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Form ADV Part 2A
Firm Brochure
Unique Wealth Strategies, LLC.
570 Village Center Drive, Suite: 203
Burr Ridge, IL, 60527
(630) 318-0565
www.uniquewealthstrategies.com
August 25, 2025
Item 1 – Cover Page
This Brochure provides information about the qualifications and business practices of Unique
Wealth Strategies, LLC. If you have any questions about the contents of this Brochure, please
contact us using the information listed above. The information in this Brochure has not been
approved or verified by the United States Securities and Exchange Commission (“SEC”) or by
any state securities authority.
Unique Wealth Strategies, LLC (CRD# 323994) is a registered investment advisor with the SEC.
Registration of an investment advisor does not imply a certain level of skill or training.
Additional information about Unique Wealth Strategies, LLC is also available on the SEC’s
website at www.adviserinfo.sec.gov.
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Item 2 – Material Changes
Since the last annual filing of this document in January 2024, the following material changes
have occurred:
• UWS can now offer alternative investments to its clients. Alternative Investments or
Strategies - Some clients may wish to purchase alternative investments or investment
strategies that are not provided by UWS. We can, however, offer these through other
unaffiliated asset managers. Important details are included under Item 4, Advisory Business.
• UWS now has an individual that is affiliated with a broker-dealer as well as with UWS as an
investment adviser. Details are provided under Broker-Dealer Affiliations in Item 5, Fees and
Compensation and Item 10. Other Financial Industry Activities and Affiliations. There are
conflicts of interest with this arrangement that you should be aware of.
• We have updated this brochure to: (i) disclose our affiliation with Unique Multi Family Office,
LLC in Items 4 and 10; (ii) clarify in Item 5 that fees charged by UWS apply only to advisory
services and are separate from any fees charged by UMFO for non-advisory services; and
(iii) added conflict of interest disclosure in Items 4, 10, and 14 related to our common
ownership with UMFO.
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Item 3 – Table of Contents
Item 2 – Material Changes ........................................................................................................... 2
Item 1 – Cover Page 1
Item 3 – Table of Contents ........................................................................................................... 3
Item 4 – Advisory Business .......................................................................................................... 4
Item 5 – Fees and Compensation ................................................................................................. 8
Item 6 - Performance-Based Fees and Side-By-Side Management ............................................ 11
Item 7 – Types of Clients & Account Minimums .......................................................................... 11
Item 8 – Methods of Analysis, Investment Strategies, Investment Tools, and Risk of Loss ........... 11
Item 9 – Disciplinary Information................................................................................................. 16
Item 10 – Other Financial Industry Activities and Affiliations ....................................................... 16
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 17
Item 12 – Brokerage Practices ................................................................................................... 18
Item 13 – Review of Accounts .................................................................................................... 20
Item 14 – Client Referrals and Other Compensation ................................................................... 20
Item 15 – Custody ...................................................................................................................... 21
Item 16 – Investment Discretion ................................................................................................. 22
Item 17 – Voting Client Securities ............................................................................................... 22
Item 18 – Financial Information .................................................................................................. 22
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Item 4 – Advisory Business
Unique Wealth Strategies, LLC (“UWS”), was formed in May 2016, and based in Burr Ridge,
Illinois and has been providing investment advisory services since its inception. UWS’ principal
owner is Ranjit Rahadur.
UWS is under common ownership with Unique Multi Family Office, LLC (“UMFO”), a separate
legal entity. UMFO offers a suite of non-advisory services that are commonly associated with
multi-family office platforms, such as accounting and tax coordination, estate planning support,
family governance, business advisory, and lifestyle management services. These non-advisory
services are provided by UMFO directly or through third-party providers and are independent of
UWS.
To the extent that UMFO clients receive investment advisory services, those services are
provided exclusively through UWS under a separate advisory agreement. Clients of UMFO are
not required to engage UWS for investment advisory services, and UWS clients are not obligated
to engage UMFO for non-advisory services.
Because UWS and UMFO are under common ownership, there is a potential conflict of interest
when clients engage both entities. This affiliated relationship may create an incentive to
recommend services of the affiliate. UWS addresses this conflict by maintaining separate
agreements for advisory and non-advisory services, by disclosing the affiliate relationship, and by
reminding clients that they are free to select any service provider of their choice.
ASSET MANAGEMENT
UWS offers asset management services to advisory Clients. UWS will offer Clients ongoing asset
management services through determining individual investment goals, time horizons, objectives,
and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio
monitoring and the overall investment program will be based on the above factors.
All Asset Management services are offered through the Unique Wealth Strategies Wrap Program.
See Unique Wealth Strategies ADV 2A: Wrap Appendix/Brochure for details on the Unique
Wealth Strategies Wrap Program.
ERISA PLAN SERVICES
UWS offers service to qualified and non-qualified retirement plans including 401(k) plans, 403(b)
plans, pension and profit-sharing plans, cash balance plans, and deferred compensation plans.
UWS may act as a 3(21) or 3(38) advisor:
Limited Scope ERISA 3(21) Fiduciary. UWS acts as a limited-scope ERISA 3(21) fiduciary
that can advise, help, and assist plan sponsors with their investment decisions. As an
investment advisor UWS has a fiduciary duty to act in the best interest of the Client. The plan
sponsor is still ultimately responsible for the decisions made in their plan, though using UWS
can help the plan sponsor delegate liability by following a diligent process.
1. Fiduciary Services:
• Provide investment advice to the Client about asset classes and investment
alternatives available for the Plan in accordance with the Plan’s investment policies
and objectives. Clients will make the final decision regarding the initial selection,
retention, removal, and addition of investment options. UWS acknowledges that it
is a fiduciary as defined in ERISA section 3 (21) (A) (ii).
• Assist the Client in the development of an investment policy statement (“IPS”). The
IPS establishes the investment policies and objectives for the Plan. Client shall
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have the ultimate responsibility and authority to establish such policies and
objectives and to adopt and amend the IPS.
• Provide investment advice to the Plan Sponsor with respect to the selection of a
qualified default investment alternative for participants who are automatically
enrolled in the Plan or who have otherwise failed to make investment elections.
The Client retains the sole responsibility to provide all notices to the Plan
participants required under ERISA Section 404© (5) and 404(a)-5.
• Assist in monitoring investment options by preparing periodic investment reports
that document investment performance, consistency of fund management and
conformance to the guidelines set forth in the IPS and make recommendations to
maintain, remove or replace investment options.
