Facts |
Facts What Does Accurate Wealth Management Capital, Inc (“AAG”) Do With Your Personal Information? |
Why? |
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. |
What? |
The types of personal information we collect and share depend on the product or service you have with us. This information can include:
When you are no longer our customer, we continue to share your information as described in this notice. |
How? |
All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information, the reasons AWM chooses to share, and whether you can limit this sharing. |
Reasons We Can Share Your Personal Information |
Does AAG share? |
Can you limit this sharing? |
For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus |
Yes |
No |
For our marketing purposes – to offer our products and services to you |
Yes |
No |
For joint marketing with other financial companies |
No |
AWM doesn't share |
For our affiliates’ everyday business purposes – information about your transactions and experiences |
Yes |
No |
For our affiliates’ everyday business purposes – information about your creditworthiness |
No |
AWM doesn't share |
For nonaffiliates to market to you |
No |
AWM doesn't share |
For non-affiliated broker-dealers to supervise registered representatives that are also investment adviser representatives of AWM – client account and transaction information |
Yes |
Yes |
If your investment advisor representative leaves AWM, we may allow her/him to take your contact and account information in order to continue providing services to you |
Yes |
Yes |
What We Do |
|
How does AWM protect my personal information? |
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. Access to personal information is granted to our home-office associates and investment advisory representatives only to provide investments and services to customers or to serve another legitimate business need. |
How does AWM collect my personal information? |
We collect your personal information, for example, when you
We also collect your personal information from others, such as affiliates or other companies. |
Why can’t I limit all sharing? |
Federal law gives you the right to limit only:
State laws and individual companies may give you additional rights to limit sharing. |
What happens when I limit sharing for an account I hold jointly with someone else? |
Your choices will apply to everyone on your account. |
Definitions |
|
Affiliates |
Companies related by common ownership or control. They can be financial and nonfinancial companies.
|
Nonaffiliates |
Companies not related by common ownership or control. They can be financial and nonfinancial companies.
|
Joint Marketing |
A formal agreement between nonaffiliated financial companies that together market financial products or services to you
|
Contact |
|
To Limit Our Sharing |
Call (866) 241-8078 and ask for the Chief Compliance Officer or Email to opt out - gguinta@accuratewealth.com |
Questions? |
Call (866) 241-8078 |
Regulation Best Interest Disclosure Statement
This Regulation Best Interest (“Reg BI”) Disclosure Statement (“Reg BI Statement”) provides information about AAG Capital, Inc. (“AAG,” “us,” “our,” or “we”). If you have any questions about the contents of this Reg BI Statement, please contact us at 866-241-8078 or email us at: gguinta@aagcapital.com. This Reg BI Statement is applicable to retail customers for whom we are acting as broker. If you are not a retail customer and would like additional information regarding the services provided to you by AAG, please contact your AAG Broker (as defined below).
General Information Regarding AAG
AAG is registered with the Securities and Exchange Commission (“SEC”) as a broker-dealer and is a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). AAG’s affiliate, Accurate Wealth Management, LLC, is registered with the SEC as an investment adviser. AAG is directly owned by Accurate Advisory Group, LLC, a Florida-based insurance brokerage.
AAG’s brokerage services, provided by associated persons of AAG (“AAG Brokers”), are limited to the sale of variable annuity insurance products and alternative investments, including tax-advantaged third-party privately offered pooled investment vehicles. As a general matter, other than interests in such investments, AAG and AAG Brokers will not make recommendations with respect to any specific securities.
Overview of this Reg BI Statement
This Reg BI Statement provides information regarding the material facts relating to the scope and terms of our relationship with you, including the capacity in which we and AAG Brokers act; the material fees and costs that apply to your transactions, holdings, and accounts; the type and scope of services we provide, including any material limitations on the securities or investment strategies involving securities we recommend; the basis for and risks associated with our recommendations; and material facts relating to conflicts of interest associated with our recommendations.
For additional information regarding AAG and its brokerage services, or your brokerage account (“Brokerage Account”), please see the Form CRS for AAG at http://www.accurateadvisorygroup.com. The Form CRS must be provided to existing customers when a material change is made to the form, and within 30 days after filing the update with the SEC. You can also request this information from your AAG Broker.
For additional free information regarding AAG and AAG Brokers, including disciplinary events, please visit www.investor.gov and https://brokercheck.finra.org/.
This Reg BI Statement does not apply to advisory services offered by Accurate Wealth Management. For additional information on Accurate Wealth management, please see Accurate Wealth Management’s Form ADV Part 2A brochure at http://www.accurateadvisorygroup.com.
Material Facts About Our Relationship with You – Capacity
Any recommendations regarding your Brokerage Account are made in a broker-dealer capacity.
AAG has no discretionary authority over your Brokerage Account and can only purchase or sell securities or execute investment strategies that you authorize. This means that you, the customer, make the ultimate decision regarding the purchase or sale of securities or other investments or the allocation of assets recommended by us. Accordingly, you, the customer, must approve each transaction prior to execution.
Material Facts About AAG’s Relationship with You – Material Fees and Costs
The following describes the material fees and costs that apply to recommendations made by AAG to you:
- Customers generally enter into account agreements whereby brokerage services are provided by AAG.
