Singh Private Wealth Management
ITEM 1 Cover Page
Form ADV Part 2A
Firm Brochure
March 21, 2024
This Brochure provides information about the qualifications and business practices of Singh Private Wealth Management LLC. If you have any questions about the contents of this Brochure, please contact us at 480-420-4824, or via e-mail at raman@singhpwm.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.
Singh Private Wealth Management LLC is a registered investment advisory firm. Registration of an investment advisory firm does not imply a particular level of skill or training.
Additional information about Singh Private Wealth Management LLC is also available on the SEC’s website at www.adviserinfo.sec.gov.
Singh Private Wealth Management LLC
IARD# 326033
3829 N 4th Street
Phoenix, AZ 85012
480-420-4824
raman@singhpwm.com
ITEM 2 Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of our Firm Brochure. This Item discusses only specific material changes made to this Brochure and provides our clients with a summary of such changes.
Material Changes since the Last Update
Singh Private Wealth Management LLC is a newly registered investment advisory firm in 2023.
Full Brochure and Additional Information
Full Brochure and additional information about Singh Private Wealth Management LLC are available via the SEC’s website www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons affiliated with us who are registered or are required to be registered as investment adviser representatives (“IAR”).
ITEM 3 Table of Contents
ITEM 5 Fees and Compensation. 5
ITEM 6 Performance-Based Fees and Side-By-Side Management 7
ITEM 8 Methods of Analysis, Investment Strategies, and Risk of Loss 8
ITEM 9 Disciplinary Information. 10
ITEM 10 Other Financial Activities and Affiliations 10
ITEM 11 Code of Ethics, Participation in Client Transactions and Personal Trading. 11
ITEM 12 Brokerage Practices 11
ITEM 14 Client Referrals and Other Compensation. 15
ITEM 16 Investment Discretion. 16
ITEM 17 Voting Client Securities 17
ITEM 18 Financial Information. 17
ITEM 19 Requirements for State-Registered Advisers 17
ITEM 4 Advisory Business
Firm Information
Singh Private Wealth Management LLC (“Singh PWM,” “we,” “us,” “our”), formed in March 2023, is a registered investment advisory firm located in Phoenix, AZ. We have been a registered investment advisory firm since June 2023.
Principal Owners
Singh PWM is owned and controlled by Raman Singh, its Managing Member and Chief Compliance Officer.
Investment Advisory Services
Asset Management Services:
We provide asset management services in which we manage your custodial accounts and provide you with continuous and ongoing supervision of your custodial accounts. Our services provide additional investment opportunities among stocks, bonds, mutual funds, exchange-traded funds (ETFs), Real Estate Investment Trusts (REITs), options, and additional securities.
Financial Planning and Consulting Services:
We provide various financial planning and consulting services that find ways to help you understand your overall financial situation and help you set financial objectives. We accomplish this by helping you review your financial goals, tax planning strategies, asset allocation, risk management, retirement planning, and other areas and objectives such as budgeting, education planning, cash flow planning, charitable planning, lines of credit analysis, insurance analysis, business financial planning, mortgage/debt analysis, and real estate analysis. Generally, such financial planning and consulting services will involve preparing a financial plan or rendering a financial consultation based on your financial goals and objectives. We will summarize our services to you in a written plan, which will typically include general recommendations for a course of action or specific actions to be taken by you. Implementation of the recommendations will be at your discretion.
Ongoing Financial Planning and Consulting Services
Upon completion of the client’s financial plan or consulting engagement, we will revisit all or some of the following areas of analysis: financial goals, tax planning strategies, asset allocation, risk management, retirement planning, and other areas and objectives such as budgeting, education planning, cash flow planning, charitable planning, lines of credit analysis, insurance analysis, business financial planning, mortgage/debt analysis, and real estate analysis throughout the course of a year via scheduled meetings, calls, or follow-up emails to ensure that the initial recommendations in the financial plan or consulting engagement are implemented or to make adjustments to the Client’s financial plan and/or the Client’s objectives.
