CITRIN COOPERMAN WEALTH MANAGEMENT, LLC

Item 1 – Cover Page Firm Brochure (Part 2A of Form ADV) CITRIN COOPERMAN WEALTH MANAGEMENT, LLC 50 ROCKEFELLER CENTER, NEW YORK, NY 10020 Tel: (212) 697-1000 Fax: (347)-226-7591 March 29, 2025 This brochure provides information about the qualifications and business practices of Citrin Cooperman Wealth Management, LLC (“CCWM” or the “Firm”). If you have any questions about the contents of this brochure, please contact Michael Dooley at: (646) 979-6081, or by email at: mdooley@ccwmlp.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”), or by any state securities authority. Additional information about CCWM is also available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with the Firm who are registered or are required to be registered as investment adviser representatives.  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure Item 2 - Material Changes There have been no material changes to this Form ADV Part 2A Brochure since the last annual updating amendment on March 29, 2024. We will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. Currently, our Brochure may be requested by contacting Michael Dooley, Chief Compliance Officer (“CCO”) at (646) 979-6081or mdooley@ccwmlp.com, or by calling the Firm at the main number: 212-697-1000. Additional information about CCWM is also available via the SEC’s website www.adviserinfo.gov. The SEC’s website also provides information about any persons affiliated with the Firm who are registered or required to be registered as investment advisor representatives. 2  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure Item 3 - Table of Contents Item 1 – Cover Page ........................................................................................................................................................... 1 Item 2 - Material Changes ................................................................................................................................................. 2 Item 3 - Table of Contents ................................................................................................................................................ 3 Item 4 - Advisory Business................................................................................................................................................ 4 Item 5 - Fees and Compensation ................................................................................................................................... 10 Item 6 - Performance-Based Fees and Side-by-Side Management ........................................................................... 12 Item 7 - Types of Clients ................................................................................................................................................. 12 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss................................................................... 12 Item 9 - Disciplinary Information .................................................................................................................................. 17 Item 10 - Other Financial Industry Activities and Affiliations .................................................................................. 17 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..................... 18 Item 12 - Brokerage Practices ......................................................................................................................................... 19 Item 13 - Review of Accounts ........................................................................................................................................ 22 Item 14- Client Referrals and Other Compensation ................................................................................................... 23 Item 15 - Custody ............................................................................................................................................................. 23 Item 16 - Investment Discretion .................................................................................................................................... 23 Item 17 - Voting Client Securities .................................................................................................................................. 24 Item 18 - Financial Information ..................................................................................................................................... 24 3  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure Item 4 - Advisory Business CCWM is an SEC registered investment adviser with its principal place of business located in New York, NY, USA. The Firm was originally founded in 1997 as YMSR Advisors, Inc. On May 1, 2008 YMSR Advisors, Inc. merged into Citrin Cooperman Wealth Management, LP. In October 2021, Citrin Cooperman Wealth Management, LP redomesticated from Pennsylvania to Delaware and converted its form of entity from a limited partnership to a limited liability company. Principal Owners CCWM is 100% owned by Citrin Cooperman Advisors, LLC. That entity is principally owned indirectly by New Mountain Capital, LLC. Regulatory Assets Under Management As of December 31, 2024, CCWM managed $132,270,688 in assets on a discretionary basis and $1,448,681,943 on a non-discretionary basis. Types of Services CCWM offers investment advisory services on a discretionary and/or non-discretionary basis to each of its clients, including both individuals and institutions (details on the types of clients CCWM serves are in Item 7-Types of Clients). CCWM will assist a client in determining the client’s investment needs and objectives, as well as risk tolerance, through the use of an asset optimization model for asset allocation and research on investment managers and investments. After the client’s asset classes have been determined, the team recommends strategies, managers and/or products that have been evaluated and approved by CCWM’s Investment Committee (as defined below). The recommended strategies are based upon a client’s goals, investment objectives, risk tolerance, and cash flow needs, which are documented in an Investment Policy Statement and reviewed periodically. CCWM will then implement the allocation into appropriate mutual funds, ETFs, separately managed accounts, private investment funds (including, but not limited to hedge funds, private equity funds, venture capital funds), and/or investment managers within each asset class that meet the client’s individual requirements. CCWM does not recommend individual company stocks and bonds. In addition to its full consulting offering, CCWM also provides financial planning services, including providing independent guidance during the planning of upcoming liquidity events. Financial planning includes estate planning, tax planning, education funding planning, charitable gifting planning, etc., however, CCWM will provide advice as appropriate and may not provide advice on all of the aforementioned types of financial planning. The client is under no obligation to act upon any of the recommendations made by CCWM under a financial planning or consulting engagement or to engage the services of any such recommended professional, including CCWM itself. The client retains absolute discretion over all such implementation decisions in such instance and is free to accept or reject any of CCWM’s recommendations. 