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Wharton Wealth Management, LLC
Form ADV Part 2A - Brochure
110 N. Phoenixville Pike, Suite 300,
Malvern PA 19355
Main Phone Number: 484-328-3590
http://www.whartonwealth.com
March 31, 2026
This brochure provides information about the qualifications and business practices of Wharton
Wealth Management, LLC. If you have any additional questions about the contents of this
Brochure, please contact us at 484-328-3590. 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.
Wharton Wealth Management, LLC is a registered investment advisor. Registration as an
investment advisor does not imply a certain level of skill or training.
Additional information about Wharton Wealth Management, LLC is available on the SEC’s
website at http://www.adviserinfo.sec.gov.
Item 2. Material Changes
Since Wharton Wealth Management, LLC published the last version of this Brochure on March
31, 2025, WWM has not made any material changes to these disclosures.
Currently, our Brochure may be requested by contacting Robert C. Gueriera at 484-328-3590.
information about our
firm
is also available via
the SEC’s web site
Additional
www.adviserinfo.sec.gov. The SEC’s web site also provides information about any of our
affiliated persons who are registered, or are required to be registered, as investment advisor
representatives of Wharton Wealth Management, LLC.
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Table of Contents
Item 3.
ITEM 2. MATERIAL CHANGES .................................................................................................................... 2
ITEM 3. TABLE OF CONTENTS ................................................................................................................... 3
ITEM 4. ADVISORY BUSINESS ..................................................................................................................... 4
VISION2020 WEALTH MANAGEMENT PLATFORM – ADVISOR MANAGED PORTFOLIOS ............. 5
VISION2020 WEALTH MANAGEMENT PLATFORM – SMA AND UMA PROGRAM ............................. 5
Pension Consulting .................................................................................................................................................................. 7
ITEM 5. FEES AND COMPENSATION ........................................................................................................ 9
ITEM 6. PERFORMANCE-BASED FEES .................................................................................................. 11
ITEM 7. TYPES OF CLIENTS ....................................................................................................................... 11
ITEM 8. METHOD OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ........ 12
Risk Factors ............................................................................................................................................................................. 12
ITEM 9. DISCIPLINARY INFORMATION ............................................................................................... 14
ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ......................... 14
ITEM 11. CODE OF EITHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING..................................................................... 16
ITEM 12. BROKERAGE PRACTICES .......................................................................................................... 16
ITEM 13. REVIEW OF ACCOUNTS ............................................................................................................. 17
ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION ................................................... 18
ITEM 15. CUSTODY ........................................................................................................................................... 18
ITEM 16. INVESTMENT DISCRETION ...................................................................................................... 18
ITEM 17. VOTING CLIENT SECURITIES ................................................................................................. 19
ITEM 18. FINANCIAL INFORMATION ...................................................................................................... 19
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Item 4. Advisory Business
Wharton Wealth Management, LLC (“WWM”) is an investment adviser registered with the
United States Securities & Exchange Commission (“SEC”) that provides investment advisory
services to clients (each, a “Client” and together, “Clients”), as further described below. WWM
is a Pennsylvania limited liability company which has been in existence since 2015. WWM’s
principal owner and managing member is Robert C. Gueriera, Jr.
Investment Advisory Services
The investment advisory services (the “Services”) offered to WWM’s Clients include
discretionary and non-discretionary asset management and related services across a broad range
of investment strategies and asset classes, as well as comprehensive financial planning, WWM’s
Services consist of the ongoing and continuous review and management of each Client’s
investment assets consistent with each Client’s investment profile, risk tolerance and objectives.
WWM also provides reports on the Client’s assets, fees and performance. In providing
discretionary advisory services, WWM will make investment decisions as to the securities to
purchase and sell in the Client’s portfolio, and the amount of securities to purchase and sell in
such portfolios without prior notice to or consent of the Client. In non-discretionary
relationships, WWM will not engage in any transactions in Client accounts without the Client’s
prior instructions or consent. WWM does not hold itself out as specializing in a particular type
of advisory service.
In providing the Services, WWM reviews each Client’s financial situation to understand the
goals and objectives of each Client. WWM then prepares a strategy tailored to the individual
needs of each Client. WWM takes into consideration the investment objectives, risk
tolerance(s), time horizon(s), income needs, tax situation any other financial, personal and
professional characteristics of each Client when preparing an investment policy statement
(“IPS”) and when choosing which investments to use in each Client’s account. WWM
supervises and rebalances the Client’s portfolio as changes in market conditions and the Client’s
circumstances may require.
WWM primarily advises Clients with respect to investments in securities, insurance products,
real estate, private investments. WWM may also, at its discretion, provide advice on any type of
investment held in a Client’s portfolio at the inception of the advisory relationship or concerning
any investment for which the Client requests advice, whether or not included in the assets under
management with WWM.