• Meet with the Client on a periodic basis to discuss the reports and the investment
recommendations.
2. Non-fiduciary Services:
• Assist in the education of Plan participants with general investment information
and the investment alternatives available to them under the Plan. Client
understands UWS’s assistance in education of the Plan participants shall be
consistent with and within the scope of the Department of Labor’s definition of
investment education (Department of Labor Interpretive Bulletin 96-1). As such,
UWS is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan
participants. UWS will not provide investment advice concerning the prudence of
any investment option or combination of investment options for a particular
participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding by
the employees.
UWS may provide these services or, alternatively, may arrange for the Plan’s other
providers to offer these services, as agreed upon between UWS and Client.
3. UWS has no responsibility to provide services related to the following types of assets
(“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and
similar vehicles); or
• Other hard-to-value or illiquid securities or property.
Excluded Assets will not be included in the calculation of Fees paid to UWS on the ERISA
Agreement. Specific services will be outlined in detail to each plan in the 408(b)2
disclosure.
3(38) Investment Manager. UWS acts as an ERISA 3(38) Investment Manager in which it
has discretionary management and control of a given retirement plan’s assets. UWS would
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then become solely responsible and liable for the selection, monitoring and replacement of
the plan’s investment options.
1. Fiduciary Services:
• Advisor has discretionary authority and will make the final decision regarding the
initial selection, retention, removal and addition of investment options in
accordance with the Plan’s investment policies and objectives.
• Assist the Plan Sponsor with the selection of a broad range of investment options
consistent with ERISA Section 404(c) and the regulations thereunder.
• Assist the Plan Sponsor in the development of an investment policy statement.
The IPS establishes the investment policies and objectives for the Plan.
• Provide discretionary investment advice to the Plan Sponsor with respect to the
selection of a qualified default investment alternative for participants who are
automatically enrolled in the Plan or who have otherwise failed to make investment
elections. The Plan Sponsor retains the sole responsibility to provide all notices to
the Plan participants required under ERISA Section 404(c) (5).
• Assist in monitoring investment options by preparing periodic investment reports
that document investment performance, consistency of fund management and
conformance to the guidelines set forth in the IPS and make recommendations to
maintain, remove or replace investment options.
• Meet with Plan Sponsor on a periodic basis to discuss the reports and the
investment recommendations.
2. Non-fiduciary Services:
• Assist in the education of Plan participants with general investment information
and the investment alternatives available to them under the Plan. The Advisor’s
assistance in education of the Plan participants shall be consistent with and within
the scope of the Department of Labor’s definition of investment education
(Department of Labor Interpretive Bulletin 96-1). As such, the Advisor is not
providing fiduciary advice as defined by ERISA to the Plan participants. Advisor
will not provide investment advice concerning the prudence of any investment
option or combination of investment options for a particular participant or
beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding by
the employees.
UWS may provide these services or, alternatively, may arrange for the Plan’s other
providers to offer these services, as agreed upon between Advisor and Plan Sponsor.
3. UWS has no responsibility to provide services related to the following types of assets
(“Excluded Assets”):
a.
Employer securities;
b. Real estate (except for real estate funds or publicly traded REITs);
c.
Stock brokerage accounts or mutual fund windows;
d.
Participant loans;
e. Non-publicly traded partnership interests;
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f.
Other non-publicly traded securities or property (other than collective trusts
and similar vehicles); or
g. Other hard-to-value or illiquid securities or property.
FINANCIAL PLANNING AND CONSULTING
Financial planning services include an evaluation of a Client's current and future financial state
and will be provided by using currently known variables to predict future cash flows, asset values
and withdrawal plans. UWS will use current net worth, tax liabilities, asset allocation, and future
retirement and estate plans in developing financial plans. Topics generally reviewed in a financial
plan may include but are not limited to:
• Financial goals: Based on an individual's or a family's clearly defined financial goals,
including funding a college education for the children, buying a larger home, starting a
business, retiring on time, or leaving a legacy. Financial goals should be quantified
and set to milestones for tracking.
• Personal net worth statement: A snapshot of assets and liabilities serves as a
benchmark for measuring progress towards financial goals.
• Cash flow analysis: An income and spending plan determines how much can be set
aside for debt repayment, savings and investing each month.
• Retirement strategy: A strategy for achieving retirement independent of other
financial priorities. Including a strategy for accumulating the required retirement capital
and its planned lifetime distribution.
• Comprehensive risk management plan: Identify all risk exposures and provide the
necessary coverage to protect the family and its assets against financial loss. The risk
management plan includes a full review of life and disability insurance, personal
liability coverage, property and casualty coverage, and catastrophic coverage.
• Long-term investment plan: Include a customized asset allocation strategy based
on specific investment objectives and a risk profile. This investment plan sets
guidelines for selecting, buying, and selling investments and establishing benchmarks
for performance review.
• Tax reduction strategy: Identify ways to minimize taxes on personal income to the
extent permissible by the tax code. The strategy should include identification of tax
favored investment vehicles that can reduce taxation of investment income.
• Estate preservation: Help update accounts, review beneficiaries for retirement
accounts and life insurance, provide a second look at your current estate planning
documents, and prompt you to update your plan when the legal environment changes
or you have major life events such as a marriage, death, or births.
If a conflict of interest exists between the interests of UWS and the interests of the Client, the
Client is under no obligation to act upon UWS’s recommendation. If the Client elects to act on any
of the recommendations, the Client is under no obligation to affect the transaction through UWS.
Financial plans will be completed and delivered within ninety (90) days contingent upon timely
delivery of all required documentation.
The goals and objectives for each Client are documented in our Client files. Investment strategies
are created that reflect the stated goals and objectives. Clients may impose restrictions on
investing in certain securities or types of securities. These restrictions may, however, prohibit
engagement with UWS.
Alternative Investments or Strategies
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Some clients may wish to purchase alternative investments or investment strategies that are not
provided by UWS. We can, however, offer these through other unaffiliated asset managers.
For these investment products and/or strategies, UWS recommends firms such as Goldman Sachs
or Blackstone, among others. UWS does not share in the fees charged by the unaffiliated asset
managers although UWS will help facilitate the account opening and initial transaction. UWS will
monitor the assets held at the unaffiliated asset manager(s) and will disclose these on your
quarterly statements provided by UWS. You will pay UWS our advisory management fee (as
outlined in your advisory agreement with UWS) on a quarterly basis (in advance, based on the
quarter ending value of the previous quarter). These fees will be deducted from one of your
custodial accounts typically held at Schwab or Axos.
