Overview
- Total Firm Assets
- $114 million
- Average High-Net-Worth Client Portfolio Size
- $7.1 million
- Stated Minimum Account Size
- $5,000,000
Fee Disclosure
1102 PARTNERS FORM ADV2A (""DISCLOSURE BROCHURE"") AND FORM ADV2B (""BROCHURE SUPPLEMENTS"")
| Min | Max | Disclosed Annual Rate |
|---|---|---|
| $0 | $3,000,000 | 0.90% |
| $3,000,001 | $6,000,000 | 0.85% |
| $6,000,001 | $10,000,000 | 0.80% |
| $10,000,001 | $15,000,000 | 0.70% |
| $15,000,001 | $20,000,000 | 0.60% |
| $20,000,001 | and above | 0.50% |
Estimated Annual Fees (Based on ADV disclosures. Where a range is given, we use the upper rate)
| Portfolio Value | Estimated Annual Fee | Effective Fee Rate |
|---|---|---|
| $1 million | Below minimum client size | |
| $5 million | $44,000 | 0.88% |
| $10 million | $84,500 | 0.84% |
| $50 million | $299,500 | 0.60% |
| $100 million | $549,500 | 0.55% |
Clients
- High-Net-Worth Share of Firm Assets
- 99.42%
- Number of High-Net-Worth Clients
- 16
- Total Client Accounts
- 69
- Discretionary Accounts
- 66
- Non-Discretionary Accounts
- 3
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 313536
Primary Brochure: 1102 PARTNERS FORM ADV2A (""DISCLOSURE BROCHURE"") AND FORM ADV2B (""BROCHURE SUPPLEMENTS"") (2026-09-18)
View Document Text
1102 Partners, LLC
Form ADV Part 2A – Disclosure Brochure
Effective: September 18, 2026
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of 1102 Partners, LLC (“1102 Partners” or the “Advisor”). If you have any questions about the content of
this Disclosure Brochure, please contact the Advisor at (312) 488-9727 or by email at info@1102partners.com.
1102 Partners is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities
authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure
Brochure provides information about 1102 Partners to assist you in determining whether to retain the Advisor.
Additional information about 1102 Partners and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 313536.
1102 Partners, LLC
57 East Delaware Place, Suite 2205, Chicago, IL 60611
Phone: (312) 488-9727
www.1102partners.com
1102 Partners, LLC
57 East Delaware Place, Suite 2205 Chicago, IL 60611
Phone: (312) 488-9727
www.1102partners.com
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory
Persons of 1102 Partners. For convenience, the Advisor has combined these documents into a single disclosure
document.
1102 Partners believes that communication and transparency are the foundation of its relationship with clients and
will continually strive to provide you with complete and accurate information at all times. 1102 Partners encourages
all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with
the Advisor.
Material Changes
The following material changes have been made to this Disclosure Brochure since the annual amendment filing on
February 25, 2026:
- The Advisor has moved its primary business location to 57 East Delaware Place, Suite 2205, Chicago,
IL 60611.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure
Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 313536. You
may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (312) 488-9727 or by
email at info@1102partners.com.