Each Client portfolio is tailored to meet the individual needs of each individual Client, based on
the investment objectives, time horizon, income needs, tax situation, and risk profile of each
Client. The Clients may also communicate to WWM restrictions on securities, asset classes,
custodians, holdings or any other personal restriction they would like to impose on their
portfolios in their IPS.
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WWM’ Investment Adviser Representatives (“Advisory Representatives”) may periodically
recommend and refer Clients to unaffiliated money managers or investment advisers at its
discretion or Client’s request. In such circumstances where your Advisory Representative deems
this appropriate, either WWM will enter into sub-advisory agreements with such managers, and
these sub-advisors will receive an investment advisory fee computed based on a fee schedule
established with WWM, or the Client will enter a separate agreement with the unaffiliated
adviser and the adviser will be compensated based on a fee schedule negotiated between Client
and the adviser. In the case of a sub-adviser relationship between WWM and the unaffiliated
adviser, fees for the sub-adviser will be debited directly from the Client’s managed account. In
the case of a direct contract between Client and adviser, fees will be paid in the manner
negotiated between Client and the adviser. In either case, WWM’s Advisory Representative
will assist and advise the Client in establishing investment guidelines for these accounts so that
they are consistent with the Client’s overall portfolio and objectives.
VISION2020 WEALTH MANAGEMENT PLATFORM – ADVISOR MANAGED
PORTFOLIOS
The Wealth Management Platform – Advisor Managed Portfolios Program (“Advisor Managed
Portfolios”) provides comprehensive investment management of your assets through the
application of asset allocation planning software as well as the provision of execution, clearing
and custodial services through Pershing, LLC ("Pershing") or National Financial Services, Inc.
(“NFS”).
Advisor Managed Portfolios provides risk tolerance assessment, efficient frontier plotting, fund
profiling and performance data, and portfolio optimization and re-balancing tools. Utilizing these
tools, and based on your responses to a risk tolerance questionnaire (“Questionnaire”) and
discussions that we have together regarding, among other things, your personal investment
objective and goals, time horizon, risk tolerance, account restrictions, needs, personal
circumstances and overall financial situation, we construct a portfolio of investments for you.
Your Advisory Representative has the option to allocate your portfolio amongst a mix of stocks,
bonds, options, Exchange-Traded Funds, mutual funds and other securities (“Program
Investments”) which are based on your investment goals, objectives, and risk tolerance.
Each portfolio is designed to meet your individual needs, stated goals and objectives.
Additionally, you have the opportunity to place reasonable restrictions on the types of
investments to be held in the portfolio.
For further Advisor Managed Portfolios details please see the Advisor Managed Portfolios Wrap
Fee Program Brochure. We provide this brochure to you prior to or concurrent with your
enrollment in Advisor Managed Portfolios. Please read it thoroughly before investing.
VISION2020 WEALTH MANAGEMENT PLATFORM – UNIFIED MANAGED
ACCOUNT PROGRAM
The Wealth Management Platform Unified Managed Account (“UMA”) provides you with the
opportunity to invest your assets across multiple investment strategies and asset classes by
implementing an asset allocation strategy. WMAP is a Wrap Account program that offers these
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advisory services along with brokerage and custodial services for a single, annual, asset-based
advisory fee.
After you discuss your financial goals and objectives with your Advisory Representative, we wil
recommend an asset allocation model (“UMA Model”) to you which will consist of:
(a) Investment strategies serviced and created by investment managers or your Advisory
Representative that generally consist of a selection of mutual funds, Exchange-Traded
Products, equities, and/or bonds;
(b) Mutual Funds and ETFs (“Funds”);
(c) Or a combination of the preceding bundled together in an investment asset allocation
model.
We will recommend a UMA Model to you based on your responses to a Questionnaire and
discussions that we have together regarding among other things, your personal investment
objectives and goals, time horizon, risk tolerance, account restrictions, needs, personal
circumstances and overall financial situation. In addition, you can place reasonable restrictions
on investments held within your UMA account. All recommendations in the UMA are made on
a discretionary basis, which means your Advisory Representative can act without your prior
approval.
For further details, please refer to the Wealth Management Platform – Unified Managed
Account Wrap Fee Program Brochure. We provide this brochure to you prior to or concurrent
with your enrollment in UMA. Please read it thoroughly before investing.
THIRD PARTY ADVISORY SERVICES
We may also offer you the services of various third party money managers (“Third-Party Money
Managers” or “TPMMs”) for the provision of certain investment advisory programs including
mutual fund wrap and separately managed accounts. In doing so, we act in a “co-advisory”
capacity.