Tailored Investment Advisory Services and Restrictions
Singh PWM offers the same suite of services to all our clients; however, specific recommendations and their implementation are dependent upon the individual client’s current financial situation, such as income, net worth, and risk tolerance levels.
On a case-by-case basis, our clients can impose restrictions on investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent us from properly servicing the client’s account, or if the restrictions would require us to deviate from our standard suite of services, we reserve the right to end the relationship.
We can request additional information and documentation, such as current investments, tax returns, insurance policies, and estate plans. We will discuss your investment objectives, needs, and goals, but you must inform us of any changes. Unless directed by you, we do not independently verify any information provided to us by you or your attorney, accountant, or other professionals.
Wrap Fee Programs
Singh PWM does not participate in, recommend, or offer wrap fee programs.
Assets under Management
Singh PWM is a newly registered investment advisory firm with the state of Arizona and currently does not have any assets under management.
ITEM 5 Fees and Compensation
Annual Fees for Advisory Services
Singh PWM is compensated for providing asset management services by charging a negotiable fee based on the total assets under management. The fees and billing will be pre-determined in writing in the Investment Advisory Agreement executed by you and Singh PWM.
The fees charged for financial planning services are negotiable and vary depending on the complexity of the process undertaken, the types of issues addressed, the scope of services provided, and the frequency with which the services are rendered. All fees are agreed upon before entering the Financial Planning and Consulting Agreement you sign.
The below ranges are the standard fee ranges that are typically charged. We may waive the agreed-upon financial planning fees if you engage our asset management services.
Financial Planning and Consulting Fee Schedule
Hourly: $250 per hour
Fixed Fee: $2,000-$6,000
Ongoing Annual Planning Fee: Up to $12,000
Passive Planner Rate: $60 Per month
On-Going Financial Planning Fee
Tier Level
Initial Plan Fee: $500
Single Person Monthly Fee: $250 Per Month
Initial Plan Fee: $500
Married/Couples Monthly Fee: $416Per Month
Add On Services
Stock Options Planning: $1,000 Per Year
Business Cash Flow Planning: $1,500 Per Year
Asset Management Fee Schedule
$0 - $250,000: 1.00%
$250,001-$500,000: 0.85%
$500,001 - $1,000,000: 0.75%
$1,000,001+: 0.50%
Fee Billing & Payment
Our asset management fees are annual fees and are negotiable. Asset management fees are paid quarterly in arrears. Payments are due on the first day of the calendar quarter and are based on the account’s asset value as of the last business day of the prior calendar quarter multiplied by the applicable annual rate and divided by four (4). The fee for the prior quarter is billed and payable within ten (10) days after the end of the prior quarter. We will deduct our asset management fee only when in receipt of your written authorization by executing an investment advisory agreement permitting the fees to be paid directly from your account. We will send a copy of your invoice to the custodian at the same time that we send a copy to you. The qualified custodian will deliver an account statement to you at least quarterly, which will show all disbursements from your account. We urge you to review all statements for accuracy. Your account at the custodian can also be charged for certain additional assets managed for you by us but not held by the custodian (i.e., variable annuities, mutual funds, 401(k)s).
The Initial Plan Fee encompasses the expenses associated with onboarding procedures, granting access to the technological infrastructure, conducting preliminary planning analysis, and identifying the scope of planning work.
Financial planning and consulting fees are assessed on an hourly basis, as a one-time project fee, or as an annual fee payable monthly, quarterly, or semi-annually. Clients who choose to pay quarterly or semi-annually will receive a lower rate. If the client chooses to engage in ongoing financial planning only with no assets under management, the minimum annual fee is $2,500. If the client's income is greater $250k annually, the minimum fee will be 1% of their income. An estimate for total hours will be determined at the start of the relationship in order to determine whether hourly planning or a project-based plan is in the Client’s best interest. Hourly fees will be invoiced upon completion of the financial plan or the rendering of consulting services with a thirty (30) day written notice. For one-time projects, the Client agrees to pay the total fee upon signing the Financial Planning and Consulting Agreement. For ongoing financial planning or consulting services, the Client agrees to pay an annual fee paid out monthly, quarterly, or semi-annually in advance. Clients who choose to pay monthly will pay a slightly higher premium. We will not require a fee of $500 or more to be paid six months or more in advance. Financial planning and consulting fees are paid via check or by direct invoicing via an electronic payment processor.