Please refer to UWS’s ADV Part 2A - Wrap Appendix for additional information.
As of 12/31/2023, UWS had an approximate total of $312,500,000 of assets under management,
of which $307,500,000 were managed on a discretionary basis and $5,000,000 on a non-
discretionary basis. UWS also advised on Retirement Plan assets, considered as assets under
advisement, of approximately $12,000.000.
Item 5 – Fees and Compensation
ASSET MANAGEMENT
UWS offers asset management services under the UWS Wrap Fee Program. Please see the
UWS Wrap Fee Program Brochure for details.
WRAP FEE PROGRAM:
• The benefits under a wrap fee program depend, in part, upon the size of the account, the
costs associated with managing the account, and the frequency or type of securities
transactions executed in the account.
• For example, a wrap fee program may not be suitable for all accounts, including but not
limited to accounts holding primarily, and for any substantial period of time, cash or cash
equivalent investments, fixed income securities or no-transaction-fee mutual funds, or any
other type of security that can be traded without commissions or other transaction fees.
•
In order to evaluate whether a wrap (or bundled) fee arrangement is appropriate for you,
you should compare the agreed-upon Wrap Program Fee and any other costs associated
with participating in our Wrap Fee Program with the amounts that would be charged by
other advisers, broker-dealers, and custodians, for advisory fees, brokerage and
execution costs, and custodial services comparable to those provided under the Wrap Fee
Program.
Conflict of Interest. When managing a client's account on a wrap fee basis, we receive as
compensation for our investment advisory services, the balance of the total wrap fee you pay after
custodial, trading, and other management costs (including execution and transaction fees) have
been deducted. Accordingly, we have a conflict of interest because we have a financial incentive
to maximize our compensation by seeking to reduce or minimize the total costs incurred in your
account(s) subject to a wrap fee.
• For example, our wrap fee arrangement creates incentives for our advisors to trade less
frequently or select investments that reduce our costs, and in some cases increase
expenses that are borne by the client.
UWS uses two primary custodians, Axos Clearing, LLC, (“Axos”) and Charles Schwab & Co., Inc.
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(“Schwab”). Investment management fees of UWS are charged equally regardless of which
custodian is used. Other fees charged by each custodian are either equal or not materially
different from one another.
Schwab, Axos, and other custodians have eliminated transaction fees for online trades of U.S.
equities, ETFs, and options (subject to $0.65 per contract fee). This means that, in most cases,
when we buy and sell these types of securities, we will not have to pay any commissions to
Schwab or Axos. We encourage you to review Schwab’s pricing to compare the total costs of
entering into a wrap fee arrangement versus a non-wrap fee arrangement. If you choose to enter
into a wrap fee arrangement, your total cost to invest could exceed the cost of paying for
brokerage or advisory services separately. To see what you pay for transactions in a non-wrap
account, please refer to Schwab’s most recent pricing schedules.
We are available to discuss execution-related pricing with you so that you can compare the total
costs of entering into a wrap fee arrangement versus a non-wrap fee arrangement. If you choose
to enter into a wrap fee arrangement, your total cost to invest could exceed the cost of paying for
brokerage and advisory services separately.
ERISA PLAN SERVICES
The annual fees are based on the market value of the Included Assets and shall not exceed 1%.
Fees may be charged quarterly or monthly in arrears or in advance based on the assets as
calculated by the custodian or record keeper of the Included Assets (without adjustments for
anticipated withdrawals by Plan participants or other anticipated or scheduled transfers or
distribution of assets) on the last business day of the previous quarter.
The fee schedule, which includes compensation of UWS for the services is described in detail in
the ERISA Plan Agreement. The Plan is obligated to pay the fees; however, the Plan Sponsor
may elect to pay the fees. Clients may elect to be billed directly or have fees deducted from Plan
Assets. UWS does not reasonably expect to receive any additional compensation, directly or
indirectly, for its services. If additional compensation is received, UWS will disclose this
compensation, the services rendered, and the payer of the compensation.
FINANCIAL PLANNING AND CONSULTING
UWS charges fixed and ongoing fees for financial planning and consulting. Prior to the planning
process the Client will be provided an estimated plan fee which will be based on the complexity
of the engagement. Services will be completed and delivered within ninety (90) days contingent
upon timely delivery of all required documentation. UWS reserves the right to waive the fee should
the Client implement the plan through UWS.
FIXED FEES
Fixed Fee Services are offered based on a range of $100 - $15,000 depending on the
complexity of the engagement. Fees are billed 50% in advance with the balance due upon
plan delivery.
ONGOING FEES
Ongoing Fee Services are offered based on an annual fee, charged quarterly depending
on the Client’s election. Fees are billed in advance of each billing period. Ongoing Fee
Services will continue year over year until canceled, in writing, by either UWS or the Client.
The annual fee may be negotiable based upon certain criteria (e.g., historical relationship, type of
assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of
assets to be managed, related accounts, account composition, negotiations with Clients, etc.).
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Accounts within the same household may be combined for a reduced fee.
ERISA and Financial Planning Fees are generally invoiced directly to the Client but may also be
deducted from another account held with UWS.
UWS, in its sole discretion, may charge a lesser investment advisory fee based upon certain
criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated
future additional assets, dollar amounts of assets to be managed, related accounts, account
composition, negotiations with Clients, etc.).
For all services, Clients may terminate their engagement with UWS within five (5) business days
of signing an Agreement with no obligation and without penalty. After the initial (5) business days,
the Agreement may be terminated by UWS with thirty (30) days written notice to Client and by the
Client at any time with written notice to UWS. For accounts opened or closed mid-billing period,
fees will be prorated based on the days services are provided during the given period. In the case
of hourly engagements, fees will be prorated based on the work completed at the stated hourly
rate. All unpaid earned fees will be due to UWS, and all unearned fees will be refunded to the
Client. Any increase in fees will be acknowledged in writing by both parties before any increase
in said fees occurs.
Custodians may charge brokerage commissions, transaction fees, and other related costs on the
purchases or sales of mutual funds, equities, bonds, options, margin interest, and exchange-
traded funds. Mutual funds, money market funds, and exchange-traded funds may also charge
internal management fees, which are disclosed in the fund’s prospectus. UWS does not receive
any compensation from these fees. All of these fees are in addition to the management fee you
pay to UWS. For more details on the brokerage practices, see Item 12 of this brochure.