- Commissions paid to AAG are charged on a transaction basis
Private investment vehicles: If a customer invests in a privately offered investment vehicle, the customer will purchase the interests of the investment vehicles and they will be held directly with the sponsor. The customer will be subject to the fees and expenses of the investment vehicle, which are disclosed in the applicable offering memorandum or private placement memorandum (the “Offering Documents”), which will be provided to the customer prior to the customer’s subscription to any such investment. If you would like a copy of an Offering Document, please contact your AAG Broker.
Material Facts About AAG’s Relationship with You – Type and Scope of Services
Generally, AAG makes recommendations solely with respect to Variable Annuity products and investment vehicles that have been first vetted through AAG’s diligence process.
AAG does not provide any ongoing or periodic review, follow-up or monitoring. In connection with asset allocation recommendations, AAG will confirm the customer’s investment objectives on at least an annual basis but does not provide any ongoing monitoring of a customer’s accounts or investments.
AAG does not act in the capacity of an investment adviser. If you wish to receive investment advisory services, you can seek the services of Accurate Wealth Management.
AAG does not act with discretion over customers’ accounts assets; the customer makes the decision regarding any purchase or sale of securities, or any asset allocation recommended by AAG. For additional information on the type and scope of brokerage services provided by AAG to you, please see your brokerage agreement with AAG.
Material Limitations
AAG’s recommendations regarding securities are generally limited annuity products and limited private placements of tax advantaged real estate and energy investment opportunities.
AAG only recommends privately offered investment vehicles to customers who are eligible to invest by meeting certain financial sophistication requirements, including status as accredited investors and qualified purchasers under applicable securities laws.
General Basis for Recommendations
AAG seeks to help customers achieve their unique investment objectives and to deliver custom solutions. In designing solutions, AAG and AAG Brokers take the time to understand each customer’s “Investment Profile” (e.g., as applicable, the customer’s age, other investments, financial situation and needs, tax status, short- and long-term investment objectives, investment experience, investment time horizon, liquidity needs, risk tolerance, estate planning needs, generational giving and philanthropic desires, and any other information the customer discloses to AAG or AAG Brokers) in connection with each recommendation. AAG and AAG Brokers work with each customer to recommend investments and, where applicable, asset allocations that align with the needs and financial goals of the retail customer.
Material Risks Associated with Brokerage Recommendations
While AAG will take reasonable care in developing and making recommendations with respect to each retail customer, investments in securities and other financial instruments involve risk, and retail customers can lose some or all their money. All investments and investment strategies involving securities involve risk of loss, including the potential loss of a retail customer’s entire investment, which the retail customer should be prepared to bear. There is no guarantee that any retail customer will meet the customer’s investment goals, or that AAG’s recommended investments or, where applicable, asset allocations will perform as anticipated.
The investment performance and the success of any particular investment or investment strategy can never be predicted or guaranteed, and the value of a customer’s investments will fluctuate due to market conditions and other factors. Investments are subject to various market, liquidity, currency, economic, political and other risks. Past performance of any security or investment strategy is not indicative of future performance.
Customers should consult the offering documents for any security that AAG recommends for a discussion of risks associated with the particular investment. If you would like a copy of any Offering Document prior to purchasing an investment of an investment you may obtain one by contacting your AAG Broker.
In addition to the investment-specific risks associated with investments and investment strategies involving securities, there are other potential risks associated with any relationship with financial intermediaries, such as AAG. For example, as the use of technology increases, AAG may be more susceptible to operational or information security-related risks. A breach in cybersecurity refers to both intentional and unintentional events that may cause AAG to lose proprietary information or operational capacity or suffer data corruption. Cybersecurity breaches of AAG’s or third-party service providers or issuers in which customers and clients invest may also subject AAG to many of the same risks associated with direct cybersecurity breaches. Cybersecurity breaches can cause disruptions and affect business operations, potentially resulting in financial losses, impediments to trading, the inability to transact business, destruction to equipment and systems, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs or additional compliance costs.
Standard of Conduct under Regulation Best Interest
Reg BI requires that AAG and AAG Brokers act in the best interest of the retail customer at the time a recommendation of a security or an investment strategy involving a security is made, without placing the financial or other interest of AAG or the AAG Broker ahead of the interest of the retail customer.
Material Facts Regarding Conflicts of Interest
Reg BI defines a conflict of interest associated with a recommendation as “an interest that might incline a broker, dealer, or a natural person who is an associated person of a broker or dealer — consciously or unconsciously — to make a recommendation that is not disinterested.”
When AAG or an AAG Broker provides you with a recommendation regarding securities or investment strategies involving securities, AAG and the AAG Broker must act in your best interest at the time the recommendation is made without putting their interest ahead of yours. At the same time, the way AAG and AAG Brokers make money and otherwise conduct business creates conflicts with your interests. Where possible, AAG has taken steps to mitigate or eliminate material conflicts of interest associated with recommendations regarding securities and investment strategies involving securities.
AAG Fiduciary Recommendation Disclosure for Covered ERISA and IRA Accounts
Overview
This AAG Fiduciary Recommendation Disclosure for Covered ERISA and IRA Accounts (“AAG Fiduciary Recommendation Disclosure”) provides additional information to employee benefit plans subject to Title I of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and plans subject to Section 4975 of the Internal Revenue Code of 1986, as amended (the “IRC” or the “Code“) in respect of certain recommendations made by AAG Capital. Inc. (“AAG,” “us,” “our,” or “we”) and its wealth advisors or portfolio managers, in their capacity as associated persons of AAG (“AAG Brokers” and such plans, collectively, “Plan Customers”).
