposes of determining the market value of the assets
upon which the advisory fee is based.
Pension Consulting Services Fees
Asset-Based Fees for Pension Consulting
Total Assets Under Management
Annual Fee
All assets
1.00%
These fees may be negotiable, and the final fee schedule is attached as Exhibit II of the Investment
Advisory Contract.
Clients may terminate the agreement without penalty for a full refund of SWM's fees within five
business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the
Investment Advisory Contract generally with 30 days' written notice. SWM bills based on the balance
on the first day of the billing period
SWM uses the value of the account as of the last business day of the prior billing period, after taking
into account deposits and withdrawals, for purposes of determining the market value of the assets
upon which the advisory fee is based.
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B. Payment of Fees
Payment of Asset-Based Portfolio Management Fees
Asset-based portfolio management fees are withdrawn directly from the client's accounts with
client's written authorization on a quarterly basis. Fees are paid in advance for accounts custodied
at Charles Schwab. Fees on 401(k) plans not custodied at Charles Schwab are paid in arrears.
Payment of Asset-Based Pension Consulting Fees
Asset-based pension consulting fees are withdrawn directly from the client's accounts with client's
written authorization on a quarterly basis. Fees are paid in advance.
C. Client Responsibility For Third Party Fees
Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees,
mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and
expenses charged by SWM. Please see Item 12 of this brochure regarding broker-dealer/custodian.
D. Prepayment of Fees
SWM collects certain fees in advance. Refunds for fees paid in advance will be returned within
fourteen days to the client via check or return deposit back into the client’s account.
For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees
collected in advance minus the daily rate* times the number of days elapsed in the billing period up
to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-
based fee rate by 365.)
E. Outside Compensation For the Sale of Securities to Clients
Neither SWM nor its supervised persons accept any compensation for the sale of securities or other
investment products, including asset-based sales charges or service fees from the sale of mutual
funds.
Item 6: Performance-Based Fees and
Side-by-Side Management
SWM does not accept performance-based fees or other fees based on a share of capital gains on or
capital appreciation of the assets of a client.
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Item 7: Types of Clients
SWM generally provides advisory services to the following types of clients:
Individuals
•
• Pension and Profit Sharing Plans
• 401(k) Plans
Minimum Account Size
There is no account minimum for any of SWM’s services.
Item 8: Methods of Analysis, Investment
Strategies, and Risk of Loss
A. Methods of Analysis and Investment Strategies
Methods of Analysis
SWM’s methods of analysis include fundamental analysis.
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages.
Investment Strategies
SWM may use long term trading, options trading (including covered options, uncovered options, or
spreading strategies), alternative investments, and Schwab’s Institutional Intelligent Portfolios.
Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.
B. Material Risks Involved
Methods of Analysis
Fundamental analysis concentrates on factors that determine a company’s value and expected
future earnings. This strategy would normally encourage equity purchases in stocks that are
undervalued or priced below their perceived value. The risk assumed is that the market will fail to
reach expectations of perceived value.
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Investment Strategies
SWM's use of options trading generally holds greater risk, and clients should be aware that there
is a material risk of loss using any of those strategies.
Long term trading is designed to capture market rates of both return and risk. Due to its nature, the
long-term investment strategy can expose clients to various types of risk that will typically surface at
various intervals during the time the client owns the investments. These risks include but are not
limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and
political/regulatory risk.
Options transactions involve a contract to purchase a security at a given price, not necessarily
at market value, depending on the market. This strategy includes the risk that an option may expire
out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of
trading capital due to the leveraged nature of stock options.
Alternative investments include a wide range of investment vehicles that are structured differently
than exchange traded investment funds. They include, but are not limited to, Broker Development
Corporations (BDCs), registered REITs, certain privately offered securities, and certain alternative
strategy registered pools.
Schwab’s Institutional Intelligent Portfolios is an investment platform that utilizes technology to
streamline maintenance of account asset allocation. Clients are invested in index fund-based asset
allocation strategies. Accounts are monitored daily and automatically rebalanced as needed to stay
within defined asset allocation ranges.
Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.
C. Risks of Specific Securities Utilized
Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money
investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can
be of bond “fixed income” nature (lower risk) or stock “equity” nature.
Equity investment generally refers to buying shares of stocks in return for receiving a future
payment of dividends and/or capital gains if the value of the stock increases. The value of equity
securities may fluctuate in response to specific situations for each company, industry conditions
and the general economic environments.
Fixed income investments generally pay a return on a fixed schedule, though the amount of the
payments can vary. This type of investment can include corporate and government debt securities,
leveraged loans, high yield, and investment grade debt and structured products, such as mortgage
and other asset-backed securities, although individual bonds may be the best-known type of fixed
income security. In general, the fixed income market is volatile and fixed income securities carry
interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually
more pronounced for longer-term securities.) Fixed income securities also carry inflation risk,
liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of
default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury
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defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit
rather minimal. Risks of investing in foreign fixed income securities also include the general risk of
non-U.S. investing described below.
Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to
stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of
a stock holding bankruptcy). Areas of concern include the lack of transparency in products and
increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance.
Annuities are a retirement product for those who may have the ability to pay a premium now and
want to guarantee they receive certain monthly payments or a return on investment later in the
future. Annuities are contracts issued by a life insurance company designed to meet requirement or
other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be
long-term investments, to meet retirement and other long-range goals. Variable annuities are not
suitable for meeting short-term goals because substantial taxes and insurance company charges may
apply if you withdraw your money early. Variable annuities also involve investment risks, just as
mutual funds do.
Options are contracts to purchase a security at a given price, risking that an option may expire out
of the money resulting in minimal or no value. An uncovered option is a type of options contract that
is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or
uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless.
Spread option positions entail buying and selling multiple options on the same underlying security,
but with different strike prices or expiration dates, which helps limit the risk of other option
trading strategies. Option transactions also involve risks including but not limited to economic
risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing
power) risk and interest rate risk.
SWM may engage in options trading for a select number of qualified clients. If an option transaction
occurs, additional documentation will be required by the custodian for options transactions and
margin accounting.
Alternative Investments include a wide range of investments that carry certain risks. Due to these
risks, alternative investments may only be utilized by certain accredited investors who meet stringent
financial requirements. Alternative investments may be illiquid. They may utilize complex index
strategies. Alternative investments may respond to changes in market conditions in unexpected
manners. They may not be registered and/or monitored by any regulatory authority.
SWM may engage in alternative investments for a select number of qualified clients. If alternative
investments are selected for investment, additional documentation may be required by the
custodian.
Schwab Institutional Intelligent Portfolios is an investing option that utilizes technology to monitor
and maintain asset allocation in an index fund-based strategy. Client assets are invested in one of
several investment strategies prepared by SWM. The client’s selected strategy is based on several
factors including risk tolerance, age, and investment experience.
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Past performance is not indicative of future results. Investing in securities involves a risk of
loss that you, as a client, should be prepared to bear.
Item 9: Disciplinary Information
A. Criminal or Civil Actions
There are no criminal or civil actions to report.
B. Administrative Proceedings
There are no administrative proceedings to report.
C. Self-regulatory Organization (SRO) Proceedings
There are no self-regulatory organization proceedings to report.
Item 10: Other Financial Industry Activities and Affiliations
A. Registration as a Broker/Dealer or Broker/Dealer Representative
Neither SWM nor its representatives are registered as, or have pending applications to become, a
broker/dealer or a representative of a broker/dealer.
B. Registration as a Futures Commission Merchant, Commodity
Pool Operator, or a Commodity Trading Advisor
Neither SWM nor its representatives are registered as or have pending applications to become
either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor
or an associated person of the foregoing entities.
C. Registration Relationships Material to this Advisory Business
and Possible Conflicts of Interests
Richard Andrew Weidrick, CPA is an accountant and owner of Weidrick Livesay & Co. From time to
time, he will offer clients advice or products from this activity. SWM always acts in the best interest
of the client. Clients are in no way required to utilize the services of any representative of SWM in
their capacity as an accountant.