UNIQUE MULTI FAMILY OFFICE, LLC
Fees charged by UWS apply only to the investment advisory and financial planning services
provided by UWS. These fees do not include, and are separate from, any fees charged by our
affiliate, Unique Multi-Family Office, LLC (“UMFO”).
UMFO offers non-advisory services such as accounting and tax coordination, estate planning
support, family governance, business advisory, and lifestyle management. These services are
subject to separate agreements between the client and UMFO, and UMFO establishes and
charges its own fees for those services.
Clients are under no obligation to engage UMFO for any non-advisory services. If a client elects
to use UMFO, the fees for UMFO’s services will be in addition to the advisory fees paid to UWS.
Clients should carefully review UMFO’s separate agreements and fee schedules before engaging
UMFO.
BROKER-DEALER AFFILIATION
UWS allows individuals registered as investment adviser representatives with it, to also be
registered representatives with a broker-dealer. Although this in itself is a conflict of interest, it
also allows our clients to invest in securities they may not be able to access through UWS. The
individuals that are registered representatives (referred to as an IAR/RR), with the broker-dealer
must adhere to FINRA rules and regulations and the policies of the broker-dealer as well as the
policies of UWS. Additional details are provided under Item 10, Other Financial Industry Activities
and Affiliations and Item 14, Client Referrals and Other Compensation.
UWS does not receive any external compensation from the sale of securities.
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Item 6 - Performance-Based Fees and Side-By-Side Management
Fees are not based on a share of the capital gains or capital appreciation of managed securities.
UWS does not use a performance-based fee structure nor “side-by-side” management because
of the conflict of interest. Performance-based compensation may create an incentive for UWS to
recommend an investment that may carry a higher degree of risk to the Client.
Item 7 – Types of Clients & Account Minimums
UWS’s Clients are generally individuals, small businesses, trusts, estates, high net-worth
individuals, and charities. Client relationships vary in scope and length of service.
There is no minimum account size and Clients are not required to have a certain amount of
investment experience or sophistication.
Item 8 – Methods of Analysis, Investment Strategies, Investment Tools, and Risk of
Loss
Methods of Analysis and Investment Strategies
Investing in securities involves risk of loss that Clients should be prepared to bear. Past
performance is not a guarantee of future returns. Security analysis methods may include:
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.
Technical analysis attempts to predict a future stock price or direction based on market trends.
The assumption is that the market follows discernible patterns and if these patterns can be
identified then a prediction can be made. The risk is that markets do not always follow patterns
and relying solely on this method may not take into account new patterns that emerge over time.
Charting analysis strategy involves using and comparing various charts to predict long and short-
term performance or market trends. The risk involved in using this method is that only past
performance data is considered without using other methods to crosscheck data. Using charting
analysis without other methods of analysis would be making the assumption that past
performance will be indicative of future performance. This may not be the case.
Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can
be leveraged to provide performance. The risks with this strategy are twofold: 1) the markets do
not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy,
then it changes the very cycles these investors are trying to exploit.
factors as distinguished
Quantitative analysis deals with measurable
from qualitative
considerations such as the character of management or the state of employee morale, such as
the value of assets, the cost of capital, historical projections of sales, and so on.
Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected
return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected
return, each by carefully choosing the proportions of various assets.
In developing a financial plan for a Client, UWS’s analysis may include cash flow analysis,
investment planning, risk management, tax planning and estate planning. Based on the
information gathered, a detailed strategy is tailored to the Client’s specific situation.
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The main sources of information include financial newspapers and magazines, annual reports,
prospectuses, and filings with the SEC.
Investment Strategy
The investment strategy for a specific Client is based upon the objectives stated by the Client
during consultations. The Client may change these objectives at any time by providing written
notice to UWS. Each Client executes a Client profile form or similar form that documents their
objectives and their desired investment strategy.
Risks of Investments and Strategies Utilized
Investing in securities involves risk of loss that Clients should be prepared to bear. UWS’s
investment approach constantly keeps the risk of loss in mind. Investors may face the
following investment risks:
General Investment and Trading Risks. Clients may invest in securities and other financial
instruments using strategies and investment techniques with significant risk characteristics. The
investment program utilizes such investment techniques as option transactions, margin
transactions, short sales, leverage, and derivatives trading, the use of which can, in certain
circumstances, maximize the adverse impact to which a Client may be subject.
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 value to decline.
Inflation Risk. When any type of inflation is present, a dollar today will buy more than a dollar
next year, because purchasing power is eroding at the rate of inflation.
Currency Risk. Overseas investments are subject to fluctuations in the value of the dollar against
the currency of the investment’s originating country. This is also referred to as exchange rate risk.
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.
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.
Management Risk. The advisor’s investment approach may fail to produce the intended results.
If the advisor’s assumptions regarding the performance of a specific asset class or fund are not
realized in the expected time frame, the overall performance of the Client’s portfolio may suffer.
Cybersecurity Risk. UWS and its service providers may be subject to operational and
information security risks resulting from cyberattacks. Cyberattacks include, among other
behaviors, stealing or corrupting data maintained online or digitally, denial of service attacks on
websites, the unauthorized release of confidential information or various other forms of
cybersecurity breaches. Cybersecurity attacks affecting UWS, and its service providers may
adversely impact Clients. For instance, cyberattacks may interfere with the processing of
transactions, cause the release of private information about Clients, impede trading, subject UWS
to regulatory fines or financial losses, and cause reputational damage. Similar types of
cybersecurity risks are also present for issuers of securities in which Clients may invest in,
qualified custodians, governmental and other regulatory authorities, exchange and other financial
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market operators, or other financial institutions. Cybersecurity incidents that could ultimately
cause them to incur losses, including for example: financial losses, cost and reputational damage,
and loss from damage or interruption of systems. Although UWS has established its systems to
reduce the risk of these incidents from coming to fruition, there is no guarantee that these efforts
will always be successful, especially considering that UWS does not directly control the
cybersecurity measures and policies employed by third party service providers.
Options Trading. The risks involved with trading options are that they are very time-sensitive
investments. An options contract is generally for a few months. The buyer of an option could lose
his or her entire investment even with a correct prediction about the direction and magnitude of a
particular price change if the price change does not occur in the relevant time period (i.e., before
the option expires). Additionally, options are less tangible than some other investments. An option
is a “book-entry” only investment without a paper certificate of ownership.