Where AAG or an AAG Broker provides individualized investment advice for purposes of ERISA or Section 4975 of the Code when making an AAG Fiduciary Recommendation (as defined below), AAG (and the relevant AAG Broker) is a fiduciary within the meaning of ERISA for those Plan Customers subject to Title I of ERISA, and Section 4975(e)(3) of the Code for those Plan Customers subject to Section 4975 of the Code.
In addition to this AAG Fiduciary Recommendations Disclosure, Plan Customers should also carefully review AAG’s Regulation Best Interest Disclosure Statement for additional disclosure and information related to AAG Fiduciary Recommendations.
Where AAG makes AAG Fiduciary Recommendations to a Plan Customer, it may rely upon one or more exemptions, including, among others, Prohibited Transaction Exemption 2020-02 from rules under Title I of ERISA and/or Section 4975 of the Code, as may be applicable (“PTE 2020-02”), that are intended to regulate conflicts of interests. PTE 2020-02 is designed to permit AAG and AAG Brokers to provide AAG Fiduciary Recommendations in your Best Interest (as defined below) under a fiduciary standard of care (as defined under ERISA and the Code) while adhering to prescribed conditions designed to mitigate conflicts.
AAG Fiduciary Recommendations
From time to time, AAG or an AAG Broker will make recommendations in connection with Plan Customer’s potential investment in a privately offered registered or unregistered investment or investment vehicle, Plan Customer’s risk profile (“Risk Profile”), as applicable, or Plan Customer’s decision to roll over or transfer assets from an account subject to Title I of ERISA or other individual retirement account (“IRA”) to an IRA (“Rollover Decision. AAG Fiduciary Recommendations that may be covered by PTE 2020-2 may be afforded relief under other exemptions from ERISA’s and the Code’s conflict of interest rules. From time to time, AAG and its affiliate may utilize one or more other prohibited transaction exemptions, to the extent they may be necessary or appropriate.
Requirements under PTE 2020-02
The way AAG and AAG Brokers make money creates some conflicts with the interests of Plan Customers, so AAG and AAG Brokers may operate under PTE 2020-02 with respect to AAG Fiduciary Recommendations. PTE 2020-02 requires AAG and AAG Brokers to act in the Best Interest (as defined below) of the Plan Customer, without placing the interest of AAG or the AAG Broker ahead of the interest of the Plan Customer.
Under PTE 2020-02’s provisions, AAG and AAG Brokers must:
- Meet a professional standard of care when making investment recommendations (give prudent advice);
- Never put our financial interests ahead of Plan Customer’s when making recommendations (give loyal advice);
- Avoid misleading statements about conflicts of interest, fees, and investments;
- Follow policies and procedures designed to ensure that we give advice that is in Plan Customer’s best interest;
- Charge no more than is reasonable for our services; and
- Give you basic information about conflicts of interest.
“Best Interest” for this purpose means that, with respect to AAG Fiduciary Recommendations, AAG and the AAG Broker must act in accordance with a standard of prudence as set forth under ERISA based on the investment objectives, risk tolerance, financial circumstances and needs of Plan Customer and that neither AAG nor the AAG Broker may place the interests of AAG, the AAG Broker or other party ahead of the Plan Customer. In addition, neither AAG nor the AAG Broker may make statements to Plan Customer that are materially misleading, and neither AAG nor any AAG Broker will be insulated or relieved of liability that is imposed upon either as a fiduciary under ERISA and the Code, as may be applicable, when making AAG Fiduciary Recommendations. When effecting transactions arising out of AAG Fiduciary Recommendations, AAG and the AAG Broker must seek to obtain best execution in accordance with applicable securities rules. Finally, the compensation AAG and the AAG Broker receive directly or indirectly arising out of any AAG Fiduciary Recommendation must not exceed reasonable compensation under applicable ERISA guidance and related guidance under the Code. Under the exemption, AAG is required to establish, maintain and enforce written policies and procedures prudently designed to ensure satisfaction of these “Impartial Conduct Standards.” PTE 2020-02 also contains additional requirements concerning our compliance. For more information, see https://www.federalregister.gov/documents/2020/12/18/2020-27825/prohibited-transaction-exemption-2020-02-improving-investment- advice-for-workers-and-retirees.
Conflicts of Interest
The way AAG and AAG Brokers make money creates some conflicts with the interests of Plan Customers. For this purpose, a conflict of interest is defined as “an interest that might incline a financial institution or an investment professional– consciously or unconsciously – to make a recommendation that is not in the Best Interest of the Retirement Investor.”
Where possible, AAG has taken steps to mitigate or eliminate material conflicts of interest associated with AAG Fiduciary Recommendations.
For the avoidance of doubt, unless otherwise specifically agreed in writing, when making AAG Fiduciary Recommendations, none of AAG, its affiliates nor any of their respective employees, officers, directors, or agents (including AAG Brokers) is providing investment advice or otherwise acting as a fiduciary under the Investment Advisers Act of 1940, as amended.