When acting in a co-advisory capacity, WWM and the Third-Party Money Manager are jointly
responsible for the ongoing management of your account. In connection with this arrangement,
your Advisory Representative will provide assistance in the selection and ongoing monitoring of
a particular Third-Party Money Manager. Factors WWM considers in selection of a particular
Third-Party Money Manager include, but are not limited to:
(1) Our assessment of a particular Third-Party Money Manager;
(2) Your risk tolerance, goals, objectives and restrictions, as well as investment experience;
and
(3) The assets you have available for investment.
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In addition to the advisory relationship that you will have with these Third-Party Money
Managers, you will also enter into an advisory relationship with WWM by signing our
investment management agreement.
If you are interested in learning about these services, please note that a complete description of
the programs, services, fees, payment structure and termination features are available through
the applicable Third-Party Money Manager’s disclosure brochure, investment advisory
agreement, and account opening documents.
You should understand that the services provided by us through these Third-Party Money
Managers are under certain conditions directly offered by them to you. The fees charged by
Third-Party Money Managers who offer their programs directly to you may be more or less than
the combined fees charged by the Third-Party Money Managers and WWM for our participation
in the investment programs.
Trading by Third-Party Money Managers may sometimes trigger wash sale rule implications. A
wash sale occurs when a security is sold at a loss and then the same or substantially identical
security is repurchased within a short time period. The Third-Party Money Manager may not be
able to manage accounts in a manner to avoid wash sale implications. Your are encouraged to
consult with a tax advisor to discuss any tax implications involving your portfolios in these and
in all advisory programs.
As of December 31, 2025, WWM managed $209,168,956 in assets for 951 accounts under
discretionary investment management agreements.
Pension Consulting
Pension consulting services offered by WWM include the following category of services:
Plan Design:
Evaluation, design, testing and formation of qualified and/or non-
qualified plans.
Plan Implementation: Selection of investment options, identification and education of
Plan Participants, preparation of Plan documents and Participant
information, and selection of necessary financial, accounting and
legal service providers.
Plan Administration: Provide administrative services to Plan Sponsor for collection and
processing of Participant documentation, assist in enrolling and
terminating Participants’ participation in the Plan(s), providing
educational meetings with Participants, and assisting Plan Sponsor
in annual and periodic reviews of Plan options.
In essence, WWM provides support to companies offering qualified and non-qualified retirement
plans to employees. WWM’s consulting services are structured to satisfy the Client’s plan
objectives, such as maximizing employee contributions and increasing employee satisfaction and
retention, among others. WWM serves various types of qualified and non-qualified plans and
offers customized solutions to meet each Client’s individual needs.
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Financial Planning
WWM offers a variety of financial planning and consultation services to individuals, families,
businesses, institutions, trusts and charitable organizations regarding the management of their
financial resources based upon an evaluation of a number of factors. In general, WWM’s
financial planning services involve preparing a financial plan for Client that incorporates Client’s
present financial circumstances, future financial goals and risk parameters. This planning may
encompass one or more of the following areas: investment, retirement and estate planning,
charitable gifting, portfolio analysis, business succession planning and institutional financial
management.
In developing the financial plan, WWM will undertake the following steps:
1. Gather the financial, biographical and personal information necessary to develop the
plan.
2. Analyze Client’s current financial condition by preparing financial statements and
projections and assessing the Client’s insurance, investments, and estate needs, as
well as risk parameters and tolerances.
3. Assist Client in developing specific, quantifiable financial goals.
4. Prepare a written, comprehensive financial plan that maximizes Client’s ability to
efficiently achieve those goals.
5. Assist the client with the implementation of parts of the plan and coordinate the
implementation of the rest of the plan with Client’s other financial advisers.
6. Appropriately administer investment assets if these services have been requested by
the Client and an “Investment Management Agreement” has been executed by the
Client and Adviser.
7. Periodically update the analysis and recommendations based on the Client’s changing
personal and financial situation, to the extent that Client requests these services.
Periodic updates for each plan will continue for one year following delivery of the
Plan, unless WWM and Client agree in writing to extend this update period.
The written financial plan delivered to Client usually includes general recommendations for a
course of activity or specific actions to be taken by Client. For example, recommendations may
be made that Client institute or revise investment programs, establish or amend wills or trusts,
obtain or revise insurance products, open retirement or educational savings accounts, implement
charitable giving programs. In making these recommendations, WWM is not acting as Client’s
attorney or accountant. Client is urged to retain legal counsel and accounting services in
implementing the recommendations set forth in the plan.
The implementation of the recommendations will be at the discretion of Client. WWM will
assist with the implementation of the recommendations if the Client executes an investment
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management agreement. WWM may also recommend that Client implement the financial plan
through certain investment advisers, broker-dealers and/or insurance companies. Client is free to
implement the plan through advisers, broker-dealers or insurance companies of Client’s choice.