Trading on Margin. In a cash account, the risk is limited to the amount of money that has been
invested. In a margin account, risk includes the amount of money invested plus the amount that
has been loaned. As market conditions fluctuate, the value of marginable securities will also
fluctuate, causing a change in the overall account balance and debt ratio. As a result, if the value
of the securities held in a margin account depreciates, the Client will be required to deposit
additional cash or make full payment of the margin loan to bring the account back up to
maintenance levels. Clients who cannot comply with such a margin call may be sold out or bought
in by the brokerage firm.
Exchange-Traded Funds. ETFs are a type of index fund bought and sold on a securities
exchange. The risks of owning an ETF generally reflect the risks of owning the underlying
securities they are designed to track, although lack of liquidity in an ETF could result in it being
more volatile and ETFs have management fees that increase their costs. ETFs are also subject
to other risks, including: (i) the risk that their prices may not correlate perfectly with changes in
the underlying reference units; and (ii) the risk of possible trading halts due to market conditions
or other reasons that, in view of the exchange upon which an ETF trades, would make trading in
the ETF inadvisable.
Mutual Fund Risks. An investment in mutual funds could lose money over short or even long
periods. A mutual fund’s share price and total return are expected to fluctuate within a wide range,
like the fluctuations of the overall stock market.
Common Stocks and Equity-Related Securities. Certain ETFs or mutual funds hold common
stock. Prices of common stock react to the economic condition of the company that issued the
security, industry and market conditions, and other factors which may fluctuate widely.
Investments related to the value of stocks may rise and fall based on an issuer’s actual and
anticipated earnings, changes in management, the potential for takeovers and acquisitions, and
other economic factors. Similarly, the value of other equity-related securities, including preferred
stock, warrants, and options may also vary widely.
Small- and Mid-Cap Risks. Certain ETFs and mutual funds hold securities of small- and mid-
cap issuers. Securities of small-cap issuers may present greater risks than those of large-cap
issuers. For example, some small- and mid-cap issuers often have limited product lines, markets,
or financial resources. They may be subject to high volatility in revenues, expenses, and earnings.
Their securities may be thinly traded, may be followed by fewer investment research analysts,
and may be subject to wider price swings and thus may create a greater chance of loss than when
investing in securities of larger-cap issuers. The market prices of securities of small- and mid-cap
issuers generally are more sensitive to changes in earnings expectations, to corporate
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developments, and to market rumors than the market prices of large-cap issuers.
Futures, Commodities, and Derivative Investments. Certain ETFs and mutual funds hold
commodities, commodities contracts, and/or derivative instruments, including futures, options,
and swap agreements. The prices of commodities contracts and derivative instruments, including
futures and options, are highly volatile. Payments made pursuant to swap agreements may also
be highly volatile. Price movements of commodities, futures and options contracts, and payments
pursuant to swap agreements are influenced by, among other things, interest rates, changing
supply and demand relationships, trade, fiscal, monetary and exchange control programs and
policies of governments, and national and international political and economic events and policies.
The value of futures, options, and swap agreements also depends upon the price of the
commodities underlying them. In addition, Client assets are subject to the risk of the failure of any
of the exchanges on which its positions trade or of its clearinghouses or counterparties.
Highly Volatile Markets. The prices of financial instruments can be highly volatile. Price
movements of forward and other derivative contracts are influenced by, among other things,
interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange
control programs and policies of governments, and national and international political and
economic events and policies. Clients are also subject to the risk of failure of any of the exchanges
on which their positions trade or of their clearinghouses.
Non-U.S. Securities. Certain ETFs and mutual funds hold securities of non-U.S. issuers.
Investments in securities of non-U.S. issuers pose a range of potential risks which could include
expropriation, confiscatory taxation, imposition of withholding or other taxes on dividends, interest,
capital gains or other income, political or social instability, illiquidity, price volatility, and market
manipulation. In addition, less information may be available regarding securities of non-U.S.
issuers, and non-U.S. issuers may not be subject to accounting, auditing and financial reporting
standards, and requirements comparable to or as uniform as those of U.S. issuers.
Emerging Markets. Certain ETFs and mutual funds hold securities of emerging markets issuers.
In addition to the risks associated with investments outside of the United States, investments in
emerging markets (i.e., the developing countries) may involve additional risks. Emerging markets
generally are not as efficient as those in developed countries. In some cases, a market for the
security may not exist locally, and transactions will need to be made on a neighboring exchange.
Volume and liquidity levels in emerging markets are lower than in developed countries. When
seeking to sell emerging market securities, little or no market may exist for the securities. In
addition, issuers based in emerging markets are not generally subject to uniform accounting and
financial reporting standards, practices, and requirements comparable to those applicable to
issuers based in developed countries, thereby potentially increasing the risk of fraud or other
deceptive practices.
Capitalization Risks. Investing in Companies within the same market capitalization category
carries the risk that the category may be out of favor due to current market conditions or investor
sentiment.
Market Risks. Turbulence in the financial markets and reduced liquidity may negatively affect the
Companies, which could have an adverse effect on each of them. If the securities of the
Companies experience poor liquidity, investors may be unable to transact at advantageous times
or prices, which may decrease the Company’s returns. In addition, there is a risk that policy
changes by central governments and governmental agencies, including the Federal Reserve or
the European Central Bank, which could include increasing interest rates, could cause increased
volatility in financial markets, which could have a negative impact on the Companies.
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Furthermore, local, regional, or global events such as war, acts of terrorism, the spread of
infectious illness or other public health issues, recessions, or other events could have a significant
impact on the Companies. For example, the rapid and global spread of a highly contagious novel
coronavirus respiratory disease, designated COVID-19, has resulted in extreme volatility in the
financial markets and severe losses; reduced liquidity of many Companies’ securities; restrictions
on international and, in some cases, local travel; significant disruptions to business operations
(including business closures); strained healthcare systems; disruptions to supply chains,
consumer demand and employee availability; and widespread uncertainty regarding the duration
and long-term effects of this pandemic. Some sectors of the economy and individual issuers have
experienced particularly large losses. In addition, the COVID-19 pandemic may result in a
sustained economic downturn or a global recession, domestic and foreign political and social
instability, damage to diplomatic and international trade relations and increased volatility and/or
decreased liquidity in the securities markets. The Companies’ values could decline over short
periods due to short-term market movements and over longer periods during market downturns.