Client Relationship Summary ("CRS")
AAG Capital, Inc. (“AAG” or the “Firm”) is registered as a broker-dealer with the U.S. Securities and Exchange Commission (“SEC”) and is a member of Financial Industry Regulatory Authority, Inc. (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). Brokerage and investment advisory services differ, and it is important for the retail investor to understand the differences. Free and simple tools are available to research Firms and financial professionals at Investor.gov/CRS, which also provides educational materials about broker-dealers, investment advisers and investing. It is the responsibility of the FIRM to circulate Form CRS within 30 days to all retail customers after filing with the SEC and / or after material change. In addition, the Firm will recirculate Form CRS to existing customers within 60 days of required amendment(s). WHAT INVESTMENT SERVICES AND ADVICE CAN YOU PROVIDE ME? We offer a limited range of brokerage services to our clients, principally variable annuities and tax-driven private placements. We make recommendations to retail customers concerning such securities. We do not monitor your investments. We do not accept discretionary authority over your account, and you make the ultimate decision regarding the purchase or sale of investments. No minimum account size is required to open or maintain an account for you, although certain products require minimum investments. Further information regarding our brokerage services is available by contacting your representative at 866-241-8078.You should ask the broker you work with the following questions:
Given my financial situation, should I choose a brokerage service? Why or why not
How will you choose investments to recommend to me?
What is your relevant experience, including your licenses, education and other qualification? What do these qualifications mean?
You should ask the broker you work with:
Help me understand how these fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me?
HOW DO YOUR FINANCIAL PROFESSIONALS MAKE MONEY? AAG and its professionals receive compensation from customers or indirectly from the investments a customer makes. This compensation takes the form of an upfront commission, aforementioned fees and/or ongoing trailing compensation paid by mutual fund companies, insurance companies or other issuers of investment products our customers invest in. Typically, AAG receives selling compensation and shares a percentage of the selling compensation with your financial professional. Because the amount of selling compensation charged can vary between different securities and products, this could create an incentive to sell certain investments over others. It could also create an incentive to conduct a higher number of transactions. A Registered Representative’s compensation package typically includes a percentage of the selling compensation described herein, but he/she may also receive salary and other cash or non-cash compensation and benefits that may be tied to the amount revenues they generate. In addition, your financial professional can receive a greater percentage of their sales revenue, based on the total revenue they generate. Accordingly, your sales representative has an incentive to recommend more costly products or recommend additional transactions to obtain a greater percentage of the overall revenues. In addition to the sales compensation described above, the Firm also receives additional compensation from third parties, such as 12b-1 fees. This additional compensation creates an incentive for the Firm to recommend certain investments over others and in some cases to recommend continuing to hold them. The Firm is affiliated with other entities, including Accurate Wealth Management, which is registered with the Securities and Exchange Commission as an Investment Adviser, and with Accurate Advisory Group, Inc., a licensed insurance agency. The Firm and your financial professional are incentivized to refer you to all these affiliates as it generates additional compensation for the Firm and financial professional, directly, or through the enterprise. WHAT ARE YOUR LEGAL OBLIGATIONS TO ME WHEN PROVIDING RECOMMENDATIONS? HOW ELSE DOES YOUR FIRM MAKE MONEY AND WHAT CONFLICTS OF INTEREST DO YOU HAVE? When we provide you with a recommendation, we must act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the recommendations, we provide you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. In making recommendations to you, we will consider alternatives among the limited kinds of products we sell. Here are some examples to help you understand what this means:- We have an incentive to have you make investments since you are charged fees for each investment; you will be charged more if you make more investments. We may receive additional compensation if you continue to hold an investment, which creates an incentive to recommend that you continue to hold an investment.
- We have a direct financial incentive to offer or recommend that you invest in certain investments because the issuer or sponsor of those investments or another third-party has entered into an agreement with us in which we are paid a cash fee and/or receive non-cash compensation related to the investments you make.
You should ask your broker:
How might your conflicts of interest affect me, and how will you address them?
DO YOU OR YOUR FINANCIAL PROFESSIONAL HAVE LEGAL OR DISCIPLINARY HISTORY? Yes. Customers of the Firm may visit Investor.gov for a free and simple search tool to research our Firm and our financial professionals. To report a problem to the SEC, visit Investor.gov or call the SEC’s toll-free investor assistance line at (800) 732-0330. To report a problem to FINRA, call 301-590-6500. If you have a problem with your investments, investment account or a financial professional, contact us in writing at AAG Capital Inc., 2211 Ashley Oaks Circle, Wesley Chapel, FL 33544.You should ask your broker: As a financial professional, do you have any disciplinary history? For what type of conduct?
Additional Information: You can find additional information about our brokerage services. You can also request an up-to-date copy of this relationship summary from your broker or by calling 866-241-8078.
You should ask your broker: Who is my primary contact person? Is he or she a representative of an investment adviser or a broker-dealer? Who can I talk to if I have concerns about how this person is treating me?
This publication should not be utilized as a substitute for professional advice in specific situations. If legal, medical, accounting, financial, consulting, coaching or other professional advice is required, the services of the appropriate professional should be sought. Neither the author nor the publisher may be held liable in any way for any interpretation or use of the information in this publication.
The author will make recommendations for solutions for you to explore that are not his own. Any recommendation is always based on the author’s research and experience.The information contained herein is accurate to the best of the publisher’s and author’s knowledge; however, the publisher and author can accept no responsibility for the accuracy or completeness of such information or for loss or damage caused by any use thereof.
Unless otherwise noted, the source for all data cited regarding financial advisors in this report is CEG Worldwide, LLC. The source for all data cited regarding business owners and other professionals is AES Nation, LLC.