1102 Partners, LLC
57 East Delaware Place, Suite 2205 Chicago, IL 60611
Phone: (312) 488-9727
www.1102partners.com
Page 2
Item 3 – Table of Contents
Item 1 – Cover Page ............................................................................................................................................... 1
Item 2 – Material Changes ..................................................................................................................................... 2
Item 3 – Table of Contents ..................................................................................................................................... 3
Item 4 – Advisory Services .................................................................................................................................... 4
A. Firm Information .............................................................................................................................................................. 4
B. Advisory Services Offered ............................................................................................................................................... 4
C. Client Account Management ........................................................................................................................................... 6
D. Wrap Fee Programs ........................................................................................................................................................ 6
E. Assets Under Management ............................................................................................................................................. 6
Item 5 – Fees and Compensation ......................................................................................................................... 6
A. Fees for Advisory Services.............................................................................................................................................. 6
B. Fee Billing........................................................................................................................................................................ 7
C. Other Fees and Expenses .............................................................................................................................................. 7
D. Advance Payment of Fees and Termination ................................................................................................................... 7
E. Compensation for Sales of Securities ............................................................................................................................. 8
Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 8
Item 7 – Types of Clients ....................................................................................................................................... 8
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 8
A. Methods of Analysis ........................................................................................................................................................ 8
B. Risk of Loss ..................................................................................................................................................................... 9
Item 9 – Disciplinary Information ........................................................................................................................ 10
Item 10 – Other Financial Industry Activities and Affiliations .......................................................................... 10
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 11
A. Code of Ethics ............................................................................................................................................................... 11
B. Personal Trading with Material Interest ......................................................................................................................... 11
C. Personal Trading in Same Securities as Clients ........................................................................................................... 11
D. Personal Trading at Same Time as Client .................................................................................................................... 11
Item 12 – Brokerage Practices ............................................................................................................................ 11
A. Recommendation of Custodian[s] ................................................................................................................................. 11
B. Aggregating and Allocating Trades ............................................................................................................................... 12
Item 13 – Review of Accounts ............................................................................................................................. 12
A. Frequency of Reviews ................................................................................................................................................... 12
B. Causes for Reviews ...................................................................................................................................................... 13
C. Review Reports ............................................................................................................................................................. 13
Item 14 – Client Referrals and Other Compensation ........................................................................................ 13
A. Compensation Received by 1102 Partners ................................................................................................................... 13
B. Client Referrals from Promoters .................................................................................................................................... 14
Item 15 – Custody ................................................................................................................................................. 14
Item 16 – Investment Discretion ......................................................................................................................... 14
Item 17 – Voting Client Securities ....................................................................................................................... 14
Item 18 – Financial Information ........................................................................................................................... 14
Form ADV Part 2B – Brochure Supplement ....................................................................................................... 15
Item 2 – Educational Background and Business Experience .......................................................................... 16
Item 3 – Disciplinary Information ........................................................................................................................ 17
Item 4 – Other Business Activities ..................................................................................................................... 17
Item 5 – Additional Compensation ..................................................................................................................... 17
Item 6 – Supervision ............................................................................................................................................ 17
Privacy Policy ....................................................................................................................................................... 18
1102 Partners, LLC
57 East Delaware Place, Suite 2205 Chicago, IL 60611
Phone: (312) 488-9727
www.1102partners.com
Page 3
Item 4 – Advisory Services
A. Firm Information
1102 Partners, LLC (“1102 Partners” or the “Advisor”) is a registered investment advisor with the SEC. The Advisor
is organized as a Limited Liability Company (LLC) under the laws of Illinois. 1102 Partners was founded in March
2021 and is owned and operated by David M. Maley (Founder, Chief Investment Officer and Chief Compliance
Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the
advisory services provided by 1102 Partners.
B. Advisory Services Offered
1102 Partners offers investment advisory services to individuals, high net worth individuals, trusts, and estates
(each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. 1102 Partners' fiduciary commitment is further described in the Advisor’s Code of Ethics. For
more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading.
Wealth Management Services
1102 Partners provides customized wealth management services for its Clients. This is achieved through
continuous personal Client contact and interaction while providing a broad range of comprehensive financial
planning in connection with discretionary or non-discretionary investment management of Client portfolios. These
services are described below.
Asset Allocation Services - 1102 Partners works closely with each Client to identify their investment goals and risk
tolerance in order to create an asset allocation strategy. 1102 Partners will then construct a portfolio primarily
consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s
investment goals. The Advisor may also utilize equities, fixed income or options contracts to meet the needs of its
Clients. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the
overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client.
Family Office Services - 1102 Partners was founded as a Family Office for the immediate and extended family of its
principal. As such, it seeks to provide a similar level of service to its Wealth Management Clients. In addition to the
Asset Allocation Services described above,1102 Partners will provide advice and guidance on family-related topics,
including but not limited to estate planning, tax planning, philanthropy and planned giving, cash flow analysis, and
multi-generational financial literacy. 1102 Partners will work closely with a Client’s trusted advisors including but not
limited to attorneys, accountants, bookkeepers, bill payers, and insurance providers. 1102 Partners does not
charge additional fees for this enhanced level of service but rather views it as part of the Client relationship.