Inverse and Leveraged Products. UWS may recommend and engage in trading with leveraged
and inverse products. These products are aggressive in nature and carry unusual and significant
risk. They are not appropriate for inexperienced investors. These products are intended to be
used/traded daily. Most leveraged and inverse ETFs reset on a daily basis and have published
prospectuses that state (I) they're designed to achieve their stated objective within one day, (2)
clients can lose all of their investment potentially in one day, and (3) holding these securities for
periods longer than one day could lead to losses even if the underlying index moves in the
anticipated direction. Regulatory organizations, such as FINRA & SEC, have released alerts
stating that inverse and leveraged ETFs that reset daily typically are not suitable for retail investors
who plan to hold them longer than one day. Managers may hold these products in client accounts
for periods of time significantly greater than one day. Investors with holding periods longer than a
day expose themselves to substantial risk as the holding period returns will deviate from the
returns to a leveraged or inverse investment in the index. It is possible for an investor in a
leveraged ETF to experience negative returns even when the underlying index has positive
returns.
Penny Stock Risks. Generally, Penny Stocks are low-priced shares of small companies that are
not traded on an exchange. Penny Stocks typically trade over-the-counter, such as on the OTC
Bulletin Board or Pink Sheets. Penny Stocks, unlike listed stocks, are not subject to SEC reporting
requirements or the listing standards of stock exchanges. Because of this, information about the
Penny Stock companies can be difficult to find and verify. Penny Stocks also have lower liquidity
as they are traded less frequently. This also leads to higher volatility. For these reasons, Penny
Stocks are considered to be speculative investments and Clients who trade in penny stocks
should be prepared for the possibility that they may lose their entire investment, or an amount in
excess of their investment if they purchased Penny Stocks on margin.
Variable Annuity Risk. A variable annuity is a form of insurance where the seller or issuer
(typically an insurance company) makes a series of future payments to a buyer (annuitant) in
exchange for the immediate payment of a lump sum (single-payment annuity) or a series of
regular payments (regular-payment annuity). The payment stream from the issuer to the annuitant
has an unknown duration based principally upon the date of death of the annuitant. At this point,
the contract will terminate, and the remainder of the funds accumulated are forfeited unless there
are other annuitants or beneficiaries in the contract. Annuities can be purchased to provide an
income during retirement. Unlike fixed annuities that make payments in fixed amounts or in
amounts that increase by a fixed percentage, variable annuities pay amounts that vary according
to the performance of a specified set of investments, typically bond and equity mutual funds. Many
variable annuities typically impose asset-based sales charges or surrender charges for
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withdrawals within a specified period. Variable annuities may impose a variety of fees and
expenses, in addition to sales and surrender charges, such as mortality and expense risk charges;
administrative fees; underlying fund expenses; and charges for special features, all of which can
reduce the return. Earnings in a variable annuity do not provide all the tax advantages of 401(k)s
and other before-tax retirement plans. Once the investor starts withdrawing money from their
variable annuity, earnings are taxed at the ordinary income rate, rather than at the lower capital
gains rates applied to other non-tax-deferred vehicles which are held for more than one year.
Proceeds of most variable annuities do not receive a "step-up" in cost basis when the owner dies
like stocks, bonds and mutual funds do. Some variable annuities offer "bonus credits." These are
usually not free. In order to fund them, insurance companies typically impose mortality and
expense charges and surrender charge periods. In an exchange of an existing annuity for a new
annuity (so-called 1035 exchanges), the new variable annuity may have a lower contract value
and a smaller death benefit; may impose new surrender charges or increase the period of time
for which the surrender charge applies; may have higher annual fees; and provide another
commission for the broker
The foregoing list of risk factors does not purport to be a complete enumeration or
explanation of the risks involved in an investment with UWS.
Item 9 – Disciplinary Information
UWS and its management have not been involved in any criminal or civil actions, administrative
or self-regulatory enforcement proceedings, nor any legal or disciplinary events that are material
to a Client’s or prospective Client’s evaluation of UWS or the integrity of its management.
Item 10 – Other Financial Industry Activities and Affiliations
Neither UWS nor its management persons are registered as a broker-dealer, broker-dealer
representative, futures commission merchant, commodity pool operator, or a commodity trading
advisor.
Some Investment Advisor Representatives of UWS receive external compensation from sales of
investment-related services as Insurance Agents. This represents a conflict of interest because it
gives an incentive to recommend services based on the fee amount received. This conflict is
mitigated by disclosures, procedures, and UWS’s fiduciary obligation to place the best interest of
the Client first. Moreover, Clients are not required to purchase the recommended products through
the firm or individual making the recommendation. More information on this can be found in the
respective Investment Advisor Representative’s Form U4 and ADV 2B.
UWS may also select and appoint one or more Sub-Advisor(s) to provide Sub-Advisor Services
to Client’s Account without prior consultation with or the prior consent of Client. When selecting
Sub-Advisors, the Client’s best interest will be the main determining factor of UWS. UWS ensures
that before selecting other Sub-Advisors that they are properly licensed or registered as an
investment advisor. You are under no obligation to purchase or sell securities through your
Advisory Representative.
Unique Multi Family Office, LLC
UWS is under common ownership with Unique Multi Family Office, LLC – a separate legal entity
that provides multi-family office services. While UMFO offers a variety of non-advisory services
such as accounting and tax support, family governance, estate planning assistance, business
consulting, and lifestyle management, it does not provide investment advisory services except
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through UWS.
Some UMFO clients may also become clients of UWS, and vice versa. This overlapping client
base creates potential conflicts of interest because our financial interests could be affected if
clients elect to engage both entities. For example, UWS may benefit economically if its advisory
clients also retain UMFO, and UMFO may benefit if its clients also retain UWS.
Clients are under no obligation to use UMFO’s services when engaging UWS for investment
advisory services, nor are UMFO clients required to engage UWS. Clients remain free to select
any third-party providers for non-advisory services.
Broker-Dealer Affiliation
Certain Advisory Representatives are Dually Registered with Kingswood Capital Partners, LLC
(Kingswood), a broker-dealer and member of FINRA/SIPC. Kingswood is independently owned
and operated and is not affiliated with UWS. You are under no obligation to purchase or sell
securities through your Advisory Representative. Advisory Representatives in their role as a
registered representative (RR) will have a conflict of interest in having you purchase securities
through Kingswood in that the higher an IAR/RR’s production with Kingswood, the greater
potential for obtaining a higher pay-out on commissions earned. It is important to understand
investment advisers have a fiduciary obligation to provide advice and services through the
investment adviser that are in the best interest of the client. However, when advisory
representatives act in the capacity of a registered representative, their obligation is to make
recommendations and conduct transactions that are suitable to you but are not necessarily in
your best interest.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Code of Ethics
The affiliated persons (affiliated persons include employees and/or independent contractors) of
UWS have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth
standards of conduct expected of UWS affiliated persons and addresses conflicts that may arise.