You are responsible for all third-party fees (i.e., custodian fees, mutual fund fees, transaction fees, etc.). These fees are separate and distinct from the fees and expenses charged by Singh PWM.
Termination of Agreement
Either party can terminate the agreement by providing 30-day advance written notice. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable up to and including the effective date of termination.
Notwithstanding the above, if we do not deliver the appropriate disclosure statement to you at least 48 hours prior to you entering into any written or oral advisory contract with us, then you have the right to terminate the contract without penalty within five (5) business days after entering into the contract.
Other Expenses and Fees
The fees discussed above include payment solely for the investment advisory services provided by us and are separate from certain fees or charges that are imposed by third parties in connection with investments made on your behalf for your account. Third-party fees can include markdowns, markups, brokerage commissions, other transaction costs, and/or custodial fees.
All fees paid to us for asset management services are separate from the expenses charged by exchange-traded funds and mutual funds to their shareholders. These fees and expenses will be used to pay management fees for the funds, other fund expenses, account administration, and a possible distribution fee. Exchanged traded funds and mutual funds can be invested in directly by you without our services. However, you would not receive our services to assist you in determining which products or services are most suitable for your financial situation and objectives. You should review both the fees we charge and the fees charged by the fund(s) to understand the total fees to be paid fully.
Please refer to Item 12 of this brochure for a more detailed explanation of brokerage practices.
ITEM 6 Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees, which are fees based on a share of capital gains on or capital appreciation of your assets.
ITEM 7 Types of Clients
We provide our investment advisory services to:
- Individuals
- High Net Worth Individuals
- Non Profit Organizations
- Corporations
- Other business entities
We do not have a minimum account size for our asset management services.
ITEM 8 Methods of Analysis, Investment Strategies, and Risk of Loss
Methods of Analysis
We use various methods of analysis and investment strategies, including the following:
Fundamental Analysis – We evaluate economic and financial factors to determine if a security can be underpriced, overpriced, or fairly priced. This method entails assessing a security by attempting to determine its intrinsic value by examining related financial, economic, and other qualitative and quantitative factors. Fundamental analysis requires an in-depth look at all factors that can affect the security's value, from macroeconomic factors (like the overall economy and industry conditions) to individually specific factors (like the financial situation and management of companies). The overall objective of performing the fundamental analysis is to determine a value that an investor can use to determine what sort of position to take with that security. This method of security analysis is contrary to technical analysis. Fundamental analysis involves using real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks, this method of valuation can be used for just about any type of security.
Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Therefore, unforeseen market conditions and/or company developments can result in significant price fluctuations that can lead to investor losses.
Modern Portfolio Theory - Modern portfolio theory (MPT) is a risk-averse theory that involves the construction of portfolios to maximize and optimize expected return based on a given level of market risk, emphasizing that risk is an inherent part of higher reward. According to the theory, it's possible to construct an "efficient frontier" of optimal portfolios offering the maximum possible expected return for a given level of risk.
MPT tries to understand the market as a whole and measure market risk in an attempt to reduce the inherent risks of investing in the market. However, with every financial investment strategy, there is a risk of a loss of principal. Not every investment decision will be profitable, and there can be no guarantee of any level of performance.
Investment Strategies
When formulating investment advice or managing client assets, we will use the following investment strategies. There are inherent risks associated with each of these strategies.
Long-Term Strategy - A long-term strategy cannot take advantage of short-term gains or can experience more volatility over the life of the portfolio.