Richard Andrew Weidrick, CPA is 50% owner of WLM Properties, LLC and 50% owner of 47 MFA,
LLC. The entities collect rent from the accounting firm, Weidrick Livesay & Co. SWM always acts in
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the best interest of the client and clients are not offered services of any representative of SWM in
connection with such individual’s activities outside of SWM.
to purchase any
Other personnel are agents for various insurance companies and are able to receive separate, yet
customary commission compensation resulting from product transactions on behalf of advisory
clients. Clients are not under any obligation to engage these individuals when considering
implementation of advisory recommendation, or
insurance products.
Implementation of any or all recommendation is solely at the discretion of the client.
D. Selection of Other Advisers or Managers and How This Adviser is
Compensated for Those Selections
SWM does not utilize nor select third-party investment advisers. All assets are managed by SWM
management.
Item 11: Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading
A. Code of Ethics
SWM has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales,
Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities,
Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors,
Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting,
Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and
Education, Recordkeeping, Annual Review, and Sanctions. SWM's Code of Ethics is available free
upon request to any client or prospective client.
B. Recommendations Involving Material Financial Interests
SWM does not recommend that clients buy or sell any security in which a related person to SWM or
SWM has a material financial interest.
C. Investing Personal Money in the Same Securities as Clients
From time to time, representatives of SWM may buy or sell securities for themselves that they also
recommend to clients. SWM will never engage in trading that operates to the client’s disadvantage
when similar securities are being bought or sold.
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D. Trading Securities At/Around the Same Time as Clients’ Securities
From time to time, representatives of SWM may buy or sell securities for themselves at or around the
same time as clients. SWM will never engage in trading that operates to the client’s disadvantage if
representatives of SWM buy or sell securities at or around the same time as clients.
Item 12: Brokerage Practices
A. Factors Used to Select Custodians and/or Broker/Dealers
Custodians/broker-dealers will be selected based on SWM’s duty to seek “best execution,” which
is the obligation to seek execution of securities transactions for a client on the most favorable terms
for the client under the circumstances. Clients will not necessarily pay the lowest commission
or commission equivalent, and SWM may also consider the market expertise and research access
provided by the broker- dealer/custodian, including but not limited to access to written research,
oral communication with analysts, admittance to research conferences and other resources
provided by the brokers that may aid in SWM's research efforts. SWM will never charge a premium
or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian.
SWM brokerage clients will use Schwab Institutional, a division of Charles Schwab & Co., Inc.
Mutual Funds Share Class Selection: When recommending investments in mutual funds, it is the
Firm’s policy to review and consider available share classes. The Firm’s policy is to select the most
appropriate share classes based on various factors including but not limited to: minimum investment
requirements, trading restrictions, internal expense structure, transaction charges, availability and
other factors. When considering all the appropriate factors the Firm may select a share class other
than the ‘lowest cost’ share class. In order to select the most appropriate share class, the Firm may
select retail, institutional or other structured shares of the same mutual fund. Clients may be able to
obtain lower cost share classes than those selected by the Firm. SWM periodically reviews the
mutual funds held in client accounts to select the most appropriate share classes in light of its duty
to obtain best execution.
1. Research and Other Soft-Dollar Benefits
While SWM has no formal soft dollars program in which soft dollars are used to pay for third
party services, SWM may receive research, products, or other services from custodians and
broker-dealers in connection with client securities transactions (“soft dollar benefits”).
2. Brokerage for Client Referrals
SWM receives no referrals from a broker-dealer or third party in exchange for using that
broker-dealer or third party.
3. Clients Directing Which Broker/Dealer/Custodian to Use
SWM may permit clients to direct it to execute transactions through a specified broker-dealer.