Equity Management Services – 1102 Partners will provide equity management services for certain Clients
depending on the Client’s needs and/or objectives. 1102 Partners will recommend internally managed equity
strategies that include but not limited to Special Situations Micro-Cap and Quality Dividend Growth strategies. 1102
Partners may allocate all or a portion of a Client’s investment portfolio into one of these strategies depending on the
Client’s investment goals and risk tolerance. A version of the Special Situations Micro-Cap Strategy, which is highly
concentrated and generally customized to a Client’s specific goals and risk tolerance, is offered with a higher
minimum investment than is typically utilized. In some limited cases, the concentrated portfolio may be managed on
a non-discretionary basis.
1102 Partners’ investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. 1102 Partners will construct, implement and monitor the portfolio to ensure it meets the goals,
objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place
reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by
the Advisor.
1102 Partners, LLC
57 East Delaware Place, Suite 2205 Chicago, IL 60611
Phone: (312) 488-9727
www.1102partners.com
Page 4
1102 Partners evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. 1102 Partners may recommend, on occasion, redistributing investment allocations to diversify
the portfolio. 1102 Partners may recommend specific positions to increase sector or asset class weightings. The
Advisor may recommend employing cash positions as a possible hedge against market movement. 1102 Partners
may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses,
business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the
position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk
deemed unacceptable for the Client’s risk tolerance.
At no time will 1102 Partners accept or maintain custody of a Client’s funds or securities, except for the limited
authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the
Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is 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. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the
assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account
to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or
increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a
retirement account to an account managed by the Advisor.
Financial Planning Services - 1102 Partners will provide a variety of financial planning services to Clients as part of
its overall wealth management services. However, certain Clients may be offered stand-alone financial planning
services, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s
financial situation, depending on their goals and objectives. Generally, such financial planning services involve
preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals
and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to,
investment planning, retirement planning, personal savings, education savings, and other areas of a Client’s
financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
1102 Partners may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s
financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may
not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date,
assuming all information and documents requested are provided promptly.
Financial planning recommendations pose a conflict between the interests of the Advisor and the Client. For
example, the Advisor has an incentive to recommend that Clients engage the Advisor for wealth management
services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory
fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or
maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made
by the Advisor, the Client is under no obligation to implement the transaction through the Advisor.
1102 Partners, LLC
57 East Delaware Place, Suite 2205 Chicago, IL 60611
Phone: (312) 488-9727
www.1102partners.com
Page 5
C. Client Account Management
Prior to engaging 1102 Partners to provide investment advisory services, each Client is required to enter into one or
more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor
and the Client. These services may include:
• Establishing an Investment Strategy – 1102 Partners, in connection with the Client, will develop a strategy
that seeks to achieve the Client’s investment goals and objectives.
• Asset Allocation – 1102 Partners will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and risk tolerance for each Client.
•
Investment Management and Supervision – 1102 Partners will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
1102 Partners does not manage or place Client assets into a wrap fee program. Wealth management services are
provided directly by 1102 Partners.
E. Assets Under Management
As of December 31, 2025, 1102 Partners manages $114,487,348 in Client assets, $89,618,363 of which is
managed on a discretionary basis and $24,868,985 on a non-discretionary basis. Clients may request more current
information at any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more
written agreements with the Advisor.
A. Fees for Advisory Services
Wealth Management Services
Wealth management fees are paid quarterly, in advance of each calendar quarter pursuant to the terms of the wealth
management agreement. Wealth management fees are based on the market value of assets under management at
the end of the prior quarter. Wealth management fees range from up to 1.25% annually based on several factors,
including: the scope and complexity of the services to be provided; the aggregate of assets to be managed; and the
overall relationship with the Advisor. Certain Clients may be offered a fixed annual fee engagement, which will not
exceed the range of fees described below. Fee ranges are generally based on the following schedule:
Fee Schedule: Asset Allocation Tiered Schedule
0.90%
0.85%
0.80%
0.70%
0.60%
0.50%
• First $3,000,000
• Next $3,000,000
• Next $4,000,000
• Next $5,000,000
• Next $5,000,000
• Amounts above $20,000,000
For Clients in the Special Situations Micro-Cap strategy, the following fee schedule is generally used:
• Fee Schedule: 1.25% of assets up to $10,000,000; 1.00% of assets above $10,000,000.