Short-Term Strategy – A short-term strategy involves the purchase of securities with the idea of selling them within a relatively short time, typically a year or less. This strategy is done in an attempt to take advantage of conditions that result in market fluctuations in the securities purchased.
Income Strategy – An income strategy will seek to maximize income relative to a client’s risk profile and is pursued typically to provide a steady stream of income that can either be reinvested or be used at the Client’s discretion. An income strategy generally utilizes fixed income products that are subject to interest rate risk, prepayment risk, market risk, and, in the case of bonds issued by municipalities and corporations, depending on the type of bond, the potential of default risk.
Hedging Strategy – A hedging strategy uses certain instruments such as options and certain ETFs to limit or reduce investment risk; however, this strategy can also be expected to limit or reduce the potential for profit or result in losses. Certain hedging transactions can involve the use of leverage, which could result in losses exceeding the amount committed in the transaction.
Your accounts are managed separately with your underlying investment strategies, restrictions, or investment limitations defined within the investment management agreement.
Potential Risks
Investing involves different levels of risk that can result in loss of any profits and/or principal you have not realized. We manage your account in a manner consistent with your pre-determined risk tolerance and suitability profile. However, we cannot guarantee that our efforts will be successful. Investing in securities involves the risk of loss that clients should be prepared to bear.
Investing involves the assumption of risk, including:
Financial Risk: which is the risk that the companies we recommend to you perform poorly, which affects the price of your investment.
Market Risk: which is the risk that the stock market will decline, decreasing the value of the securities we recommend to you with it.
Inflation Risk: which is the risk that the rate of price increases in the economy deteriorates the returns associated with the stock.
Political and Governmental Risk: which is the risk that the value of your investment will is affected by the introduction of new laws or regulations.
Interest Rate Risk: which is the risk that the value of the investments we recommend to you will fall if interest rates rise.
Call Risk: which is the risk that your investment will be called or purchased back from you when conditions are favorable to the bond issuer and unfavorable to you.
Default Risk: which is the risk that issuer is unable to pay the contractual interest or principal on the investment promptly or at all.
Manager Risk: which is the risk that an actively managed mutual fund’s investment adviser will fail to execute the fund’s stated investment strategy.
Industry Risk: which is the risk that a group of stocks in a single industry will decline in price due to adverse developments in that industry, decreasing the value of mutual funds that are significantly invested in that industry.
Short-Term Purchases: Short-term purchases can incur more trading and brokerage costs in the form of increased commissions and transaction costs and increased tax obligations on the gains of a security’s value. A short-term strategy runs the risk that certain anticipated market movements do not occur, resulting in the client holding a security for longer than intended.
Alternative Investments Risk: which is the risk associated with investing in alternative investments that are speculative, not suitable for all clients, and are intended for experienced and sophisticated investors who are willing to bear the high economic risks of the investment. Investing in alternative investments includes the following economic risks:
loss of all or a substantial portion of the investment due to leveraging, short-selling, or other speculative investment practices
lack of liquidity in that there is a lack of a secondary market for the investment and none expected to develop;
the volatility of returns;
restrictions on transferring interests in the investment;
potential lack of diversification and resulting in higher risk due to concentration of trading authority when a single adviser is utilized;
absence of information regarding valuations and pricing;
delays in tax reporting;
less regulation and higher fees than mutual funds; and
risks associated with the operations, personnel, and process of the manager funds investing in alternative investments.
ITEM 9 Disciplinary Information
As of the date of this brochure, we have not been subject to any disciplinary, legal, or regulatory events related to past or present investment clients. There has been no disciplinary, legal, or regulatory events related to us or any of our management persons.
ITEM 10 Other Financial Activities and Affiliations
Financial Industry Activities
Neither Singh PWM nor its management persons are registered or has an application pending to register as a broker-dealer or a registered representative of a broker-dealer.
Neither Singh PWM nor its management persons are registered or has an application pending to register as a futures commission merchant, commodity pool operator, or commodity trading advisor.