4  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure Tailored Relationships CCWM tailors its advisory services to the individual needs of clients. Customarily, the Firm will arrange for an initial meeting, which may be by telephone or webcast to determine the extent to which financial planning and investment management may be beneficial to the client. CCWM consults with clients on an ongoing basis to determine risk tolerance, time horizon and other factors that may impact the clients’ investment needs. CCWM helps clients find suitable investments for their goals, objectives, and risk tolerance. Prior to CCWM providing investment management services, the client will be required to enter into a formal Investment Management Agreement (as defined below) with CCWM setting forth the terms and conditions under which CCWM shall manage the client’s assets, as well as a separate custodial/clearing agreement with the broker-dealers/custodians (See Item 12 – Brokerage Practices). Clients may impose restrictions on investing in certain securities or types of securities in the Investment Management Agreement. Investment Management CCWM provides continuous and regular account supervision. As part of our investment management service, we generally create a portfolio, consisting of separately managed accounts comprising stocks or bonds, exchange traded funds, mutual funds and other public and private securities or investments. We may also provide broader financial planning/financial consulting to clients. We offer at least one, but often more than one meeting (in person, if possible, otherwise via telephone or webcast conference) with clients in order to understand their current financial situation, existing resources, financial goals, and tolerance for risk. Based on what we learn, we propose an investment approach to the client that will be suitable to the client’s circumstances. Each client’s individual investment strategy is tailored to their specific needs and may include some or all of stocks or bonds, exchange traded funds, options, mutual funds and other public and private securities or investments. Upon the client’s agreement to the proposed investment plan, we work with the client to establish or transfer investment accounts so that we can manage the client’s portfolio. We review the client’s investment plan at least annually and, if necessary, rebalance the portfolio based upon the client’s individual needs, stated goals and objectives. CCWM generally recommends that clients allocate investment assets among certain third-party money managers / investment programs (collectively, the “Independent Managers”) and private investment funds. CCWM’s trading activities are therefore extremely limited. The vast majority of account transactions are executed by Independent Managers and private investment fund managers that maintain day-to-day discretionary authority for the management of the allocated assets. Based upon these and other factors, there may be extended periods when CCWM determines that upon review, trades within a client’s portfolio are not prudent. Clients nonetheless remain subject to the fees described in Item 5 during periods of portfolio trading inactivity. Clients are advised to promptly notify CCWM if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon CCWM’s management services. Clients may impose reasonable restrictions or mandates on the management of 5  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure their account if, in CCWM’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. If the client experiences any significant changes to their financial or personal circumstances, the client must notify us so that we can consider such information in managing the client’s investments. CCWM offers to manage clients’ investment portfolios on a discretionary or non-discretionary basis. a. Discretionary. CCWM has the discretionary authority to manage client accounts by determining the amount and type of investments to be bought and sold and managers to be hired and terminated without receiving client confirmation for each transaction. In all cases, CCWM exercises this discretion in a manner consistent with the stated investment objectives for the particular client account. The Investment Committee (as defined below) determines the investment strategy and manager selection options for CCWM. Depending on the CCWM Investment Committee (the “Investment Committee”) recommendation, CCWM will adopt an implementation plan that considers the goals of the Investment Committee decision, fairness to all clients, and practical issues (such as short-term redemption fees and tax liabilities). The Investment Committee is responsible for considering how and when to implement the investment strategy and manager selection options for each client and considers these factors, among others, when making those decisions: investment objective, policies, and strategy of the account; appropriateness of the investment to the account’s time horizon and risk objectives; existing levels of ownership of the investment and other similar investments; immediate availability of cash or buying power to fund the investment; and complexity of client portfolio (including whether the portfolio holds private investment vehicles or more liquid securities). As a result of customizing client portfolios based on the above considerations, the time frame for implementing the investment strategy and/or manager selection may vary client by client which may result in different clients receiving favorable or disadvantageous execution. CCWM will monitor the implementation plan to ensure all investment decisions are implemented fairly and in accordance with the goals and objectives of the Investment Committee. CCWM may also allocate a clients’ investment management assets among Independent Managers (as defined below), mutual funds, exchange-traded funds, bonds, master limited partnerships and alternative investments in accordance with the investment objectives of the client. b. Non-Discretionary. CCWM may not make investment decisions, including buying or selling securities, for the client without prior consultation with, and the consent of, the client. Clients understand that they may forego a particular transaction if CCWM cannot obtain that consent. In addition, certain clients, such as institutional clients, may only make investment decisions with the approval of oversight groups, such as Board of Directors, Board of Trustees, or investment committees. As such, depending on when these oversight groups have scheduled meetings and CCWM has access to such oversight boards, CCWM may not have an opportunity to make recommendations within the timeframe of the implementation plan. CCWM will make investment recommendations as soon as practicable, and may, if deemed necessary, request access to the oversight committee in between scheduled meetings. If such access is not available, however, CCWM may not be able to make recommendations and get consent in accordance with implementation plans available to other clients. Non-discretionary investment management services can negatively impact client accounts if CCWM is unable to contact clients during sudden negative market conditions. 6  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure With respect to its non-discretionary asset management services, CCWM generally maintains ongoing responsibility to make recommendations, based upon the needs of the client, as to the specific securities the account may purchase or sell. The final decision on investment selection rests with the client in this arrangement and the client always maintains asset control. CCWM may place trades for clients under a limited power of attorney, as may be provided by the client. Certain of the alternative investments recommended by the Firm, which may include debt, equity, and/or pooled investment vehicles, exist in the form of private placement securities. As such, CCWM limits such recommendations to those clients which are deemed to be “accredited investors,” or “institutional investors” as defined under Rule 501 of the Securities Act of 1933. Prior to engaging CCWM to provide investment management services, the client is required to enter into a written investment management agreement with CCWM setting forth the terms and conditions of the engagement (the “Investment Management Agreement”). Independent Managers CCWM may recommend that certain clients authorize the active discretionary management of a portion of their assets among Independent Managers. When selecting an Independent Manager for a client, CCWM considers the client’s stated investment objectives as well as the Independent Manager’s reputation, performance, management style, investment strategies, past performance, and disclosures and/or research materials. CCWM will continue to provide ongoing monitoring and review of account performance and asset allocation as compared to account and overall portfolio investment objectives. The investment management fee charged by the Independent Manager is separate from, and in addition to, CCWM’s advisory fee. In addition to CCWM’s written disclosure brochure, the client also receives the written disclosure brochure