Item 1: Introduction
ACCURATE WEALTH MANAGEMENT, LLC is an investment adviser registered with the Securities and Exchange Commission offering advisory accounts and services. Brokerage and investment advisory services and fees differ, and it is important that you understand the differences. This document gives you a summary of the types of services and fees we offer. Please visit www.investor.gov/CRS for free, simple tools to research firms and for educational materials about broker-dealers, investment advisers, and investingItem 2: Relationships and Service
Questions to ask us: Given my financial situation, should I choose an investment advisory service? Why or why not? How will you choose investments to recommend to me? What is your relevant experience, including your licenses, education and other qualifications? What do these qualifications mean? What investment services and advice can you provide me? Our firm primarily offers the following investment advisory services to retail clients: portfolio management in a wrap fee program or outside a wrap fee program (we review your portfolio, investment strategy, and investments); financial planning (we assess your financial situation and provide advice to meet your goals). Each investment adviser representative periodically reviews the general holdings of his/her client accounts. Each investment adviser representative also meets with clients on an annual basis to review their financial situations. Our firm has discretionary management without any material limitations. We do not limit the types of investments that we recommend, although you may propose restrictions in writing, which we will attempt to honor. Our firm does not have a minimum account size. Please also see our Form ADV Part 2A (“Brochure”), specifically Items 4 & 7. We periodically review your investments but do not monitor your account.Item 3: Relationships and Service
Questions to ask us: Help me understand how these fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me? How might your conflicts of interest affect me, and how will you address them? What fees will I pay? Our fees vary depending on the services you receive. Additionally, the amount of assets in your account affects our advisory fee; the more assets you have in your advisory account, the more you will pay us, and we have an incentive to increase those assets in order to increase our fee. In some cases, we charge a performance fee based on the increase in value of your investments. This creates a conflict of interest because we have an incentive to take risks to increase performance in order to generate additional fees. This risk is addressed by supervisory review to verify that investments for your account are in line with the information you have given us in regard to your investment objectives and risk tolerance. For hourly fee arrangements, each additional hour (or portion therefore) we spend working for you would increase the advisory fee. Our fixed fee arrangements are based on the amount of work we expect to perform for you, so material changes in that amount of work will affect the advisory fee we quote you. Except in the case of accounts with performance based fees, annualized fees are billed quarterly in advance, based on the value of the account(s) on the last day of the previous quarter. Performance based fees are more fully described in our Brochure. Third Party Costs: Some investments (e.g., mutual funds, variable annuities, etc.) impose additional fees (e.g., transactional fees and product-level fees) that reduce the value of your investment over time. You will also pay fees to a custodian that will hold your assets. For the wrap fee program, you will not pay additional transaction fees and thus our advisory fee is higher than if you paid transaction fees separately. You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying. Please also see our Brochure for additional details. What are your legal obligations to me when acting as my investment adviser? How else does your firm make money and what conflicts of interest do you have? When we act as your investment adviser, we are held to a fiduciary standard and have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the investment advice we provide you. Here are some examples to help you understand what this means: as disclosed above, the more assets you have in your advisory account, the more you will pay us and thus we have an incentive to increase those assets in order to increase our fee; we have an incentive to take greater risk in a performance fee based account; we have an incentive to minimize transactions in a wrap fee account, since we absorb the transaction costs. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. How do your financial professionals make money? Primarily, we and our financial professionals benefit from the advisory services we provide to you because of the advisory fees we receive from you. This compensation may vary based on different factors, such as those listed above in this Item. Please also see Item 10 of our Brochure for additional details.Item 4: Disciplinary History
Questions to ask us: As a financial professional, do you have any disciplinary history? For what type of conduct? Do you or your financial professionals have legal or disciplinary history? Yes. Visit https://www.investor.gov/ for a free, simple search tool to research us and our financial professionalsItem 5: Additional Information
Questions to ask us: Who is my primary contact person? Is he or she a representative of an investment adviser or a broker-dealer? Who can I talk to if I have concerns about how this person is treating me? For additional information on our advisory services, see our Brochure available at https://adviserinfo.sec.gov/firm/summary/298137 and any individual brochure supplement your representative provides. If you have any questions, or want another copy of this Client Relationship Summary, then please contact us at 813-994-0984.Exibit A - Material Changes to Client Relationship Summary
- Item 3 has been amended to describe our use of performance based fees for certain accounts
Accurate Wealth Management, LLC Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure
This wrap fee program brochure provides information about the qualifications and business practices of Accurate Wealth Management, LLC. If you have any questions about the contents of this brochure, please contact us at (813) 994-0984 or by email at: pharris@accuratewealth.com The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority Additional information about Accurate Wealth Management, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Accurate Wealth Management, LLC’s CRD number is: 298137. 2211 Ashley Oaks Circle, Wesley Chapel, FL 33544 (813) 994-0984 www.accurateadvisorygroup.com Registration as an investment adviser does not imply a certain level of skill or training.Item 2: Material Changes
Since our last annual report on Form ADV, we have added a compensated solicitor and have agreed to performance-based fees with respect to certain accounts.Item 4: Services, Fees and Compensation