Selection of Other Investment Advisers
We do not recommend or select other investment advisers for our clients.
ITEM 11 Code of Ethics, Participation in Client Transactions and Personal Trading
Code of Ethics
Singh PWM has developed a code of ethics that will apply to all of our supervised persons. We and our IARs must act in a fiduciary capacity when providing investment advisory services to you. As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. Singh PWM has a fiduciary duty to all clients. This fiduciary duty is considered the core underlying principle of our code of ethics, which also covers our insider trading and personal securities transactions policies and procedures. We require all of our supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment or affiliation and at least annually thereafter, all supervised persons will acknowledge that they have read, understand, and agree to comply with our Code of Ethics.
Our Code of Ethics is available to clients and prospective clients upon request.
Recommendations Involving a Material Financial Interest
Neither we nor any related person recommend to clients or buys or sells for clients’ accounts securities in which we or a related person has a material financial interest.
Participation or Interest in Client Transactions
There are instances where an IAR will recommend to investment advisory clients or prospective clients the purchase or sale of securities in which an IAR, its affiliates, or other clients can also have a position or interest. Certain affiliated accounts can trade in the same securities with client accounts on an aggregated basis. Generally, in such circumstances, the affiliated and client accounts will share execution costs equally. Completed trade orders will be allocated according to the instructions from the initial trade order. Partially filled trade orders will be allocated on a pro-rata basis. Any exceptions will be explained in the trade order.
Personal Trading
Employees are permitted to have personal securities accounts as long as personal investing practices are in line with fiduciary standards and regulatory requirements and do not conflict with their duty to Singh PWM and our clients. Singh PWM monitors and controls personal trading through pre-approval of all personal securities transactions or blackout periods imposed upon employees trading in the same securities as Singh PWM. We forbid any officer or employee, either personally or on behalf of others, to trade on material, nonpublic information or to communicate such information to others in violation of the law.
ITEM 12 Brokerage Practices
Singh PWM currently has arrangements with Fidelity Investments and Charles Schwab Corporation. These are the unaffiliated, qualified custodian whereby Singh PWM would suggest you custody your accounts. is an independent SEC-registered broker-dealer and a member of FINRA and SIPC.
As a fiduciary, we are obligated to seek out the best execution of client transactions for accounts that we manage. In general, the execution of securities transactions is at a total cost to process each transaction and are the most favorable under the circumstances. However, we do not limit the best execution to the lowest available price. Additional factors are taken into consideration when determining the arrangement and services in the selection of a broker-dealer or qualified custodian. Our review consists of reviewing the commission and fee structures of various broker-dealers, research platforms, and execution services. Accordingly, while we consider competitive rates, we do not necessarily obtain the lowest possible commission rates for account transactions. Therefore, the overall services provided by unaffiliated broker-dealers and qualified custodians are evaluated to determine the best execution. You can pay trade execution charges and higher commissions through the trading platforms approved by us than through platforms that have not been approved by us.
Singh PWM does not maintain custody of your assets that we manage, although we are deemed to have custody of your assets if you give us authority to withdraw assets from your account (see Item 15—Custody, below). Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. We may recommend that our clients use Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer and member of SIPC, as the qualified custodian.
We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them. While we recommend that you use Schwab as a custodian/ broker, you will decide whether to do so and will open your account with Schwab by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian.
We do not open the account for you, although we can assist you in doing so. Not all advisors require their clients to use a particular broker-dealer or other custodian selected by the advisor. Even though your account is maintained at Schwab, and we anticipate that most trades will be executed through Schwab, we can still use other brokers to execute trades for your account as described below (see “Your brokerage and custody costs”).
When considering whether the terms that Schwab provides are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including:
· Combination of transaction execution services and asset custody services (generally without a separate fee for custody
· Capability to execute, clear, and settle trades ( buy and sell securities for your account
· Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payments, etc.
· Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs), etc.)