Adviser does not exercise discretion with respect to any of Client’s transactions unless the Client
and WWM execute a separate Investment Management Agreement.
WWM will maintain a business continuity plan in the event of a disruption in business. Among
other things, the plan details how Clients may access their accounts in the event of an
emergency. A copy of the plan is available for review upon request.
Clients will be provided a copy of this Brochure at or before the execution of a written contract
with WWM for advisory, retirement consulting or financial planning services. If this Brochure is
not provided to a Client at least 48 hours before execution of the advisory, retirement consulting
or financial planning agreement, the Client will have five (5) business days to cancel the
agreement without penalty.
As reflected in WWM privacy policy, WWM prohibits the public disclosure of any Client related
nonpublic, personally identifiable information, except as permitted by law. Such Client related
information is maintained in a safe and secure manner. Questions regarding WWM’s privacy
policy should be directed to Robert C. Gueriera, Jr. at 484-328-3590.
Item 5. Fees and Compensation
Investment Management
WWM charges Clients an investment advisory fee for its investment management and pension
consulting services. This fee is based on the Client’s total assets under management or under
consultation with WWM. The fees are paid quarterly in advance, based on the market value of
the account as of the last business day of the previous quarter. Accounts that are not open for a
full calendar quarter will be responsible for the pro-rata portion of the fee based on the number
of days the account is open during the quarter.
Clients and WWM may terminate the relationship at any time by giving written notice to the
other party. In the event the advisory agreement is cancelled during any quarter, the Client is
refunded any amounts collected that are not yet earned as of the date the relationship ends.
Refunds are calculated by WWM on a pro-rata basis and are deposited into the Account they
were deducted from or WWM sends a check to the Client. Refunds are paid within thirty (30)
days after the relationship ends.
Advisory fees will be withdrawn directly from the Client’s account held by an independent
custodian. However, the following criteria must be met when the custodian makes payment:
• The Client must provide written authorization permitting the fees to be paid directly from
the clients account held by independent custodian.
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• WWM will send to the custodian written notice of the amount of the fee to be deducted
from the account. The custodian agrees to send the Client a statement directly, at least
quarterly, indicating all the amounts disbursed from the account including the amount of
advisory fees paid directly to WWM. The custodian of the account is advised in writing
of the limitation on WWM’s access to the account. WWM does not and will not have
custody of Client’s funds and securities.
• WWM sends to the Client an invoice showing the amount of the fee, including
any formulae used to calculate the fee, the time period covered by the fee and the
amount of assets under management the amount of fee was based. WWM advises the
Client that it is the clients responsibility to verify the accuracy of the fee calculation and
that the custodian will not determine whether the fee is properly calculated.
• WWM shall only utilize the custodial services of the “Qualified Custodian.”
WWM charges asset management fee of between .38% and 1.15%, depending upon the size of
the account and complexity of the investments. Depending on certain Client specific factors,
WWM may reduce its annual fee, account size, or amend the fee schedule.
Other Fees
WWM’s advisory fees are exclusive of and in addition to brokerage commissions, transaction
fees, and other related costs and expenses which shall be incurred by the client. Clients may
also incur certain other charges imposed by custodians, brokers, third-party investment
managers, and other third-parties, such as interest charges, deferred sales charges, odd-lot
differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on
brokerage accounts and securities transactions. In certain circumstances, WWM may pay these
costs and expenses on behalf of the Client. Clients should review all fees charged by WWM and
its custodians, brokers, and others to fully understand the total amount of fees to be paid. Mutual
funds, exchange-traded funds, sub- advisory firms (explained below) and private funds also
charge internal management fees, which are disclosed in a fund’s prospectus or offering
documents. WWM will not receive any portion of these commissions, fees, or costs.
At WWM’s sole discretion, WWM may negotiate with Clients to pay the brokerage fees and
transaction costs of a Client’s account out of the fees charged by WWM. These arrangements
will not constitute or include a Wrap Fee program.
Third-Party Money Manager Fees
For Clients who require particular investment management services, WWM may recommend
that Clients authorize the active discretionary management of their assets by Third-Party Money
Managers (as defined above). The terms and conditions under which Third-Party Money
Managers are engaged are set forth in a separate written agreement between WWM or the Client
and the designated Third-Party Money Manager. WWM renders services to the Client relative to
the discretionary and non-discretionary recommendations of Third-Party Money Managers.
WWM monitors and reviews the account performance and the Client’s investment objectives.
WWM receives an annual advisory fee which may be based upon a percentage of the market
value of the assets being managed by the designated Third-Party Money Managers. The
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annual advisory fee for Clients’ assets managed by designated Third-Party Money Managers
will be the same as the fee schedule listed above, though WWM reserves the right to reduce its
annual fees where appropriate, particularly where such combined fees may be deemed excessive
as discussed below.