The wealth management fee in the first quarter of service is prorated from the inception date of the account[s] to the
end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. All securities held in accounts
managed by 1102 Partners will be independently valued by the Custodian. The Advisor will conduct periodic reviews
of the Custodian’s valuations to ensure accurate billing.
1102 Partners, LLC
57 East Delaware Place, Suite 2205 Chicago, IL 60611
Phone: (312) 488-9727
www.1102partners.com
Page 6
The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other
related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor
shall not receive any portion of these commissions, fees, and costs. Lower fees for comparable services may be
available from other sources.
Financial Planning Services
1102 Partners offers financial planning services as part of its overall wealth management services and fees. The
Advisor does not charge separate fees for financial planning services. For certain Clients, 1102 Partners offers
standalone financial planning services at an hourly rate of $250 per hour. Fees for standalone engagements will be
negotiated based on the nature and complexity of the services to be provided and the overall relationship with the
Advisor. An estimate for total hours and overall costs will be provided to the Client prior to engaging for standalone
financial planning services.
B. Fee Billing
Wealth Management Services
Wealth management fees are calculated by the Advisor and deducted from the Client’s account[s] at the Custodian.
The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s
account[s] at the beginning of the respective quarter. The amount due is calculated by applying the quarterly rate
(annual rate divided by 4) to the total assets under management with 1102 Partners at the end of the prior quarter.
Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the wealth
management fee. Clients are urged to review the brokerage statement from the Custodian, as the Custodian does not
perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by 1102
Partners to be paid directly from their account[s] held by the Custodian as part of the wealth management agreement
and separate account forms provided by the Custodian.
Financial Planning Services
For standalone financial planning services, fees may be invoiced up to fifty percent (50%) of the expected total fee
upon execution of the financial planning agreement. The balance shall be invoiced upon completion of the agreed
upon deliverable[s].
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than 1102 Partners, in connection with
investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities
execution fees charged by the Custodian, as applicable. The advisory fees charged by 1102 Partners are separate
and distinct from these custody and execution fees.
In addition, all fees paid to 1102 Partners for wealth management services are separate and distinct from the
expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are
described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for
the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a
possible distribution fee. A Client may be able to invest in these products directly, without the services of 1102
Partners, but would not receive the services provided by 1102 Partners which are designed, among other things, to
assist the Client in determining which products or services are most appropriate for each Client’s financial situation
and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by
1102 Partners to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for
additional information.
D. Advance Payment of Fees and Termination
Wealth Management Services
1102 Partners may be compensated for its wealth management services in advance of the quarter in which services
are rendered. Either party may terminate the wealth management agreement, at any time, by providing advance
written notice to the other party. The Client may also terminate the wealth management agreement within five (5)
business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur
charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by
1102 Partners, LLC
57 East Delaware Place, Suite 2205 Chicago, IL 60611
Phone: (312) 488-9727
www.1102partners.com
Page 7
the Client. Upon termination, the Advisor will refund any unearned, prepaid wealth management fees from the
effective date of termination to the end of the quarter. The Client’s wealth management agreement with the Advisor is
non-transferable without the Client’s prior consent.
Financial Planning Services
For standalone financial planning engagements, 1102 Partners may require an advance deposit as described above.
Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the
other party. The Client may also terminate the financial planning agreement within five (5) business days of signing
the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide
advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon
termination, the Client shall be billed for actual hours logged on the planning project times the contractual hourly rate.
The Advisor will refund any unearned, prepaid planning fees from the effective date of termination. The Client’s
financial planning agreement with the Advisor is non-transferable without the Client’s prior consent.
E. Compensation for Sales of Securities
1102 Partners does not buy or sell securities to earn commissions and does not receive any compensation for
securities transactions in any Client account, other than the wealth management fees noted above.