Accurate Wealth Management, LLC (hereinafter “AWM”) provides portfolio management to clients under a wrap fee program, as described herein, as sponsor and portfolio manager. AWM is a registered investment adviser. Registration of an investment adviser does not imply any level of skill or training. Additional information about Accurate Wealth Management, LLC is available on the SEC’s website www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Accurate Wealth Management, LLC’s CRD number is 29813. Portfolio management fees are withdrawn directly from the client’s accounts with each client’s written authorization. Fees are paid quarterly in advance except where fees are paid annually in arrears for performance fee based accounts. The advisory fee is calculated using the value of the assets on the last business day of the prior billing period. Refunds for any fees paid in advance but not yet earned will be refunded on a prorated basis and returned within fourteen days to the client via check or return deposit back into the client’s account. For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee rate by 365.) For a description of performance based fees, please see below. Clients may terminate the agreement without penalty and receive a full refund of AWM’s fees, within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 30 days written notice. Services, Fees and Compensation Fees are generally calculated based on assets under management and will not exceed 2.5 Fees are negotiable The Adviser may receive performance-based fees with respect to certain strategies. The Adviser manages both accounts that are charged a performance fee and accounts that are not charged a performance fee. The Adviser may have an incentive to favor accounts that are charged a performance fee; however, the Adviser believes this does not create a conflict of interest because accounts that are charged a performance fee are not using the same strategy as those that are not charged a performance fee. Charging a performance fee may create an incentive for the Adviser to make investments that are riskier or more speculative than would be the case in the absence of a fee based on the performance of the Account. The following are the fees applicable where we charge a performance-based fee: An annualized percentage of the net liquidation value of the portfolio is charged. A 20% performance fee is charged annually in arrears on a high-water mark basis. The term “high-water mark” means the highest value that an account has achieved on previous performance fee calculation dates. Performance-based fees are only payable if an accounts performance exceeds the high-water mark. A high-water mark ensures that if a manager loses money over a period, they must achieve investment returns above the high-water mark before receiving a performance-based fee. We share the performance-based fee with the Third Party Advise. The wrap fee program may cost the client more or less than purchasing such services separately. There are several factors that bear upon the relative cost of the program, including the trading activity in the client’s account, the adviser’s ability to aggregate trades, and the cost of the services if provided separately (which in turn depends on the prices and specific services offered by different providers). AWM will pay third party fees (i.e., custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.) for wrap fee portfolio management accounts. AWM will charge clients one fee and pay all transaction fees using the fee collected from the client. Accounts participating in the wrap fee program are not charged higher advisory fees based on trading activity, but clients should be aware that AWM has an incentive to limit trading activities for those accounts, since the firm absorbs those transaction costs. Certain other fees are not included in the wrap fee and are paid for separately by the client. These include, but are not limited to, margin costs, charges imposed directly by a mutual fund or exchange traded fund, fees associated with “step out” transactions if the account uses different custodians or broker-dealers, 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. Tax and trust service fees are not included. AWM uses the brokerage and custody services of Schwab Advisor Services, a division of Charles Schwab & Co., an unrelated registered broker-dealer and member of FINRA/SIPC. Schwab has eliminated commissions for online trades of 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. 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 and advisory services separately. To see what you would pay for transactions in a non-wrap account please refer to Schwab’s most recent pricing schedules available at schwab.com/aspricingguide. Our firm receives certain economic benefits from custodians in the form of the support products and services made available to our firm and other independent investment advisors that have their clients maintain accounts at the custodians. These products and services, how they benefit AWM and the related conflicts of interest are described in our Firm brochure (see Item 14 of the Firm brochure). The availability of such products and services is not based on our firm giving particular investment advice, such as buying particular securities for our clients. Neither AWM, nor any representatives of AWM receive any additional compensation beyond advisory fees for the participation of clients in the wrap fee program. However, compensation received may be more than what would have been received if client paid separately for investment advice, brokerage, and other services. Therefore, AWM may have a financial incentive to recommend the wrap fee program to clients.Item 5: Account Requirement and Types of Client
We offer our services to individuals, high net worth individuals, pension and profit sharing plans, charities, corporations, and other business entities. We do not require a minimum account size or place any restrictions on opening an account.Item 6: Portfolio Manager Selection and Evaluation
AWM will select and periodically review outside Third Party Advisers for management of this wrap fee program based upon criteria including historical performance, lack of disciplinary history, management stability and depth, and ability to match our asset allocation needs. AWM will use industry standards to calculate Third Party Advisers performance. AWM reviews the performance information to determine and verify its accuracy and compliance with presentation standards by utilizing vendor software and conducting a supervisory review of sample client account. AWM and its personnel serve as the portfolio managers for all wrap fee program account. AWM offers ongoing wrap fee portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. AWM creates a suitability profile for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following:- Determine investment strategy
- Asset selection
- Assessment of risk tolerance
- Personal investment policy
- Asset allocation
- Periodic portfolio review
Services Limited to Specific Types of Investment
AWM generally limits its investment advice to mutual funds, equities, bonds, fixed income, debt securities, ETFs, real estate, hedge funds, REITs, insurance products including annuities, private placements, and government securities. AWM may use other securities as well to help diversify a portfolio when applicable.Wrap Fee Programs
As discussed herein, AWM acts as manager for this wrap fee program. AWM manages the investments in the wrap fee program in the same way in which it manages non-wrap fee accounts.Amounts Under Management
AWM has the following assets under management.Item 7: Client Information Provided to Portfolio Manager
All client information material to managing the portfolio (including basic information, risk tolerance, sophistication level, and income level) is gathered by the Adviser in its capacity as portfolio manager and is updated periodically and in the event of material change.Item 8: Client Contact with Portfolio Manager