· Availability of investment research and tools that assist us in making investment decisions
· Quality of services
· Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices
· Reputation, financial strength, security, and stability
· Prior service to us and our clients
· Services delivered or paid for by Schwab
· Availability of other products and services that benefit us, as discussed below (see “Products and services available to us from Schwab”)
Your brokerage and custody costs
For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for example, mutual funds and ETFs) do not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. For some accounts, Schwab charges you a percentage of the dollar amount of assets in the account in lieu of commissions. In addition to asset-based fees, Schwab charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your Schwab account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we have Schwab execute most trades for your account.
We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through Schwab, we have determined that having Schwab execute most trades is consistent with our duty to seek the “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How we select brokers/custodians”). By using another broker or dealer, you can pay lower transaction costs.
Research and Other Benefits
Products & Services Available to Us from Schwab
Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business serving independent investment advisory firms like ours. They provide us and our clients with access to its institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis and at no charge to us as long as we maintain a total of at least $10 million of our clients’ assets in accounts at Schwab.
Services that Benefit Client
Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access, or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit clients or their account(s).
Services that May Not Directly Benefit Clients
Schwab also makes available to us other products and services that benefit us but cannot directly benefit the client or their account(s). These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We can use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that:
provides access to client account data (such as duplicate trade confirmations and account statements);
facilitates trade execution and allocates aggregated trade orders for multiple client accounts;
provides pricing and other market data;
facilitates payment of our fees from our clients’ accounts; and
assists with back-office functions, recordkeeping, and client reporting.
Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include:
educational conferences and events
technology, compliance, legal, and business consulting;
publications and conferences on practice management and business succession; and
access to employee benefits providers, human capital consultants, and insurance providers.
Schwab can provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab can also discount or waive its fees for some of these services or pay all or a part of a third party’s fees.
Irrespective of direct or indirect benefits to our client through Schwab, we strive to enhance the client’s experience, help reach their goals and put their interests before that of our firm or its associated persons.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers.
Directed Brokerage
We do not recommend, request, require, or permit clients to direct us to execute transactions through a specific broker-dealer other than those we recommend.
Trade Aggregation
We attempt to allocate trade executions in the most equitable manner possible, taking into consideration current asset allocation and availability of funds using price averaging, proration, and consistently non-arbitrary methods of allocation. We can aggregate orders in order to obtain best execution, to negotiate more favorable commission rates, or to allocate equitably among our clients’ differences in prices and commission or other transaction costs. In aggregated orders, transactions will be price-averaged and allocated among our clients in proportion to the purchase and sale orders placed for each client account on any given day.
ITEM 13 Review of Accounts
Periodic Reviews
We review asset management accounts no less than annually. These accounts will be reviewed by Raman Singh, CCO. Accounts are reviewed to evaluate asset allocation, investment strategy and objectives, cash balance, and performance, as well as the general economic outlook and current investment trends.
Financial plans created utilizing our ongoing financial planning services will be reviewed monthly or quarterly by Raman Singh, CCO. Project-based financial planning clients are provided a one-time plan or consulting session and receive no additional reviews unless a new financial planning and consulting agreement is executed.
Review Triggers
We conduct periodic reviews to evaluate the current market, economic and political events and how these can affect client accounts. Additional reviews can be triggered by these events or by events in the client’s financial or personal status.
Regular Reports
Asset management clients will receive advisory account reports no less than quarterly. These reports show asset value by cash balances, security, unit cost, total cost, current per share values, etc. Clients are urged to review the quarterly reports provided by us with those provided by their custodians and notify us of any differences. Clients are encouraged to phone or e-mail us as often as they deem necessary to receive information regarding the investment tactics and strategies being followed.
Financial plans created utilizing our ongoing financial planning services will receive status updates and/or reports during plan reviews. We can make adjustments to the Client’s financial plan and/or the Client’s objectives.
Project-based financial planning and consulting clients are provided a one-time written financial plan concerning their financial situation. After the presentation of the plan, there are no further reports.