of the designated Independent Managers. Certain Independent Managers may impose more restrictive account requirements and varying billing practices than CCWM. In such instances, CCWM may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. A client may also choose to implement CCWM’s recommendations through CCWM. In the event the client decides to implement investment recommendations through CCWM on a fee basis, CCWM shall charge an annual investment management fee based upon a percentage of the market value of the assets being managed by CCWM. The investment management fee charged shall vary (generally between 0.25% and 1.00%) depending upon the market value of assets under management and the specific type of discretionary or non-discretionary investment management services to be rendered. The terms and conditions under which the client shall engage the Independent Managers shall be set forth in separate written agreements between the client, CCWM and the designated Independent Managers. CCWM shall continue to render non-investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives, for which CCWM shall receive an annual advisory fee which is based upon a percentage of the market value of the assets being managed by the designated Independent Managers. The investment management fees charged by the designated Independent Managers are exclusive of, and in addition to, CCWM’s ongoing investment advisory fee. 7  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure Financial Planning and Consulting Services CCWM may provide its clients with a broad range of comprehensive financial planning and consulting services, addressing a multitude of investment and non-investment related matters which may include, but is not limited to, the following: • Asset protection strategies • Charitable giving • Philanthropic planning • Education funding • Insurance coverage • Risk management • Retirement planning • Tax strategies • Estate planning • Succession planning Prior to engaging CCWM to provide financial planning and/or consulting services, the client will be required to enter into a financial planning agreement with CCWM setting forth the terms and conditions of the engagement, describing the scope of the services to be provided (the “Financial Planning Agreement”). In the event the client terminates CCWM’s investment management, financial planning, and/or consulting services, the balance of CCWM’s fee, if any, shall be refunded to the client. Neither CCWM nor the client may assign a Financial Planning Agreement or Investment Management Agreement without the prior consent of the other party. Transactions that do not result in a change of actual control or management of CCWM shall not be considered an assignment. A client may terminate any of the aforementioned agreements at any time by notifying CCWM in writing and paying the rate for the time spent on the investment advisory engagement prior to notification of termination. If the client made an advance payment, CCWM’s fee shall be prorated through the date of termination. CCWM may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, CCWM’s fee shall be prorated through the date of termination. A copy of the written disclosure statement for CCWM, as set forth on Part 2A and 2B of Form ADV, shall be provided to each client prior to, or contemporaneously with, the execution of the Financial Planning Agreement or Investment Management Agreement. Consolidated Reporting CCWM also provides consolidated investment reporting services, which amalgamates client accounts from various custodians, including alternatives to show overall performance allocation and other pertinent metrics. 8  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure Miscellaneous ERISA / IRC Fiduciary Acknowledgment. When CCWM provides investment advice to a client about the client’s retirement plan account or individual retirement account, it does so as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Because the way CCWM makes money creates some conflicts with client interests, CCWM operates under a special rule that requires it to act in the client’s best interest and not put its interests ahead of the client’s. Under this special rule’s provisions, CCWM must: meet a professional standard of care when making investment recommendations (give prudent advice); never put its financial interests ahead of the client’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 CCWM gives advice that is in the client’s best interest; charge no more than is reasonable for CCWM’s services; and give the client basic information about conflicts of interest. Retirement Plan Rollovers – No Obligation / Conflict of Interest. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If CCWM recommends that a client roll over their retirement plan assets into an account to be managed by CCWM, such a recommendation presents a conflict of interest if CCWM will earn a new (or increase its current) advisory fee as a result of the rollover. Clients are not obligated to roll over retirement plan assets to an account managed by CCWM. Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. Except for stand-alone financial planning engagements, CCWM will provide general financial planning and related consulting services under its advisory fee set forth at Item 5 below. CCWM strongly recommends that clients address financial planning and related issues with CCWM on an ongoing basis, especially because CCWM’s fee will remain as set forth in Item 5 below regardless of whether the client engages CCWM in that capacity. Unless specifically agreed in writing, neither CCWM nor its representatives are responsible to implement any financial plans or financial planning advice, provide ongoing financial planning services, or provide ongoing monitoring of financial plans or financial planning advice. Clients are solely responsible to revisit the financial plan or financial planning advice with CCWM, if desired. CCWM’s financial planning and consulting services are completed upon communicating its recommendations to the client, upon delivery of the written financial plan, or upon termination of the applicable agreement. CCWM does not serve as an attorney, accountant, or insurance agent, and no portion of our services should be construed as same. Accordingly, CCWM does not prepare legal documents, prepare tax returns, or sell insurance products. To the extent requested by a client, CCWM may recommend the services of other professionals for non-investment implementation purpose (i.e., attorneys, accountants, insurance, etc.), including CCWM’s affiliated CPA firm, which presents a conflict of interest. Clients are not obligated to engage the services of any recommended professionals, who are responsible for the quality and competency of the services they provide. 9  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure Client Obligations. When performing its services, CCWM is not required to verify any information received from the client or from the client’s designated professionals and is expressly authorized to rely on that information. Clients are responsible to promptly notify CCWM if there is ever any change in their financial situation or investment objectives for the purpose of reviewing or amending CCWM’s services or previous recommendations. Item 5 - Fees and Compensation CCWM charges for its services on a fully disclosed basis per the terms and conditions of an Investment Advisory Agreement or Financial Planning and Consulting Agreement, in one of the following manners: Fixed Annual Fee. In such fee arrangements, CCWM will consider various objective and subjective factors including but not limited to, such as the amount of assets to be managed, the scope and complexity of the engagement, anticipated meetings, and consulting services to be rendered. This annual fee is payable in either four equal quarterly installments or twelve equal monthly installments, in arrears or in advance. Each year the annual fee is reviewed, and if adjusted, such adjustment is confirmed, in writing. The terms of the engagement shall be confirmed in an Investment Advisory Agreement between CCWM and the client. The vast majority of CCWM’s client engage CCWM on a fixed annual fee basis. Assets Under Management. In such fee arrangements, the client pays CCWM a fee based upon a