Factors that WWM considers in recommending Third-Party Money Managers are set forth in
Item 4 above. The investment management fees charged by the designated Third-Party
Money Managers together with the fees charged by the corresponding designated broker-
dealer/custodian of the Client’s assets, may be exclusive of, and in addition to, WWM’s
investment advisory fee set forth above. However, WWM undertakes that in no case will the
combined fees charged by WWM and the Third-Party Money Managers exceed 3.00% of the
Client’s assets under management, which amount is considered excessive.
Financial Planning Fees
The fees for financial planning services may be hourly, with the hourly rates ranging between
$150 and $300 per hour depending upon complexity. Depending on certain factors, including,
but not limited to, the level of planning requested, the amount of assets, the complexity of
assets, the number of individuals, trusts, and entities involved, the length of the plan, and other
matters, WWM may reduce the fee. One-half of the fee is payable at the time Client executes
this Agreement, and the balance is payable upon delivery of the plan. In the event a Client
cancels the agreement prior to Adviser delivering the plan, the Client is refunded any amounts
collected that are not yet earned as of the date the relationship ends (as discussed below).
Clients may terminate their relationship with WWM at any time by giving written notice to
WWM, which termination shall be effective upon receipt. WWM will provide the Client with all
written work completed as of the effective date of termination. In the event Client terminates the
agreement prior to completion of the plan, Client will be responsible for all fees incurred up to
the date of termination, and any unearned fees paid in advance will be refunded by WWM on a
pro-rata basis. WWM will send a refund check to the Client within thirty (30) days after the
relationship ends, of applicable. WWM may terminate the agreement at any time following
delivery of the plan, which termination shall be effective upon receipt.
Item 6. Performance-Based Fees
WWM does not charge performance fees.
Item 7. Types of Clients
WWM provides Services to various types of clients, including individuals, families, businesses,
institutions, charitable organizations, retirement plans, trusts, and other advisers and financial
services providers. WWM has the discretionary authority to buy or sell securities or other
investments, or determine the securities or investments to buy or sell, without the Client’s
consent. For those Clients who execute non-discretionary agreements, WWM will not purchase
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or sell securities or other investments absent such Client’s authorization or direction, WWM will
not require that customers invest a minimum amount with the adviser.
Item 8. Method of Analysis, Investment Strategies and Risk of
Loss
WWM works closely with Clients to determine their investment goals, time horizons and levels
of risk tolerance. WWM then constructs an investment strategy designed to meet that Client’s
objectives.
Investment Strategies
The investment strategy for a specific client is based upon the objectives stated by the client
during consultations with WWM’s investment advisory personnel. Each Client completes an
investment profile statement or similar form that documents the Client’s objectives, risk
tolerance, financial condition, investment experience and desired investment strategy. WWM
recommends or implements various investment strategies when providing asset allocation
proposals and advice to clients based on these objectives. WWM’s investment adviser
representatives are accountable for reviewing asset allocation recommendations on at least an
annual basis. If the Client should change their objectives, WWM may recommend a new
proposal in order to achieve the Client’s revised objectives, risk tolerance and updated
investment strategy.
WWM may employ one or more methods of securities and investment analyses in determining
the suitability of an investment for a Client. One method of analysis involves “Charting”, which
uses trading, pricing and volume patterns to identify trends to forecast the direction of securities
and asset prices. Another method is “Fundamental” analysis, which seeks to establish a forecast
of the investment returns possible from a given investment alternative. A third method WWM
may employ is “Technical” analysis, which relies on historical and current price and trading data
to forecast the direction of investment values.
Using one or more of the above-referenced methods, and in consideration of the Client’s
information collected through the investment profile statement or similar documentation, WWM
may recommend investment options in equities, fixed income, bank obligations, real estate
investment trusts, direct participation programs, and lending clubs or direct lending strategies.
Each of these investment options carry particular risks in addition to the general risks applicable
to all investment options. The specific and general risks of investments recommended by WWM
are detailed below.
Risk Factors
Clients are advised that investments are not guaranteed and there is a risk of loss. The value of
securities and portfolios containing investments will fluctuate, and may be worth more or less
than the original investment value at the time of sale. While certain strategies may offer the
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potential for greater growth, these same strategies may have greater potential volatility. While it
is WWM’s intent to reduce risk when possible, certain strategies may impose more risk than
others. Clients are advised that WWM’s past results are not predictive of future results, that no
investment return is guaranteed, and that significant losses can occur by investing in any security
or by following any strategy. Clients are advised that all investment programs have certain risks
and that accounts can decline in value. These risks include, but are not limited to:
Market Risk – The price of security, bond, or mutual fund may drop in reaction to tangible and
intangible events and conditions. This type of risk is caused by external factors independent of a
security’s particular underlying circumstances. For example, political, economic and social
conditions may trigger market events.