ITEM 14 Client Referrals and Other Compensation
We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. In addition, Schwab has also agreed to pay for certain products and services for which we would otherwise have to pay once the value of our clients’ assets in accounts at Schwab reaches a certain size. [In some cases, a recipient of such payments is an affiliate of ours or another party which has some pecuniary, financial, or other interests in us (or in which we have such an interest). You do not pay more for assets maintained at Schwab as a result of these arrangements. However, we benefit from the arrangement because the cost of these services would otherwise be borne directly by us. You should consider these conflicts of interest when selecting a custodian. The products and services provided by Schwab, how they benefit us, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices).
While we do not have any current arrangements with any TPMMs, at such time that we do, we will receive compensation based on the service they provide to our clients. Any such compensation arrangement will be formalized in an agreement and disclosed to our clients.
Please see Item 12 Brokerage Practices for information regarding the benefits we receive from our custodian.
We do not pay a referral fee to third-party solicitors.
ITEM 15 Custody
We are deemed to have custody of client funds and securities due to our ability to deduct management fees from clients’ accounts. We will not take physical custody of clients’ funds and will not assign or transfer trading authorization to another advisor. Clients will receive account statements from the qualified custodian(s) holding their funds and securities at least quarterly. The custodian’s account statements will indicate the amount of our advisory fees deducted from the clients’ account(s) each billing period. These statements should be carefully reviewed by the client for accuracy. Item 5 – Fees and Compensation has additional information regarding our ability to deduct management fees from clients’ accounts.
If using Schwab as a custodian, you will receive account statements directly from Schwab at least quarterly. They will be sent to the email or postal mailing address you provided to Schwab. You should carefully review those statements promptly when you receive them. We also urge you to compare Schwab’s account statements with the periodic account statements and/or portfolio reports you will receive from us.
ITEM 16 Investment Discretion
Discretionary Authority for Trading
If you are participating in our asset management services, upon receiving your written authorization via our executed investment advisory agreement, we will maintain trading authorization over your designated account and can also implement trades on a discretionary basis.
When discretionary authority is granted, we will have the limited authority to determine the type of securities to be purchased, sold, or exchanged and a number of securities that can be bought, sold, or exchanged for your portfolio without obtaining your consent for each transaction.
If you do not grant this limited investment discretion, your IAR will be required to contact you and get affirmation regarding our investment recommendations, such as the security being recommended, the number of shares, and whether the security should be bought or sold before implementing changes in your account.
Once the above factors are agreed upon, we will be responsible for making decisions regarding the timing of buying or selling an investment and the price at which the investment is bought or sold. If your accounts are managed on a non-discretionary basis, it is critical that you respond promptly. If we do not receive a response to our request immediately, the timing of trade implementation can lead to an adverse impact where we cannot achieve the optimal trading price.
On a case-by-case basis, you can place reasonable restrictions on the types of investments that can be purchased or sold in your account so long as the restrictions are explicitly set forth or included as an attachment to the investment advisory agreement.
ITEM 17 Voting Client Securities
We do not have the authority to vote proxies as it pertains to the issuers of securities held in your account. The responsibility for voting your securities places increased liability to us and does not add enough value to the services provided to you to justify the additional compliance and regulatory costs associated with voting your securities.
Therefore, you are responsible for voting all proxies for securities held in accounts managed by us. Typically, our qualified custodian will forward you your proxy information. Although we do not vote your proxies, you can contact us if you have a question about a particular proxy.
ITEM 18 Financial Information
We will not require a fee of $500 or more to be paid six months or more in advance. We are not required to include a balance sheet for our most recent fiscal year. We are not subject to a financial condition that is reasonably likely to impair our ability to meet contractual commitments to our clients.
We are currently not in, nor have we been historically, in a financially precarious situation or the subject of a bankruptcy petition.
ITEM 19 Requirements for State-Registered Advisers
Educational Background and Business Experience of Principal Officers
Raman Singh is the sole owner and principal for Singh PWM. For information regarding Raman Singh’s educational background and business experience, please see the brochure supplement supplied as Part 2B.