percentage of the assets under CCWM’s management (i.e., mutual funds, exchange traded fund, Independent Managers, private investment funds, money market accounts, etc.) per the following fee schedule: Traditional Fixed Income (Treasury, Sovereign, Agency, Municipal, and IG Corporate Bonds) All amounts - 25 basis points All Assets Excluded from Above First $10 million – 75 basis points Next $15 million – 50 basis points Next $25 million – 40 basis points Thereafter – 30 basis points The fee is payable on a quarterly basis, in arrears, based upon the market value (including accrued earnings) of the accounts on the last day of the previous quarter. No increase in the annual fee percentage is effective without prior written notification to the client. The values used to calculate investment advisory fees based on the market value of client assets may differ from the values shown on the applicable client’s custodial statement due to various account activities such as unsettled trades. accrued interest, and accrued dividends, which may not be reflected on that client’s custodial statement as of the valuation date. The terms of the engagement shall be confirmed in an Investment Advisory Agreement between CCWM and the client. Although CCWM will allocate client assets consistent with the client’s designated investment objective, the fact that CCWM earns a higher fee for management of securities other than traditional fixed income as referenced in the above fee schedule, CCWM has a conflict of interest since it will present an economic incentive to allocate more assets to those types of securities from which it will earn a higher advisory fee. 10  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure Hourly Fees. CCWM can also be engaged to provide financial planning and/or consulting services on an hourly rate basis per the terms and conditions of a Financial Planning and Consulting Agreement. Consolidated Reporting Fees. CCWM’s consolidated reporting fees vary based on the number of accounts subject to the services, account complexity, and data sources, but typically range between $1,000 and $5,000 per month. Fee Dispersion. CCWM may charge a lesser investment advisory fee, charge a flat fee, or waive its fee entirely based upon certain criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, complexity of the engagement, grandfathered fee schedules, CCWM employees and family members, courtesy accounts, competition, negotiations with client, etc.). Certain clients may have accepted different service offerings from CCWM and may therefore receive services under different fee schedules than as set forth above. Accordingly, similarly situated clients could pay different fees, and CCWM reminds clients that similar advisory services may be available from other investment advisers for similar or lower fees. Cash Positions. Unless CCWM expressly agrees to the contrary, account assets consisting of cash and cash equivalent positions are included in the value of an account’s assets for purposes of calculating CCWM’s advisory fee. Alternative Investment / Private Fund Valuation. Interests of private investment partnerships, separate accounts, or other private investment structures will generally be valued at the most recent net asset value supplied by the investment manager to the respective investment vehicle. However, for valuation and client billing purposes, that amount may be adjusted to the client’s favor to account for capital calls, management fees, distributions, or partnership expenses. As result of the valuation process, the current value of a client’s private investment holding could be significantly more or less than the value reflected in the report. Unless otherwise agreed upon, the client’s advisory fee shall be based upon the value reflected in the report. Other Fees The Firm’s advisory fees are exclusive of and in addition to brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients may also incur certain other charges imposed by custodians, brokers, third-party investment managers, and other third parties, such as interest charges, deferred sales charges, odd-lot differentials, transfer taxes, expense ratios / fund management fees, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Clients are responsible for the payment of these costs and expenses. Independent Managers may execute transactions through broker-dealers other than the account custodian, in which event, the client generally will incur both the transaction fee (commission, mark-up/mark-down) charged by the executing broker-dealer and a separate “tradeaway” and/or prime broker fee charged by the account custodian. CCWM does not receive any portion of the transaction or tradeaway/prime broker fees. Clients should review all fees charged by CCWM and its custodians, brokers, and others to fully understand the total amount of fees to be paid. Mutual funds, exchange-traded funds, investment advisors and alternative investments / private funds also charge internal management fees, which are disclosed in a fund’s prospectus or offering documents. CCWM will not receive any portion of these commissions, fees, or costs. 11  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure Item 6 - Performance-Based Fees and Side-by-Side Management CCWM does not use a performance-based fee structure and CCWM’s fees are not based on a share of the capital gains or capital appreciation of managed securities. Item 7 - Types of Clients CCWM may provide portfolio management and investment planning to high net worth individuals, trusts, family entities, pension and profit sharing plans, charitable organizations, and foundations. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis CCWM provides asset allocation and manager selection advice to clients. CCWM’s Investment Committee is responsible for CCWM’s investment strategy and manager due diligence. The Investment Committee is responsible for overseeing and monitoring various aspects of the investment process and the performance of client investment portfolios, including risk and diversification. The Investment Committee is also responsible for, among other things: determining CCWM’s overall investment philosophy; analyzing and interpreting changing economic trends as they impact CCWM’s investment process and portfolio performance; revising CCWM’s investment philosophy and implementation strategies accordingly; and establishing and articulating CCWM’s implementation philosophy, including the appropriateness of incorporating various asset classes, sub-asset classes, investment styles, and strategies in client portfolios. The Investment Committee meets at least quarterly. Investment Strategies The investment strategy for a specific client is based upon the objectives stated by the client during consultations with CCWM. Each client completes a risk tolerance questionnaire or similar form that documents their objectives and their desired investment strategy. CCWM recommends or implements various investment strategies when providing asset allocation proposals and advice to clients based on these objectives. The Investment Committee is accountable for reviewing asset allocation recommendations on a quarterly basis, if appropriate. If the client should change their objectives, CCWM will recommend a new proposal in order to achieve the client’s revised objectives and newly desired investment strategy. Investment Managers CCWM recommends Independent Managers to help clients meet their investment objectives. The Independent Managers that the Firm selects and monitors are responsible for the analysis, selection, and execution of the securities. Independent Managers establish their own specific asset management fee schedules and may have account minimum requirements. Account minimums are generally higher on fixed income accounts than for equity-based accounts. A complete description of the Independent Manager’s services, fee schedules and account minimums will be disclosed in the Independent 12  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure Manager’s disclosure brochure which will be provided to a client prior to or at the time an agreement for services is executed and the account is established. The actual fee charged to a client will depend on the Independent Manager’s fee schedule and will be billed directly by such Independent