AWM does not restrict clients from contacting portfolio managerItem 9: Additional Information Manager
Addressed in Firm brochure.Item 10: Requirements For State Registered Advisers
Not applicable.Accurate Wealth Management, LLC Part 2A of Form ADV: Firm Brochure March 29, 2023
This brochure provides information about the qualifications and business practices Accurate Wealth Management, LLC. If you have any questions about the contents of this brochure, please contact us at (813)994-0984. 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 Accurate Wealth Management, LLC is a registered investment adviser. Registration of an investment adviser does not imply any level of skill or training. Additional information about Accurate Wealth Management, LLC is available on the SEC’s website www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Accurate Wealth Management, LLC’s CRD number is 298137. 2211 Ashley Oaks Circle, Wesley Chapel, FL 33544 (813) 994-0984 pharris@accuratewealth.com www.accurateadvisorygroup.comItem 2: Material Changes
Since our last annual report on Form ADV, we have added a compensated solicitor and have agreed to performance based fees with respect to certain accounts.Item 4: Advisory Business
Ownership/Advisory History Accurate Wealth Management, LLC (“We” or “AWM”) was formed in July 2014. We are a Florida Limited Liability Company registered with the United States Securities and Exchange Commission. Our Owner is Accurate Advisory Group, LLC, a Florida limited liability company owned by Konstantinos “Gus” Gotsis, Paul J. O’Grady and Robert Leone. Gregg Guinta is the firm’s Chief Executive Officer and Patrick Harris is the firm’s Chief Compliance Officer. Advisory Services Offered Before we enter into an Adviser-Client relationship, we may offer a complimentary general consultation to discuss services available, give a prospective client time to review services desired and determine whether a relationship might benefit the client. Investment advisory services begin only after we and the client formalize the relationship with a properly executed agreement. We offer the following services to our clients. Financial Planning We create a written financial plan that typically focuses on one or more specific areas such as financial and cash management, risk management, financial issues relating to divorce or death of a family member, tax issues, retirement planning, educational funding, goal setting, or other needs identified by the client or by our review of the client’s financial circumstances. Through discussion with the client and/or questionnaires, we will collect pertinent data, identify goals, objectives, financial concerns, and potential solutions. We will present the client with a written analysis. Following the conclusion of the consulting services, we may make recommendations regarding implementation of the financial strategies discussed. Portfolio Management Service We manage individualized portfolios for our clients on a discretionary basis. We work with each client to formulate an individualized portfolio based upon his/her objectives, time frame, risk parameters and other investment considerations. We use marketable securities that may include mutual funds, exchange traded funds, bonds, common stock (equities), structured notes, and options including covered calls and treasury bonds. (Additional information about securities used and their risks can be found under Item 8.) Our investment philosophy is to use principles of value, safety, and quality to seek investment opportunities. We place heavy emphasis on risk control, believing that avoiding losses allows appreciation potential of investments to be realized. Fees for portfolio management services will be based on a percentage of the assets under management. Our maximum annual management fee is 2.50%. The management fee is calculated, accrued and due quarterly in advance, except in the case where performance-based fees are charged. The annual fee is negotiable. A client may aggregate accounts to negotiate a lower fee. The pro-rated first quarter’s management fee will be calculated on the Account’s initial value as reported by its custodian. Thereafter, the periodic fee will be based upon the previous quarter-end Account value as reported by the client’s custodian. Our fees are separate and distinct from any brokerage and custodian fees or expenses. These fees and expenses may include brokerage commissions, transaction fees, and other related costs and expenses. Additionally, clients may incur certain charges imposed by custodians, brokers, third party investment and other third parties such as fees charged by managers, custodial fees, 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. Mutual funds and exchange traded funds also charge internal management fees, as disclosed in a fund’s prospectus, which are separate and distinct from the firm’s fee. Selection of Third Party Advisors: After an initial meeting with the client or when deemed appropriate, we may recommend the services of a third-party investment adviser (“Third Party Adviser”) within or outside a wrap fee program. The recommendation will depend on the client’s circumstances, goals and objectives, strategy desired, account size, risk tolerance, or other factors. We work with each client to determine which Third Party Adviser may be appropriate. Clients are never obligated to use a recommended Third Party Adviser. We will review Third Party Advisers prior to making a recommendation to the client. We consider the following factors during this review: fees, reputation, performance, financial strength, management, price, reporting capabilities, client’s financial situation, client’s goals, client’s needs, and client’s investment objectives. After our review we will present the client with one or more recommendations. Under these arrangements, the Third-Party Adviser is responsible for portfolio management, best execution, portfolio reporting, trading,trade error resolution, and custodian reconciliations. We maintain our relationship with the client by periodically reviewing the status of the client’s accounts with the Third- Party Adviser and making on-going recommendations about the Third-Party Adviser, usually meeting with the client either in person or by telephone on an annual basis. All questions regarding the Third-Party Adviser’s services and performance will be directed to AWM. Because the compensation required by the Third-Party Adviser may differ depending on the agreement with each Third-Party Adviser, we may have an incentive to recommend one Third Party Adviser over another if the compensation arrangements are more favorable to AWM. We address this conflict by insuring that client assets are invested in accordance with their investment objectives and risk tolerance. Clients who are referred to Third Party Advisers will receive full disclosure, including services rendered and fee schedules, at the time of the referral, by delivery of a copy of the relevant Third-Party Adviser’s Form ADV Part 2A or equivalent disclosure document before receiving investment advisory services from the Third-Party Adviser. In addition, if the investment program recommended to a client is a wrap fee program the client will receive Appendix 1 or equivalent wrap fee brochure provided by the sponsor of the program. Tailored Service We tailor all of our services to the client’s stated goals, needs and objectives. For our portfolio management service clients, we allow them to impose restrictions on investment in certain securities or types of securities. All restrictions must be presented to AWM in writing. Wrap Program We sponsor and act as portfolio manager for a wrap fee program for which we may use Third Party Advisers. We manage the wrap fee program in the same manner that we manage the non-wrap accounts, and we receive a portion of the wrap fee for our services. Client Assets Managed Accurate Wealth Management, LLC has the following assets under management.Item 5: Fees and Compensation