Other Business Activities of Principal Officer
Please see the brochure supplement supplied as Part 2B.
Performance-Based Fees
Singh PWM’s IARs do not currently charge any performance-based fees (fees based on a share of capital gains or capital appreciation of the assets of a client).
Disciplinary Information
Singh PWM’s IARs are not subject to any arbitration claim or are found liable in a civil, self-regulatory, or administrative proceeding.
Material Relationships with Issuers of Securities
Neither Singh PWM nor its IARs has any relationship or arrangement with issuers of securities.
Business Continuity Plan
Singh PWM maintains a written Business Continuity Plan that identifies procedures related to an emergency or significant business disruptions, including the death of the owner of the registered investment adviser or any of its investment adviser representatives.
This Brochure Supplement provides information for Raman Singh that supplements the Singh Private Wealth Management LLC brochure. You should have received a copy of that brochure. Please contact us at 480-420-4824 or raman@singhpwm.com if you did not receive Singh PWM’s Brochure or if you have any questions about the contents of this supplement.
Additional information about Raman Singh is also available on the SEC’s website at www.adviserinfo.sec.gov.
Form ADV Part 2B
Firm Brochure
Supplement
March 21, 2024
Raman Singh
CRD# 326033
Singh Private Wealth Management LLC
IARD#5899381
3829 N 4th Street
Phoenix,AZ,85012
480-420-4824
raman@singhpwm.com
Singh Private Wealth LLC
ITEM 1
ITEM 2 Educational Background and Business Experience
Raman Singh, born in 1988, graduated from the University of Houston in December 2012 with a Bachelor of Business Administration in Finance. Raman Singh’s employment information is listed below.
Singh Private Wealth LLC Founder and CCO March 2023-Present
Facet Wealth Senior Financial Planner April 2021 - Sept 2022
Facet Wealth Investment Adviser Representative April 2021-September 2022
Mutual trust Asset Management Investment Adviser Representative March 2020-March 2021
The Holland Group Retirement Wealth Advisors Certified Financial Planner June 2018 - March 2021
Northwestern Mutual Investment Services Associate Wealth Management Advisor February 2017-March 2018
Professional designations
Certified Financial Planner™, CFP®
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education, (2) stringent code of conduct and standards of practice, and (3) ethical requirements that govern professional engagements with clients. Currently, more than 71,000 individuals have obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
· Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a bachelor’s degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning;
· Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real-world circumstances;
· Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and
· Ethics – Agree to be bound by the CFP Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks:
· Continuing Education – Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and
· Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to the CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP® certification.
ITEM 3 Disciplinary Information
Raman Singh has not been and/or is presently not involved in any disciplinary, legal, or regulatory events that would be material to a client’s evaluation of him or of Singh PWM.
ITEM 4 Other Business Activities
Raman Singh is a tutor at Varsity Tutors. Raman provides tutoring sessions to students trying to pass the FINRA licenses such as the SIE, Series 7, Series 63, Series 65, Series 66, Insurance License, and the CFP Exam. Raman spends approximately 20 hours per week in this role.
Raman Singh is the managing partner of RRJR Enterprises, LLC, a distributor, and reseller of leather products. He spends approximately 10 hours per month in this role.
ITEM 5 Additional Compensation
Raman Singh does not receive any additional compensation.
ITEM 6 Supervision
Raman Singh, Managing Member, and Chief Compliance Officer of Singh PWM is responsible for supervising the investment advisory activities of the investment adviser representatives. Raman Singh monitors and reviews all forms of written communications that the investment adviser representatives provide to clients. Raman Singh can be contacted via telephone at 480-420-4824 and via email at raman@singhpwm.com.
ITEM 7 Requirements for State-Registered Advisers
A. Raman Singh has not been involved in an award or found liable in any arbitration claim or in any civil, self-regulatory organization or administrative proceedings.
B. Raman Singh has not been the subject of a bankruptcy petition.