# TSW Wealth Management

> TSW Wealth Management is an SEC-registered investment advisory firm in Framingham, MA, registered since 2019, reporting $100 million to $500 million in regulatory assets under management in its Form ADV filing dated March 24, 2026.

- CRD: 125209
- Filed as: TSW WEALTH MANAGEMENT
- Legal name: Wells Financial Advisors, Inc.
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Framingham, MA
- Filing period: October 2026
- Form ADV filing dated: March 24, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/125209
- AdvisorCensus page: https://advisorcensus.com/firm/tsw-wealth-management-framingham-ma-125209

## Quick answers

**How is TSW Wealth Management compensated?**
On its Form ADV (Item 5.E, October 2026), TSW Wealth Management reports these compensation arrangements: a percentage of assets under its management; hourly charges; fixed fees (other than subscription fees).

**Where is TSW Wealth Management located?**
TSW Wealth Management's principal office is in Framingham, MA, according to its Form ADV.

**Is TSW Wealth Management registered with the SEC or a state?**
TSW Wealth Management is an SEC-registered investment advisory firm, registered since 2019. Status as filed: Approved. CRD 125209.

**How much does TSW Wealth Management manage?**
TSW Wealth Management reports $279,258,283 in regulatory assets under management in its Form ADV filing dated March 24, 2026 (100% discretionary).

**How have TSW Wealth Management's assets and staff changed since 2021?**
In the Form ADV data for TSW Wealth Management: Regulatory assets under management: $203,948,315 in the October 2021 data and $279,258,283 in the October 2026 data, up 37%. Total employees: 5 in October 2021 and 5 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does TSW Wealth Management serve?**
By number of clients on Form ADV Item 5.D: high net worth individuals (75); individuals (other than high net worth individuals) (57).

**Which custodians does TSW Wealth Management use?**
TSW Wealth Management's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Charles Schwab & Co., Inc. and Investment Distributors, Inc. as custodians holding 10% or more of its separately managed account assets.

**Does TSW Wealth Management report any disciplinary disclosures?**
Reports no disclosure items on Form ADV Item 11. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/125209

**Does TSW Wealth Management state an account minimum?**
Its Form ADV Part 2A brochure dated March 16, 2026 says: "TSW generally requires a $1 million minimum for investment management services. However, TSW, in its sole discretion, may modify its minimum"

**What changed in TSW Wealth Management's recent Form ADV filings?**
In the April 2026 filing data: Regulatory assets under management went from $248,586,439 to $279,258,283 (+12%).

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management
- Hourly charges
- Fixed fees (other than subscription fees)

### Fees and minimums (Form ADV Part 2A brochure dated March 16, 2026)

- Account minimum: $1,000,000 (the brochure says it may be waived or negotiated)

> TSW generally requires a $1 million minimum for investment management services. However, TSW, in its sole discretion, may modify its minimum

As stated in the firm's brochure. Fees can differ by service and may be negotiable.

### Custodians (Schedule D, Section 5.K(3))
- Charles Schwab & Co., Inc.
- Investment Distributors, Inc.

Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.

### Regulatory assets under management (Item 5.F)
- Total: $279,258,283
- Discretionary: $279,258,283
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 57 | $30,851,546 |
| High net worth individuals | 75 | $248,362,612 |
| Charitable organizations | Fewer than 5 | $44,125 |

### Advisory services (Item 5.G)
- Financial planning services
- Portfolio management for individuals and/or small businesses

### Firm details
- Registered since: 2019 (7 years)
- Employees: 5 total, 2 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: CT, FL, MA, NH, TX
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- tswmanagement.com
- LinkedIn @WELLS-FINANCIAL-ADVISORS-INC-

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $203,948,315 | 5 | March 26, 2021 |
| October 2022 | $233,833,812 | 6 | March 27, 2022 |
| October 2023 | $203,387,997 | 5 | March 21, 2023 |
| October 2024 | $223,311,497 | 5 | March 28, 2024 |
| October 2025 | $248,586,439 | 5 | March 20, 2025 |
| October 2026 | $279,258,283 | 5 | March 24, 2026 |

Regulatory assets under management: $203,948,315 in the October 2021 data and $279,258,283 in the October 2026 data, up 37%.
Total employees: 5 in October 2021 and 5 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Regulatory assets under management went from $248,586,439 to $279,258,283 (+12%).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. TSW Wealth Management (CRD 125209): Form ADV filing data as of October 2026.