Small and Mid-capitalization Securities Risk – Securities of Small or mid-capitalized companies,
and mutual funds which invest primarily in small and mid-sized securities issuers, may be
subject to higher degrees of risk, because companies of this capitalization size may have earnings
which are less predictable, securities values which are more volatile, and less liquidity than
securities of large capitalization companies.
Interest-Rate Risk – Fluctuations in interest rates may cause investment prices to fluctuate. If
interest rates rise, debt security prices usually decline. The longer a debt security’s maturity, the
greater the impact a change in interest rates can have on its price. Not holding a debt security
until maturity may cause a gain or loss when the debt security is sold. Debt securities also carry
the risk of default, which is the risk that the issuer is unable to make further income and principal
payments. Other risks, including inflation risk, call risk, and pre-payment risk also apply.
Inflation Risk – When any type of inflation is present, a dollar today will buy more than a dollar
in the future as 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.
Creditworthiness Risk - Investments in high yield debt securities or “junk” bonds carry a degree
of risk in addition to those of general debt securities. High yield debt securities are assigned a
credit rating of “non-investment grade” by independent ratings agencies, which relates to their
higher risk of default. In return for the higher yield these bonds typically offer, the investor is
accepting the risk that they may receive neither payment of interest nor the repayment of the
principal of their investment.
Reinvestment Risk – This is the risk that future proceeds from investments may have to be
reinvested at a potentially lower rate of return. This primarily relates to fixed income securities.
Liquidity Risk – Liquidity is the ability to readily convert an investment into cash.
Foreign Market Risk - Investment strategies recommended by WWM may include investments
in Non-U.S. foreign securities and fixed income investments (“Non-U.S. Investments”).
Investing in Non-U.S. investments, in particular emerging markets, will subject a client to certain
risks not typically associated with investing in securities in the United States. Non-U.S.
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investments may be affected by changes in currency rates. A decline in an exchange rate of the
foreign currency in which a portfolio security is quoted or denominated relative to the U.S. dollar
would reduce the value of the portfolio security in U.S. dollars proportionately. The costs and
expenses associated with investing in Non-U.S. markets are generally higher than in U.S.
markets. There generally may be less publicly available information regarding Non-U.S.
Investments than U.S. companies. In addition, certain Non-U.S. economies are less stable that
the U.S. economy due to, among other things, volatile political environments and less stable
monetary systems.
Key Person Risk - Performance is largely dependent on the talents and efforts of certain
individuals. There can be no assurance that WWM investment professionals will continue to be
associated with WWM and the failure to retain such investment professionals could have an
adverse effect on the value of an investment.
Short-selling and Hedging Risk - Certain investment strategies may employ short selling, options
trading, and other derivative or “hedging” transactions that can, in some circumstances,
substantially increase the impact of adverse price movements.
Concentration Risk - Certain strategies may also invest in certain industries or sectors of the
market and are therefore less volatile. Such strategies may be at higher risk in the event the
industry or sector invested in is subject to adverse market conditions.
Tax Risks - The investments recommended by WWM may generate taxable income and realized
capital gains or losses, and Clients should consult with their tax advisors about the tax
consequences of their investments. WWM does not offer tax advice to Clients.
Item 9. Disciplinary Information
Registered investment advisors are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of WWM or the integrity of
WWM’s management. WWM has no information to disclose.
Item 10. Other Financial Industry Activities and Affiliations
WWM is required to disclose any relationship or arrangement that is material to its advisory
business or to its clients with certain related persons.
Registered Representatives of Broker Dealer
Clients may engage certain persons associated with WWM (but not WWM itself) to render
securities brokerage services under a commission arrangement. Clients are under no obligation
to engage such persons and may choose brokers or agents not affiliated with WWM. Under
this arrangement, Clients may implement securities transactions through certain of WWM’s
Supervised Persons in their respective individual capacities as registered representatives of
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FSC Securities Corporation (“FSC”), an SEC registered broker-dealer and member of
FINRA. FSC may charge brokerage commissions to effect these securities transactions and
thereafter, a portion of these commissions may be paid by FSC to such Supervised Persons.
Prior to effecting any transactions, Clients are required to enter into a new account agreement
with FSC. The brokerage commissions charged by FSC may be higher or lower than those
charged by other broker-dealers. In addition, certain of the firm’s Supervised Persons may also
receive ongoing 12b-1 fees for mutual fund purchases from the mutual fund company during
the period that the Client maintains the mutual fund investment. The firm may recommend
no-load mutual funds.