Manager to the client. Under this program, a client may incur additional charges including but not limited to, management fees, performance fees, partnership expenses, mutual fund sales loads, 12b-1 fees and surrender charges, and IRA and qualified retirement plan fees. Manager Due Diligence For all CCWM recommended managers or investments, the Investment Committee evaluates investment managers, private investment funds, mutual funds, and ETFs, among other products and services. CCWM employs a due diligence process that generally involves, among other things, a review of managers’ Form ADVs, past performance, marketing literature, site visits, financial reviews and interviews with the investment managers and key personnel. The Investment Committee also considers a broad range of factors that may include investment performance, review of investment process, personnel depth, turnover and experience, operational issues, and financial condition. Periodically, the Investment Committee personnel will conduct follow-up due diligence reviews on CCWM recommended managers, including some or all of the above-mentioned factors, in addition to other topics. In determining which investments are appropriate for recommendation and/or implementation for clients, the Investment Committee may also apply quantitative analysis using a factor-based scoring system that ranks each investment option utilizing data and information obtained from third party databases. (However, the data and information provided by third party databases are not independently verified by CCWM.) The factor-based methodology and the resulting investments derived and approved through this scoring process are reviewed periodically by the Investment Committee to evaluate whether they continue to meet the Investment Committee’s minimum standards for recommendation or should be placed on watch or terminate status. It is important to note that not all managers or products recommended by CCWM are or were evaluated under the current formalized due diligence process. The Investment Committee retains the discretion, based on their experience and knowledge, to determine the level of due diligence appropriate for each manager and/or product. The Investment Committee will evaluate the retention of managers and/or investment products. If CCWM terminates a manager, the Investment Committee will make alternative recommendations or implementations for clients taking into consideration the client’s portfolio allocation, risk tolerance, tax implications, or other situations. Due diligence on the manager will be conducted for two quarters after the termination. In the event the client does not take the recommendation to terminate the manager, the client is notified and asked to acknowledge that CCWM will no longer conduct due diligence on the manager and will no longer provide any recommendation or advice regarding the manager. In certain circumstances, CCWM may monitor non-CCWM recommended managers for clients. CCWM will document the managers it is monitoring in the client’s Investment Management Agreement. Depending on the type of investment vehicle, monitoring involves site visits, reviews of manager newsletters, marketing materials, financials, and performance, among other things. CCWM may charge an additional fee for monitoring non-CCWM recommended managers. 13  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure Sources of Information As discussed above, CCWM employs a due diligence process to evaluate managers and investment products. In addition to information directly requested from managers, CCWM will use published databases of mutual fund, ETF, investment manager, hedge fund, and private equity fund performance or third-party databases. Some of the information provided in these third-party databases is sourced from SEC filings, Form ADV, monthly performance returns, manager’s assets under management, narratives on the manager’s investment process, biographies on portfolio managers, changes in personnel, information on managers’ errors and omissions insurance, and litigation. CCWM does not independently audit or verify the performance figures or other information reported by the funds or managers that appear in these databases. Risks All investment programs have certain risks that are borne by the investor. No guarantees can be made that a client’s financial goals or objectives will be achieved. Past performance is no guarantee of future performance. Our investment approach constantly keeps the risk of loss in mind. Generally, investors may face the following investment risks: • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market events. • Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. • Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. 14  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure • Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. • Third Party Risk: It is common for companies to maintain myriad third-party relationships in an effort to reduce costs, increase efficiency and focus more intently on core competencies. However, while businesses seek to gain a competitive and operational advantage through these relationships, they are also exposing themselves to an increasing level of risk. At the same time, however, it is becoming increasingly difficult for businesses to maintain the necessary controls for mitigating the risks associated with these relationships. Failure to manage these risks can expose a business to regulatory action, financial loss, litigation, and reputational damage, and may even impair the institution’s ability to establish new or service existing customer relationships. • Mutual Fund Risk: Mutual funds are operated by investment companies that raise money from shareholders and invest it in stocks, bonds, and/or other types of securities. Each fund will have a manager that trades the fund’s investments in accordance with the fund’s investment objective. Mutual funds charge a separate management fee for their services, so the returns on mutual funds are reduced by the costs to manage the funds. While mutual funds generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market. Mutual funds come in many varieties. Some invest aggressively for capital appreciation, while others are conservative and are designed to generate income for shareholders. In addition, the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). • Exchange Traded Fund Risk: ETFs are marketable securities that are designed to track, before fees and expenses, the performance or returns of a relevant index, commodity, bonds, or basket of assets, like an index fund. Unlike mutual funds, ETFs trade like common stock on a stock exchange. ETFs experience price changes throughout the day as they are bought and sold. In addition to the general risks of investing, there are specific risks to consider with respect to an investment in ETFs, including, but not limited to: (i) an ETF’s shares may trade at a market price that is above or below its net asset value; (ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. • Interval Fund Risk: CCWM may recommend or purchase closed-end interval funds, which are unable to be repurchased or otherwise sold on a daily basis. Rather, to provide limited liquidity to its shareholders, interval funds conduct periodic repurchase offers for a portion of a fund’s outstanding shares. However, there is no guarantee that investors may sell their shares at any given time or in the desired amount. If a repurchase offer is oversubscribed, the fund will repurchase the shares tendered on a pro rata basis, and shareholders will have to wait until the next repurchase offer to make another repurchase request. As a result, shareholders may be unable to liquidate all, or a given percentage, of their investment in the fund during a repurchase offer. Some shareholders, in anticipation of proration, may tender more shares than they wish to have repurchased in a quarter, thereby increasing the likelihood that proration will occur. A shareholder may be subject to market and other risks, and the net asset value of shares tendered in a repurchase offer may decline between 15  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure the repurchase request deadline and the date on which the net asset value for tendered shares is determined. In addition, the