Compensation for our Advisory Service This section provides additional details regarding our Firm’s services along with descriptions of each service’s fees and compensation arrangements. It should be noted that lower fees for comparable service may be available from other sources. The exact fees and other terms will be described in the agreement between you and AWM. The maximum annual fee charged for asset management will not exceed 2.50%. Fees to be assessed will be described in the advisory agreement to be signed by the client and our Firm. Fees of Third Party Advisers will be disclosed as explained below. Except in the case of accounts with performance based fees, annualized fees are billed quarterly in advance based on the value of the account(s) on the last day of the previous quarter. Fees for the initial quarter of management shall be prorated. Fees are negotiable and will be deducted from client account(s). For those clients whose fees are deducted by us:- a. Clients will provide authorization permitting our Firm to be directly paid;
- b. Our Firm will send an invoice directly to the custodian; and
- c. The client’s independent custodian sends statements at least quarterly showing the market values for each security included in the account and all account disbursements, including the amount of the advisory fees paid to our Firm
Item 6: Performance-Based Fees and Side by Side Management
See discussion of Performance Based Portfolio Management Fees in Item 5 above We do not provide side-by-side management services.Item 7: Types of Clients
We offer our services to individuals, high net worth individuals, high net worth individuals, pension and profit sharing plans, charities,corporations, and other business entities. We do not require a minimum account size or place any restrictions on opening an account.Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis and Investment Strategies When we manage a client’s portfolio, we start with an individualized asset allocation method. When deciding on the asset allocation for a client, we take into account the client’s risk tolerance, goals, investment objectives and other data gathered during the client meetings. Asset Allocation is an investment strategy that aims to balance risk and reward by apportioning a portfolio’s assets according to an individual’s goals, risk tolerance and investment horizon among various asset classes. The asset classes typically include equities, fixed Income, and cash and equivalents. Each class has different levels of risk and return, so each will behave differently over time. Recommended Securities and Investment Risks We may use several types of securities in our clients’ accounts. These securities may include, but are not limited to, the following: Stocks; Bonds; Exchange Traded Funds; Mutual Funds; Government Debt instruments Including Treasury Bills and Municipal securities; Traded Real Estate Investment Trusts; Structured Notes; Money Market Funds and Cash. All investments bear different types and degrees of risk and investing in securities involves risk of loss that clients should be prepared to bear While we use investment strategies that are designed to provide appropriate investment diversification, some investments have significantly greater risks than others. Obtaining higher rates of return on investments entails accepting higher levels of risk. Recommended investment strategies seek to balance risks and rewards to achieve investment objectives. Clients should feel free to ask questions about risks they do not understand. We would be pleased to answer all questions.Facts |
Facts What Does AAG Capital, Inc (“AAG”) Do With Your Personal Information? |
Why? |
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. |
What? |
The types of personal information we collect and share depend on the product or service you have with us. This information can include:
When you are no longer our customer, we continue to share your information as described in this notice. |
How? |
All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information, the reasons AAG chooses to share, and whether you can limit this sharing. |
Reasons We Can Share Your Personal Information |
Does AAG share? |
Can you limit this sharing? |
For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus |
Yes |
No |
For our marketing purposes – to offer our products and services to you |
Yes |
No |
For joint marketing with other financial companies |
No |
AAG doesn't share |
For our affiliates’ everyday business purposes – information about your transactions and experiences |
Yes |
No |
For our affiliates’ everyday business purposes – information about your creditworthiness |
No |
AAG doesn't share |
For nonaffiliates to market to you |
No |
AAG doesn't share |
For non-affiliated broker-dealers to supervise registered representatives that are also investment adviser representatives of AAG – client account and transaction information |
Yes |
Yes |
If your investment advisor representative leaves AAG, we may allow her/him to take your contact and account information in order to continue providing services to you |
Yes |
Yes |
What We Do |
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How does AAG protect my personal information? |
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. Access to personal information is granted to our home-office associates and investment advisory representatives only to provide investments and services to customers or to serve another legitimate business need. |
How does AAG collect my personal information? |
We collect your personal information, for example, when you
We also collect your personal information from others, such as affiliates or other companies. |
Why can’t I limit all sharing? |
Federal law gives you the right to limit only:
State laws and individual companies may give you additional rights to limit sharing. |
What happens when I limit sharing for an account I hold jointly with someone else? |
Your choices will apply to everyone on your account. |
Definitions |
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Affiliates |
Companies related by common ownership or control. They can be financial and nonfinancial companies.
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Nonaffiliates |
Companies not related by common ownership or control. They can be financial and nonfinancial companies.
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Joint Marketing |
A formal agreement between nonaffiliated financial companies that together market financial products or services to you
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Contact |
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To Limit Our Sharing |
Call (866) 241-8078 and ask for the Chief Compliance Officer or Email to opt out - gguinta@accuratewealth.com |
Questions? |
Call (866) 241-8078 |