The Code defines acceptable behavior for affiliated persons of UWS. The Code reflects UWS and
its supervised persons’ responsibility to act in the best interest of their Client.
One area which the Code addresses is when affiliated persons buy or sell securities for their
personal accounts and how to mitigate any conflict of interest with our Clients. We do not allow
any affiliated persons to use non-public material information for their personal profit or to use
internal research for their personal benefit in conflict with the benefit to our Clients.
UWS’s policy prohibits any person from acting upon or otherwise misusing non-public or inside
information. No advisory representative or other affiliated person, officer, or director of UWS may
recommend any transaction in a security or its derivative to advisory Clients or engage in personal
securities transactions for a security or its derivatives if the advisory representative possesses
material, non-public information regarding the security.
UWS’s Code is based on the guiding principle that the interests of the Client are our top priority.
UWS’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to our Clients
and must diligently perform that duty to maintain the complete trust and confidence of our Clients.
When a conflict arises, it is our obligation to put the Client’s interests over the interests of either
affiliated persons or the company.
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The Code applies to “access” persons. “Access” persons are affiliated persons who have access
to non-public information regarding any Clients' purchase or sale of securities, or non-public
information regarding the portfolio holdings of any reportable fund, who are involved in making
securities recommendations to Clients, or who have access to such recommendations that are
non-public.
UWS will provide a copy of the Code of Ethics to any Client or prospective Client upon request.
Recommendations Involving Material Financial Interests
Neither UWS nor its related persons recommend to Clients, or buys or sells for Client accounts,
securities in which UWS or a related person has a material financial interest.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest
UWS and its affiliated persons may buy or sell securities that are also held by Clients. In order to
mitigate conflicts of interest such as trading ahead of Client transactions, affiliated persons are
required to disclose all reportable securities transactions as well as provide UWS with copies of
their brokerage statements.
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Transactions and Conflicts of Interest
UWS does not maintain a firm proprietary trading account and does not have a material financial
interest in any securities being recommended and therefore no conflicts of interest exist. However,
affiliated persons may buy or sell securities at the same time they buy or sell securities for Clients.
In order to mitigate conflicts of interest such as front running, affiliated persons are required to
disclose all reportable securities transactions as well as provide UWS with copies of their
brokerage statements.
The Chief Compliance Officer of UWS is Jason Andryzak. He reviews all trades of the affiliated
persons each quarter. The personal trading reviews ensure that the personal trading of affiliated
persons does not affect the markets and that Clients of UWS receive preferential treatment over
associated persons’ transactions.
Item 12 – Brokerage Practices
Factors Used to Select or Recommending Broker-Dealers
UWS requires the use of specific broker-dealers, UWS will recommend appropriate brokers based
on a number of factors, including but not limited to their transaction fees, quality of customer
service, and reporting ability. UWS relies on the broker-dealer to provide its execution services at
the best prices available. Lower fees for comparable services may be available from other
sources. Clients pay for any and all custodial fees in addition to the advisory fee charged by UWS.
Research and Other Soft Dollar Benefits
UWS does not receive soft dollar benefits; however, the Firm does receive products and services
from our custodians.
Products and services available to us from Schwab
Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms
like us. They provide us and our clients with access to their institutional brokerage services
(trading, custody, reporting, and related services), many of which are not typically available to
Schwab retail customers. However, certain retail investors may be able to get institutional
brokerage services from Schwab without going through us. Schwab also makes available various
support services. Some of those services help us manage or administer our clients’ accounts,
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while others help us manage and grow our business. Schwab’s support services are generally
available on an unsolicited basis (we don’t have to request them) and at no charge to us. Following
is a more detailed description of Schwab’s support services:
Services that benefit you. Schwab’s institutional brokerage services include access to a broad
range of investment products, execution of securities transactions, and custody of client assets.
The investment products available through Schwab include some to which we might not otherwise
have access or that would require a significantly higher minimum initial investment by our clients.
Schwab’s services described in this paragraph generally benefit you and your account.
Services that do not directly benefit you. Schwab also makes available to us other products
and services that benefit us but do not directly benefit you or your account. These products and
services assist us in managing and administering our clients’ accounts and operating our firm.
They include investment research, both Schwab’s own and that of third parties. We use this
research to service all or a substantial number of our clients’ accounts, including accounts not
maintained at Schwab. In addition to investment research, Schwab also makes available software
and other technology that:
• Provide access to client account data (such as duplicate trade confirmations and account
statements)
• Facilitate trade execution and allocate aggregated trade orders for multiple client accounts
• Provide pricing and other market data
• Facilitate payment of our fees from our clients’ accounts
• Assist with back-office functions, recordkeeping, and client reporting
Schwab provides some of these services itself. In other cases, it will arrange for third-party
vendors to provide the services to us. Schwab also discounts or waives its fees for some of these
services or pays all or a part of a third party’s fees. Schwab also provides us with other benefits,
such as occasional business entertainment of our personnel. If you did not maintain your account
with Schwab, we would be required to pay for these services from our own resources.
Our interest in Schwab’s services
The availability of these services from Schwab benefits us because we do not have to produce or
purchase them. We don’t have to pay for Schwab’s services. The fact that we receive these
benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making
such a decision based exclusively on your interest in receiving the best value in custody services
and the most favorable execution of your transactions. This is a conflict of interest. We believe,
however, that taken in the aggregate, when we recommend a Client’s use of Schwab as custodian
and broker, it is in the best interests of our clients. Our selection is primarily supported by the
scope, quality, and price of Schwab’s services and not Schwab’s services that benefit only us.
Brokerage for Client Referrals
UWS does not receive Client referrals from any custodian or third party in exchange for using that
broker-dealer or third party.
Directed Brokerage
UWS does not allow Client-directed brokerage.
Investment advisors who manage or supervise Client portfolios have a fiduciary obligation of best
execution. The determination of what may constitute best execution and price in the execution of
a securities transaction by a broker involves a number of considerations and is subjective. Factors
affecting brokerage selection include the overall direct net economic result to the portfolios, the
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efficiency with which the transaction is affected, the ability to affect the transaction where a large
block is involved, the operational facilities of the broker-dealer, the value of an ongoing
relationship with such broker and the financial strength and stability of the broker. The firm does
not receive any portion of the trading fees.