repurchase of shares by the fund may be a taxable event to shareholders. • Alternative Investment / Private Investment Fund Risk: For those clients choosing to invest in alternative investments including, but not limited to hedge funds, private equity funds and venture capital funds, such securities come with additional substantial risks as they are speculative in nature. Alternative investments generally involve various risk factors and liquidity constraints (a complete discussion of which is set forth in each fund’s offering documents) that will be provided to each client for review and consideration. Investing in private investment funds is intended for experienced and sophisticated investors only who are willing to bear the high economic risks of the investment. Investors should carefully review and consider potential risks before investing. Certain of these risks may include loss of all or a substantial portion of the investment due to: leveraging, short-selling, or other speculative practices; lack of liquidity because of redemption terms and conditions and that there may not and will not be a secondary market for the fund; volatility of returns; restrictions on transferring interests in the fund; a potential lack of diversification; higher fees than mutual funds; lack of information regarding valuations and pricing; and advisor risk. Each prospective client investor will be required to review the offering memorandum and complete a Subscription Agreement with the private investment fund itself, pursuant to which the client investor shall establish that they are qualified for investment in the fund and acknowledge and accept the various risk factors that are associated with such an investment. Private funds have liquidity risk and investors may not be able to redeem their investment per the offering document’s disclosures. As a result, the client may be required to hold alternative investments in its account after termination of this or any Investment Management Agreement with CCWM. • Independent Manager Risk: While CCWM conducts due diligence about Independent Managers and their respective investment style and process, CCWM will not necessarily have the opportunity to evaluate each specific investment that the Independent Managers will execute on the client’s behalf. CCWM depends on Independent Managers to develop the appropriate systems and procedures to control operational risks. As a result, the rates of return to clients will primarily depend upon the choice of investments and other investment and management decisions of Independent Managers and returns could be adversely affected by unfavorable performance of such Independent Managers. Some of the strategies that Independent Managers employ may present additional risk. There may be other third-party money managers that may be suitable for a client that may be more or less costly. This Independent Manager risk description is intended to supplement but not supersede related information in this Brochure about CCWM’s allocation to Independent Managers. • Cash and Cash Equivalent Risk: CCWM may hold a portion of client’s assets in cash or cash equivalent positions (such as but not limited to money market funds) typically for defensive and liquidity purposes. Investments in these assets may cause a client to miss upswings in the markets. CCWM’s advisory fee could exceed the yield / interest income from holding cash or cash equivalents. A client can advise CCWM not to maintain (or to limit the amount of) cash or cash equivalent positions in their account. • Cybersecurity Risk: The information technology systems and networks that CCWM and its third- party service providers use to provide services to CCWM’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in CCWM’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and CCWM 16  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost, and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although CCWM has established its systems to reduce the risk of cybersecurity incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that CCWM does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. The foregoing list of risk factors does not purport to be a complete explanation of the risks involved with investing. Item 9 - Disciplinary Information Registered investment advisors are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of CCWM or the integrity of CCWM’s management. CCWM has no information applicable to this Section as neither it nor any of its employees have faced legal or disciplinary matters since its inception. Item 10 - Other Financial Industry Activities and Affiliations Neither CCWM or its representatives are registered or have an application pending to register as: a broker-dealer or a registered representative of a broker-dealer, a futures commission merchant, a commodity pool operator, a commodity trading advisor, or a representative of the foregoing. As described in Item 4, CCWM does not serve as an attorney, accountant, or insurance agent, and no portion of our services should be construed as same. Accordingly, CCWM does not prepare legal documents, prepare tax returns, or sell insurance products. Upon specific client request, we may recommend the services of other professionals for non-investment implementation purpose (i.e., attorneys, accountants, insurance, etc.), including CCWM’s affiliated CPA firm (Citrin Cooperman Advisors, LLC - “CPA,” which owns 100% of CCWM. Clients are not obligated to engage any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from CCWM and/or its representatives. The recommendation by CCWM that a client engage CPA to provide services presents a conflict of interest. Clients can obtain accounting and insurance services from other unaffiliated service providers. Engagement of CPA is subject to the terms and conditions of a separate agreement and fee. There are no fee sharing arrangements between CCWM’s affiliates and CCWM. However, key CCWM employees, Michael Dooley, and Arnold Herman, are also minority owners of the CPA, and will indirectly benefit from compensation paid to CPA. CCWM does not recommend or select other investment advisers for its clients and receive direct or indirect compensation from those advisers. 17  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading CCWM has adopted a Code of Ethics for all supervised persons of the firm that describes its high standard of business conduct, and fiduciary duty to its clients. The Code of Ethics includes, among other things, that employees: • Act with integrity, competence, diligence, respect, and in an ethical manner with the public, clients, prospective clients, employers, employees, colleagues in the investment profession, and other participants in the global capital markets; • Place the integrity of the investment profession, the interests of clients, and the interests of CCWM above one’s own personal interests; • Disclose conflicts of interest; • Conduct all personal securities transactions in a manner consistent with this policy; • Promote the right of the client to select and choose any broker or dealer they wish to utilize; • Emphasize the unrestricted right of the client to decline to implement or modify any advice rendered; • Use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, taking investment actions, and engaging in other professional activities; • Practice and encourage others to practice in a professional and ethical manner that will reflect favorably on themselves and the profession; • Promote the integrity of, and uphold the rules governing, capital markets; • Maintain and improve one’s professional competence and strive to maintain and improve the competence of other investment professionals; and • Comply with applicable provisions of the federal securities laws. All supervised persons at CCWM must acknowledge the terms of the Code of Ethics annually, or as amended. CCWM anticipates that, in appropriate circumstances, consistent with clients’ investment objectives, it will cause accounts over which CCWM has management authority to effect and will recommend to investment advisory clients or prospective clients, the purchase or sale of securities in which CCWM, its affiliates and/or clients, directly or indirectly, have a position of interest. CCWM’s employees and persons associated with