A conflict of interest exists to the extent that WWM recommends the purchase of securities
where WWM’s Supervised Persons receive commissions or other additional compensation as a
result of WWM’s recommendations. WWM has procedures in place to ensure that any
recommendations made by such Supervised Persons are in the best interest of Clients. Although
WWM has procedures in place to monitor the activities of Supervised Persons acting in their
capacity as registered representative of FSC, FSC supervises the registered representative’s
conduct and transactions.
The firm’s Supervised Persons currently devote between 5% - 20% of their time to the
commission securities brokerage business, depending on the individual Supervised Person.
Investment Adviser Representative of another Investment Adviser
Certain Supervised Persons of WWM are also investment adviser representatives of FSC, an
unaffiliated investment adviser. Such Supervised Persons may make recommendations to
Clients of FSC that may be similar or inconsistent with recommendations made to Clients of
WWM. In such instances, all Supervised Persons are required to make those recommendations
to Clients that are suitable for the Client, and not in the interest of the Supervised Person.
A conflict of interest may exist to the extent that Supervised Persons of WWM advise Clients of
FSC and WWM on the purchase or sale of the same securities. In such circumstances, WWM
and FSC have procedures in place to ensure that any recommendations made by such
Supervised Persons are in the best interest of Clients of the respective investment adviser, and
that no Client of either firm is disadvantaged by the advisory services provided.
The firm’s Supervised Persons currently devote between 5% - 20% of their time to the
investment advisory services of FSC depending on the individual Supervised Person.
Receipt of Insurance Commission
Certain of WWM’s Supervised Persons, in their individual capacities, are also licensed
insurance agents with various insurance companies, and in such capacity, may recommend, on a
fully-disclosed commission basis, the purchase of certain insurance products. While WWM does
not sell such insurance products to its investment advisory clients, WWM does permit its
Supervised Persons, in their individual capacities as licensed insurance agents, to sell insurance
products to its investment advisory clients. A conflict of interest exists to the extent that WWM
recommends the purchase of insurance products where WWM’s Supervised Persons receive
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insurance commissions or other additional compensation. WWM has procedures in place to
limit the conflict of interest, although WWM does not supervise the activities of the
Supervised Persons when they are acting as insurance agents. WWM’s Supervised Persons
currently devote between 5% and 20% of their time to insurance sales.
Item 11. Code of Eithics, Participation or Interest in Client
Transactions and Personal Trading
WWM has adopted a Code of Ethics that complies with Rule 204A-1 under the Investment
Advisors Act of 1940. The Code of Ethics applies to all of WWM’s supervised persons. The
term “supervised person” means any partner, officer, director (or other person occupying a
similar status or performing similar functions) or employee of WWM, or other person who
provides investment advice on behalf of WWM and is subject to WWM’s supervision and
control. WWM’s supervised persons must certify on an annual basis that they have received,
read and understood the Code of Ethics.
WWM’s Code of Ethics addresses the following areas of WWM’s business: procedures for
personal securities transactions of directors, officers and employees; and initial public offerings
and private offerings. Each officer, director and employee is required to certify annually that he
or she has read and understands the Code of Ethics. WWM will provide a copy of its Code of
Ethics to any Client or prospective Client upon request. Please contact Robert C. Gueriera, Jr.
for a copy.
WWM, its directors, officers and employees may from time to time purchase or sell securities
that WWM recommends to Clients. These purchases or sales must be effected in accordance
with WWM’s Code of Ethics, which includes a personal trading policy. Transactions where
WWM purchases the same securities and investment products that WWM recommends to a
Client are subject to the Code of Ethics and may present a conflict of interest. Such transactions,
as well as personal securities transactions of WWM’s supervised persons will generally not be
allowed when the investment would be made at or near the same time as a trade in the same
security on behalf of a Client account.
WWM’s Chief Compliance Officer is responsible for ensuring that WWM receives duplicate
confirmations and account statements for anyone associated with WWM who has a securities
account with a broker-dealer. A review of the trading activity of WWM personnel with such
securities accounts will be conducted quarterly to ensure that the personnel comply with the
personal trading policy of WWM.
Item 12. Brokerage Practices
WWM does not have discretionary authority to select the broker-dealer/custodian for custodial
and execution services or the administrator for defined contribution accounts. The Client will
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select the broker-dealer or custodian to safeguard Client assets and authorize WWM to direct
trades to this custodian as agreed in the Investment Management Agreement.