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Clients must refer to their advisory agreements for a complete understanding of how they
may be permitted to direct brokerage. If a client directs brokerage, the client will be required
to acknowledge in writing that the client’s direction with respect to the use of brokers
supersedes any authority granted to SWM to select brokers; this direction may result in higher
commissions, which may result in a disparity between free and directed accounts; and
trades for the client and other directed accounts may be executed after trades for free
accounts, which may result in less favorable prices, particularly for illiquid securities or
during volatile market conditions. Not all investment advisers allow their clients to direct
brokerage.
B. Aggregating (Block) Trading for Multiple Client Accounts
SWM maintains the ability to block trade purchases across accounts that are custodied at the same
custodian.
Item 13: Reviews of Accounts
A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews
All client accounts for SWM's advisory services provided on an ongoing basis are reviewed at least
annually by Richard A Weidrick, CCO, with regard to clients’ respective investment policies and risk
tolerance levels.
B. Factors That Will Trigger a Non-Periodic Review of Client Accounts
Reviews may be triggered by material market, economic or political events, or by changes in client's
financial situations (such as retirement, termination of employment, physical move, or inheritance).
C. Content and Frequency of Regular Reports Provided to Clients
Each client of SWM's will receive a report n o l e s s t h a n q u a r t e r l y detailing the client’s
account, including assets held, asset value, and recent transactions. This written report will come
from the custodian.
Item 14: Client Referrals and Other Compensation
A. Economic Benefits Provided by Third Parties for Advice
Rendered to Clients (Includes Sales Awards or Other Prizes)
SWM does not receive any economic benefit, directly or indirectly from any third party for advice
rendered to SWM's clients.
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B. Compensation to Non – Advisory Personnel for Client Referrals
SWM does not directly or indirectly compensate any person who is not advisory personnel for client
referrals.
Item 15: Custody
Custody, as it applies to investment advisers, has been defined as having access or control over client
funds and/or securities, but does not include the ability to execute transactions in client
accounts. Custody is not limited to physically holding client funds and securities. If an investment
advisor can access or control client funds or securities, the investment advisor is deemed to have
custody for purposes of the Investment Advisers Act of 1940 and must ensure proper procedures are
implemented.
SWM does not act as custodian of any Client account and does not have physical possession of any
Client’s funds or securities. Clients engage qualified custodians directly to maintain custody of their
funds and securities. In many instances, our Clients utilize Schwab for custody and brokerage
services.
SWM has been deemed to have custody of certain Clients’ assets by virtue of having been granted the
authority to periodically deduct the agreed investment advisory fees directly from the Client’s
account and to pay the fees to SWM. SWM has also been deemed to have custody of certain Clients’
assets by being granted authority to instruct the Client’s custodian to disburse assets to third parties
under standing letter of authorizations (“SLOAs”). We have developed policies and procedures to
monitor the use of SLOAs, structuring them according to the guidance provided by the SEC.
Item 16: Investment Discretion
SWM provides discretionary investment advisory services to clients. The Investment Advisory
Contract established with each client sets forth the discretionary authority for trading. Where
investment discretion has been granted, SWM generally manages the client’s account and makes
investment decisions without consultation with the client as to when the securities are to be
bought or sold for the account, the total amount of the securities to be bought/sold, what securities
to buy or sell, or the price per share.
Item 17: Voting Client Securities (Proxy Voting)
SWM will not ask for, nor accept voting authority for client securities. Clients will receive proxies
directly from the issuer of the security or the custodian. Clients should direct all proxy questions to
the issuer of the security.
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Item 18: Financial Information
A. Balance Sheet
SWM neither requires nor solicits prepayment of more than $1,200 in fees per client, six months
or more in advance, and therefore is not required to include a balance sheet with this brochure.
B. Financial Conditions Reasonably Likely to Impair Ability to Meet
Contractual Commitments to Clients
Neither SWM nor its management has any financial condition that is likely to reasonably impair
SWM’s ability to meet contractual commitments to clients.
C. Bankruptcy Petitions in Previous Ten Years
SWM has not been the subject of a bankruptcy petition in the last ten years.
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