CCWM are required to follow CCWM’s Code of Ethics. Subject to satisfying this policy and applicable laws, officers, directors, and employees of CCWM and its affiliates may trade for their own accounts in securities which are recommended to and/or purchased for CCWM’s clients. The Code of Ethics is designed to assure that the personal securities transactions, activities, and interests of the employees of CCWM will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code of Ethics, certain classes of securities have been 18  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure designated as exempt transactions, based upon a determination that these would not materially interfere with the best interest of CCWM’s clients. In addition, the Code of Ethics requires pre- clearance of certain transactions, and may restrict certain trading in close proximity to client trading activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is monitored under the Code of Ethics to reasonably prevent conflicts of interest between CCWM and its clients. It is CCWM’s policy that clients’ transactions will always have priority over the transaction of an employee of CCWM. Additional procedures have been adopted to ensure compliance with the provisions of the Code of Ethics, including affirmations of compliance annually and upon amendment and regular reviews of holdings and transactions. CCWM’s clients or prospective clients may request a copy of the Firm’s Code of Ethics by contacting the CCO at mdooley@ccwmlp.com. It is CCWM’s policy that the Firm will not affect any principal or agency cross securities transactions for client accounts. CCWM will also not cross trades between client accounts. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. A principal transaction may also be deemed to have occurred if a security is crossed between an affiliated hedge fund and another client account. An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions may arise where an adviser is dually registered as a broker-dealer or has an affiliated broker-dealer. Item 12 - Brokerage Practices If a client requests that CCWM recommend a broker-dealer/custodian for execution or custodial services, CCWM generally recommends that investment management accounts be maintained at Charles Schwab & Co., Inc. and its affiliates (“Schwab”). Before engaging CCWM to provide investment management services, the client enters into an agreement with CCWM setting forth the terms and conditions for the management of the client’s assets, and a separate custodial/clearing agreement with each designated broker-dealer/custodian. Depending on which broker- dealer/custodian clients selects to maintain their account, they may experience differences in customer service, transaction timing, the availability and yield / interest income of sweep account vehicles and money market funds, and other aspects of investing that could cause differences in account performance. When seeking “best execution,” from a broker-dealer, the determinative factor is not always the lowest possible cost, but whether the transaction represents the best qualitative execution when considering the full range of a broker-dealer’s services including the value of research provided, execution capability, commission rates, and responsiveness. Although CCWM cannot guarantee that clients will always experience the best possible execution available, CCWM seeks to recommend a broker- 19  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure dealer/custodian that will hold client assets and execute transactions on terms that are, overall, most advantageous when compared with other available providers and their services. CCWM considers a wide range of factors when recommending a broker-dealer/custodian, 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 client accounts); • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.); • Breadth of available investment products (stocks, bonds, mutual funds, ETFs, etc.); • Quality of services (including research); • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices; • Reputation, financial strength, and stability; and • Prior service to CCWM and its other clients. Schwab is compensated for its services according to its fee schedule (which may vary), generally by charging clients commissions or other fees on trades that it executes or that settle into their Schwab account. Although CCWM will seek competitive rates, it may not necessarily obtain the lowest possible commission rates for all client account transactions. The fees charged by the designated broker- dealer/custodian are exclusive of, and in addition to, CCWM’s investment advisory fees. Research and Other Benefits. While CCWM does not receive traditional “soft dollar benefits,” CCWM and by extension, its clients, receive access to certain institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. Schwab also makes various support services available to CCWM. Some of those services help CCWM manage or administer its clients’ accounts; while others help it manage and grow its business. Schwab’s support services generally are available on an unsolicited basis (CCWM does not have to request them) and at no charge to CCWM. 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 CCWM might not otherwise have access or that would require a significantly higher minimum initial investment by its clients. These services benefit CCWM’s clients and their accounts. Schwab also makes other products and services available to CCWM that benefits CCWM but may only indirectly benefit its clients or their accounts, such as investment research developed by Schwab or third parties that CCWM may use to service clients’ accounts. In addition to investment research, Schwab also makes available software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements); • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts; • Provide pricing and other market data; • Facilitate payment of our fees from other clients’ accounts; and 20  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure • Assist with back-office functions, recordkeeping, and client reporting. Schwab may offer other services intended to help CCWM manage and further develop its business. These services include: • Educational conferences and events; • Consulting on technology, compliance, legal and business needs; • Publications and conferences on practice management and business succession; and • Access to employee benefits providers, human capital consultants, and insurance providers. Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to CCWM Schwab may discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab can also provide occasional business meals and entertainment for CCWM’s personnel. CCWM’s Interest in Schwab’s Services and Benefits and Related Conflict of Interest. The availability of the services and products described above that CCWM receives from Schwab (the “Services and Products”) provides CCWM with an advantage, because CCWM does not have to produce or purchase them. However, CCWM does not have to pay Schwab or any other entity for Services and Products that Schwab provides. CCWM’s clients do not pay more for investment transactions executed or assets maintained at Schwab as a result of this arrangement. The receipt of Services and Products is not contingent upon CCWM committing any specific amount of business to Schwab in trading commissions or assets in custody. There is no corresponding commitment made by CCWM to Schwab or any other entity to invest any specific amount or percentage of client assets in any specific securities or investment products as a result of the above. However, this arrangement nonetheless incentivizes CCWM to recommend that clients maintain their account with Schwab, based on its interest in receiving Schwab’s services that benefit its business rather than based on clients’ interest in receiving the best value in custody services and the most favorable execution of their transactions. This presents a conflict of interest. When making such a recommendation, however, CCWM does so when it reasonably believes that recommending Schwab to serve as broker- dealer/custodian is in the best interests of its clients. It is primarily supported by the scope, quality, and price of Schwab’s services and not Schwab’s services that benefit only