Though WWM does not exercise discretion over the selection of the custodian, it may
recommend the custodian[s] to Clients for execution and/or custodial services. As discussed
above, WWM may recommend the use of FSC for brokerage and custodial services of
investment management accounts. WWM may develop other relationships with custodians
depending upon the services offered to clients and the factors considered in determining “best
execution” for client transactions (discussed below), and therefore may recommend use of other
custodians with which WWM has a contractual relationship to clients. WWM is not affiliated
with FSC or any other custodian recommended to clients, and clients are not obligated to use the
recommended custodian nor will clients incur any extra fee or cost associated with using a broker
not recommended by WWM. For those clients who may have existing custodial relationships at
firms other than those mentioned, WWM is able to work with these clients to maintain that
already established relationship.
The commissions paid by WWM’s clients comply with WWM’s duty to obtain “best execution.”
Clients may pay commissions that are higher than another qualified custodian might charge to
effect the same transaction where WWM determines that the commissions are reasonable in
relation to the value of the brokerage and research services received. In seeking best execution,
the determinative factor is not the lowest possible cost, but whether the transaction represents
the best qualitative execution, taking into consideration the full range of a broker’s services,
including among others, the value of research provided, execution capability, commission
rates, and responsiveness. WWM seeks competitive rates but may not necessarily obtain the
lowest possible commission rates for Client transactions.
The Client may also direct W WM in writing to use a particular broker or custodian to
execute some or all transactions for the client. In that case, the Client will negotiate terms and
arrangements for the account with that broker, and WWM will not seek better execution
services or prices from other brokers or be able to “batch” Client transactions for execution
through other brokers with orders for other accounts managed by WWM (as described above).
As a result, the Client may pay higher commissions or other transaction costs or greater spreads
or receive less favorable net prices, on transactions for the account than would otherwise be
the case. Subject to its duty of best execution, WWM may decline a C lient’s request to
direct brokerage if, in WWM’s sole discretion, such directed brokerage arrangements would
result in additional operational difficulties or violate restrictions imposed by other broker-
dealers.
Item 13. Review of Accounts
WWM reviews investment advisory Client accounts annually to ensure that the current asset
allocation of each Client is consistent with the IPS. Investment models and capital markets are
monitored on a continuous basis.
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For financial planning Clients, WWM develops the financial plan for the Client’s assets subject
to the agreement, (assists the Client in implementing the financial plan,) and then schedules a
review of the plan every 12 months. The review will be conducted by telephone, and will seek to
determine whether the plan needs to be adjusted and whether the Client’s circumstances have
changed materially.
Reviews with all Clients are also conducted in the event of a deposit or withdrawal, the
rebalancing of a portfolio, a material change in the investment environment, a change in the
Client’s goals, time horizons or financial needs, changes in target allocations, or at the Client’s
request.
Item 14. Client Referrals and Other Compensation
This Item requires an investment adviser to provide information relating to its arrangements with
third-parties through which it receives compensation from a third-party for providing investment
management services to its clients or through which it provides compensation to third-parties for
Client referrals. WWM does not receive any economic benefit, directly or indirectly, from any
third party for advice rendered to Clients. WWM does not pay for solicitor or referral services.
Item 15. Custody
Other than the Client authorized direct deductions of fees from accounts held by a qualified
custodian, WWM does not have custody of any Client account, funds or securities. WWM uses
a qualified custodian to maintain Client accounts, funds and securities. The custodian sends
periodic reports to each Client and WWM urges each Client to carefully review those statements.
WWM’s statements may vary from custodial statements based on accounting procedures or
reporting dates.
Item 16. Investment Discretion
WWM usually receives discretionary authority from the Client at the outset of an investment
advisory relationship to select the securities to be bought or sold and the amount of securities to
be bought or sold. Details of this relationship are fully disclosed to the Client before any
advisory relationship begins in the investment advisory agreement the Client signs. The Client
provides WWM with discretionary authority through a limited power of attorney in the
investment advisory agreement and in any contract between the Client and the qualified
custodian. In all cases, however, such discretion is to be exercised in a manner consistent with
the stated investment objectives for the particular Client account.
Investment guidelines and restrictions must be provided to WWM in writing. In most cases, a
client’s investment guidelines and restrictions will be set forth in the IPS, which is attached to
the investment management agreement between WWM and the Client.
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Item 17. Voting Client Securities
WWM will not ask for, and it will not accept, authority to vote proxies on behalf of Clients.
Clients will receive proxies directly from the issuer of the security or the qualified custodian.
Clients may discuss proxies with WWM by calling 484-328-3590.
Item 18. Financial Information
This Item requires investment advisers to provide certain financial information or disclosures
about their financial condition. While WWM charges Clients in advance, WWM does not
require or solicit prepayment of more than $1,200 in fees per Client, six months or more in
advance. Therefore it is not required to include a balance sheet with this Brochure. WWM has
no financial hardships or other conditions that might impair its ability to meet its contractual
obligations to Clients. WWM has not been the subject of a bankruptcy proceeding.
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