Aggregating Trading for Multiple Client Accounts
When a Client authorizes discretionary management, UWS is authorized in its discretion to
aggregate purchases and sales and other transactions made for the account with purchases and
sales and transactions in the same securities for other Clients of UWS. All Clients participating in
the aggregated order shall receive an average share price with all other transaction costs shared
on a prorated basis. If aggregation is not allowed or infeasible and individual transactions occur
(e.g., withdrawal or liquidation requests, odd-late trades, etc.) an account may potentially be
assessed higher costs or less favorable prices than those where aggregation has occurred.
Broker-Dealer Affiliation
As previously stated, some Advisory Representatives are Registered Representatives of
Kingswood Capital Partners LLC. As a result, the IAR/RR is subject to FINRA Conduct Rule 3040
which restricts them from conducting securities transactions away from Kingswood unless
Kingswood provides them with written authorization. Kingswood has provided the required
approval for your advisory accounts to be custodied at one of our recommended custodians. The
investments you purchase through Kingswood will not be advisory accounts but will instead be
commissionable brokerage or other non-advisory accounts.
Item 13 – Review of Accounts
Frequency and Nature of Periodic Review and Who Makes Those Reviews
Account reviews are performed at least annually by the Chief Compliance Officer of UWS.
Account reviews are performed more frequently when market conditions dictate. Reviews of Client
accounts include, but are not limited to, a review of Client documented risk tolerance, adherence
to account objectives, investment time horizon, and suitability criteria, reviewing target allocations
of each asset class to identify if there is an opportunity for rebalancing, and reviewing accounts
for tax loss harvesting opportunities.
Financial plans are updated as requested by the Client and pursuant to a new or amended
agreement, UWS suggests updating at least annually.
Factors That Will Trigger a Non-Periodic Review of Client Accounts
Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new
investment information, and changes in a Client's own situation
Content and Frequency of Regular Reports
Clients receive written account statements no less than quarterly for managed accounts. Account
statements are issued by the Client’s custodian. Client receives confirmations of each transaction
in accounts from the Custodian and an additional statement during any month in which a
transaction occurs. UWS may also send periodic or other event-inspired reports based on market
or portfolio activity. Reports will generally be provided in electronic format.
Item 14 – Client Referrals and Other Compensation
Unique Multi Family Office, LLC
UWS does not receive any direct compensation from UMFO, and UMFO does not receive
compensation from UWS, in connection with clients who choose to engage both entities. However,
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because of the common ownership of UWS and UMFO, there is a conflict of interest in that both
entities may benefit financially if clients elect to engage both firms.
We disclose this affiliated relationship and remind clients that:
•
Investment advisory services are provided exclusively by UWS under a separate advisory
agreement;
• Non-advisory services are provided exclusively by UMFO under a separate UMFO
agreement; and
• Clients are not obligated to engage our affiliate for any services.
Economic Benefits Provided by Third Parties
We receive an economic benefit from our custodians in the form of the support products and
services it makes available to us and other independent investment advisors whose clients
maintain their accounts at our custodians. You do not pay more for assets maintained at our
custodians as a result of these arrangements. However, we benefit from the referral arrangement
because the cost of these services would otherwise be borne directly by us. You should consider
these conflicts of interest when selecting a custodian. The products and services provided by our
custodians, how they benefit us, and the related conflicts of interest are described above (see
Item 12—Brokerage Practices).
UWS receives indirect compensation from Charles Schwab & Co, Inc., based on the amount of
assets under management that the Firm custodies at Schwab. In exchange for using Schwab to
custody client assets up to $200M at Schwab, the Firm can receive indirect compensation up to
$40,000. This compensation will be used to offset any ACAT, or account transfer costs incurred
by clients moving their accounts to Schwab from other custodians. Additional compensation can
be paid to vendors of the Firm who assist in the Firm’s ability to provide advisory services to their
clients. None of this compensation can be paid directly to UWS by Schwab.
Compensation to Non-Advisory Personnel for Client Referrals
UWS does not compensate for Client referrals.
Broker-Dealer Registrations
In their role as Registered Representatives of Kingswood, some of our Advisory Representatives
will earn commissions. The amount of commissions paid by Kingswood to the Representative will
fluctuate based on overall production. Therefore, certain production thresholds may allow the
IAR/RR to earn a higher payout of the commissions earned. This is considered a conflict of interest.
Kingswood and your IAR/RR attempt to mitigate any conflicts of interest by evaluating and
recommending services based on the benefits that each service provides to their clients. In some
cases an advisory account is a better option for a client.
UWS may share in the commissions earned by the IAR/RR indirectly as certain IAR/RRs pay rent
and other related office and administrative expenses to UWS. These charges are not based on
the commissions earned by the IAR/RR but rather the charges are based on reasonable and
customary office and administrative charges which may vary based on actual usage.
Item 15 – Custody
All assets are held at qualified custodians, which means the custodians provide account
statements directly to Clients at least quarterly. Clients are urged to compare the account
statements received directly from their custodians to any documentation or reports prepared by
UWS.
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UWS is not affiliated with the custodian. The custodian does not supervise UWS, its employees
or its activities.
Item 16 – Investment Discretion
If applicable, Client will authorize UWS discretionary authority, via the Advisory Agreement, to
determine, without obtaining specific Client consent, the securities to be bought or sold, and the
amount of the securities to be bought or sold. If applicable, Client will authorize UWS discretionary
authority to execute selected investment program transactions as stated within the Investment
Advisory Agreement. If, however, consent for discretion is not given, UWS will obtain prior Client
approval before executing each transaction.
UWS allows Clients to place certain restrictions, as outlined in the Client’s Investment Policy
Statement or similar document. Such restrictions could include only allowing purchases of socially
conscious investments. These restrictions must be provided to UWS in writing.
The Client approves the custodian to be used and the commission rates paid to the custodian.
UWS does not receive any portion of the transaction fees or commissions paid by the Client to
the custodian.
Item 17 – Voting Client Securities
When assistance on voting proxies is requested, UWS will provide recommendations to the Client.
However, UWS will not have the authority to vote proxies on behalf of the Client. If in the future
UWS obtains authority to vote proxies, this Brochure will be appropriately amended.
Item 18 – Financial Information
UWS has no financial commitment that impairs its ability to meet contractual and fiduciary
commitments to Clients and has not been the subject of a bankruptcy petition.
UWS does not require nor solicit prepayment of more than $1,200 in fees per Client, six months
or more in advance.
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