CCWM. CCWM does not receive referrals from broker-dealers. Directed Brokerage. CCWM recommends that its clients utilize the brokerage and custodial services provided by Charles Schwab & Co., Inc. The Firm may accept directed brokerage arrangements (when a client requires that account transactions be effected through a specific broker-dealer). In such client directed arrangements, the client will negotiate terms and arrangements for their account with that broker-dealer, and Firm will not seek better execution services or prices from other broker-dealers or be able to "batch" the client’s transactions for execution through other broker-dealers with orders for other accounts managed by CCWM. As a result, a client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case. In the event that the client directs CCWM to effect securities transactions for the client’s accounts through a specific broker-dealer, the client correspondingly acknowledges that such direction may cause the accounts to incur higher commissions or transaction costs than the accounts would otherwise incur had the client determined to effect account transactions 21  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure through alternative clearing arrangements that may be available through CCWM. Higher transaction costs adversely impact account performance. Order Aggregation. If CCWM is executing transactions directly, it will generally do so for each client independently, unless CCWM decides to purchase or sell the same securities for several clients at approximately the same time. CCWM may (but is not obligated to) combine or “bunch” such orders to seek best execution, to negotiate more favorable commission rates, or to equitably allocate differences in prices and commissions or other transaction costs among CCWM’s clients, which might have been obtained if the orders were placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among clients in proportion to the purchase and sale orders placed for each client account on any given day. CCWM will not receive any additional compensation or remuneration as a result of such aggregation. Item 13 - Review of Accounts Account Reviews For those clients to whom CCWM provides investment management services, CCWM reviews their portfolios at least quarterly, but often more frequently, for performance and client restrictions. The timeliness of these reviews is based upon the accessibility of client information from selected money managers. Two members of the Investment Committee typically review all accounts. For those clients to whom CCWM provides financial planning and/or consulting services, reviews are conducted on an “as needed” basis by the Firm. All investment advisory clients are encouraged to discuss their needs, goals, and objectives with CCWM and to keep CCWM informed of any changes thereto. CCWM contacts ongoing investment advisory clients at least annually to review its previous services or recommendations and to discuss the impact resulting from any changes in the client’s financial situation and investment objectives. Account Statements and Supplemental Reports Unless otherwise agreed upon, clients are provided with transaction confirmation notices and regular summary account statements directly from the broker-dealer or custodian for the client accounts. However, CCWM may provide clients with supplemental reports including relevant account or market-related information such as an inventory of account holdings and account performance from time to time. Those reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Clients should compare the account statements they receive from their custodian with those they receive from CCWM. Financial Planning and/or Consulting Reports Those clients to whom CCWM provides financial planning and/or consulting services will receive reports from CCWM summarizing its analysis and conclusions as requested by the client or otherwise agreed to in writing by CCWM. Review Triggers 22  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure Triggering factors for an immediate review include but are not limited to material changes in a client’s financial situation, changes in a money manager’s management team or advisory fee, changes in tax law, and political and economic events. Item 14- Client Referrals and Other Compensation CCWM receives economic benefits from Schwab including support services and/or products without cost or at a discount as described in Item 12. CCWM’s clients do not pay more for investment transactions executed or assets maintained at Schwab as a result of this arrangement. There is no corresponding commitment made by CCWM to Schwab or any other entity to invest any specific amount or percentage of client assets in any specific mutual funds, securities, or other investment products as a result of the above arrangement. CCWM does not compensate any person or entity besides its supervised persons for client referrals. Item 15 - Custody Clients are provided with written transaction confirmation notices, and a written summary account statement directly from the custodian (i.e., Schwab, etc.) at least quarterly. To the extent that CCWM provides clients with periodic account statements or reports, the client is urged to compare any statement or report provided by CCWM with the account statements received from the account custodian. The account custodian does not verify the accuracy of CCWM’s advisory fee calculation. CCWM engages in other practices and services on behalf of its clients that require disclosure at ADV Part 1, Item 9, which are subject to an annual surprise CPA examination in accordance with the requirements of Rule 206(4)-2 under the Investment Advisers Act of 1940. Item 16 - Investment Discretion If the client signs a discretionary investment advisory agreement, CCWM will be granted discretionary authority from the client at the outset of the advisory relationship. This authority will allow CCWM to select the identity, amount, time, and price at which securities are to be purchased and sold for the client’s portfolio. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account. When selecting securities and making investment decisions, CCWM observes the investment policies, limitations, and restrictions of the clients for which it provides discretionary investment advisory services. CCWM allows its clients to place reasonable restrictions on the management of their portfolio. For discretionary clients, all investment guidelines and restrictions must be agreed to in writing between CCWM and the client. CCWM consults with the client prior to each trade to obtain concurrence if a blanket trading authorization has not been given. Additionally, CCWM consults with the client prior to hiring and firing Independent Managers. 23  Citrin Cooperman Wealth Management, LLC Form ADV Part 2A, Brochure Clients who engage CCWM on a non-discretionary basis concurrently acknowledge that CCWM cannot execute any account transactions without obtaining the client’s prior consent to the transactions. Therefore, if CCWM would like to make a transaction for a client’s account (including selling a security that CCWM no longer believes is appropriate, or buying a security that CCWM believes is appropriate), and the client is unavailable to provide consent, CCWM will be unable to execute the account transactions (as it would for its discretionary clients). Affected clients may be disadvantaged as a result, which could include investment losses or missing potential gains as a result. Item 17 - Voting Client Securities As a matter of Firm policy and practice, CCWM does not have authority to, and does not vote proxies on behalf of its advisory clients, unless the particular client agreement states otherwise. The obligation to vote client proxies shall at all times rest with the client, except for those specific client assets over which an independent investment manager has assumed proxy voting authority. Clients receive proxies directly from the appropriate financial institutions. Item 18 - Financial Information CCWM has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. CCWM does not have any financial impairment that will preclude the Firm from meeting contractual commitments to clients and does not solicit fees of more than $1,200, per client, six months or more in advance. 24