Item 6 – Performance-Based Fees and Side-By-Side Management
1102 Partners does not charge performance-based fees for its wealth management services. The fees charged by
1102 Partners are as described in Item 5 above and are not based upon the capital appreciation of the funds or
securities held by any Client. 1102 Partners does not manage any proprietary investment funds or limited
partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any
particular investment options to its Clients.
Item 7 – Types of Clients
1102 Partners offers investment advisory services to individuals, high net worth individuals, trusts and estates. For
Clients engaged with the Advisor for wealth management services, 1102 Partners generally requires a minimum
relationship size of $5,000,000. The minimum relationship size can be waived or reduced at the Advisor’s sole
discretion.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
1102 Partners primarily employs a fundamental analysis method in developing investment strategies for its Clients.
Research and analysis from 1102 Partners are derived from numerous sources, including financial media
companies, third-party research materials, Internet sources, and review of company activities, including annual
reports, prospectuses, press releases and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria
consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being
analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with
a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment,
it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in
the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors
these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the
Advisor’s review process are included below in Item 13 – Review of Accounts.
As noted above, 1102 Partners generally employs a long-term investment strategy for its Clients, as consistent with
their financial goals. 1102 Partners will typically hold all or a portion of a security for more than a year, but may hold
for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, 1102
1102 Partners, LLC
57 East Delaware Place, Suite 2205 Chicago, IL 60611
Phone: (312) 488-9727
www.1102partners.com
Page 8
Partners may also buy and sell positions that are more short-term in nature, depending on the goals of the Client
and/or the fundamentals of the security, sector or asset class.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. 1102 Partners will assist Clients in determining an appropriate
strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a
Client will meet their investment goals.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the
investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may
lose value and may have negative investment performance. The Advisor monitors these economic indicators to
determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are
included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client
or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or
other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts.
The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction
process. Following are some of the risks associated with the Advisor’s investment strategies:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs
will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk
based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-
ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may
dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased
or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later.
Fixed Income Risks
Fixed income is subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices
will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the
coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate
than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate
that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the
risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its
repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the
company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity
Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the
mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual
1102 Partners, LLC
57 East Delaware Place, Suite 2205 Chicago, IL 60611
Phone: (312) 488-9727
www.1102partners.com
Page 9
fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same
price as a mutual fund purchased later that same day.
Options Contracts
Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts
are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock.
This leverage can compound gains or losses.
Concentrated Portfolios
Concentrated portfolios are an aggressive and highly volatile approach to trading and investing and should be
viewed as complementary to a stable, highly predictable investment approach. Concentrated portfolios hold fewer
different stocks than a diversified portfolio and are much more likely to experience sudden dramatic price swings. In
addition, the rise or drop in price of any given holding in the portfolio is likely to have a larger impact on portfolio
performance, than a more broadly diversified portfolio.
Small and Mid-Size Company Risks
Small and mid-size companies carry additional risks because the operating histories of these companies tend to be
more limited, their earnings and revenues less predictable and their share prices more volatile than those of larger,
more established companies. The shares of smaller companies tend to trade less frequently than those of larger,
more established companies, which can adversely affect the pricing of these securities and the Advisor’s ability to
sell these securities. These companies may have limited product lines, markets or financial resources, or may
depend on a limited management group. Some of the strategy’s investments will rise and fall based on investor
perception rather than economic factors. Other investments are made in anticipation of future products, services or
events whose delay or cancellation could cause the stock price to drop.
Alternative Investments
Alternative Investments are normally investments with companies or sectors that are not publicly traded. They can
be structured in the form of equity, debt, or other hybrid structures. These investments are normally very illiquid;
therefore, they are not ideal for clients with frequent cash needs. There is normally no public market for private
equity shares, if investors need to sell their shares, they may do so at a substantial discount. These investments
should be viewed as long-term investments. These investments are highly speculative and may only be suitable for
clients who (a) understand and are willing to assume the economic, legal and other risks involved, and (b) are
financially able to assume significant losses. Before deciding to invest in Alternative Investments, clients should
carefully consider its investment objectives, level of experience, and risk appetite. The possibility exists that a client
could sustain a loss of some or all of its initial investment. Clients should be aware of all the risks associated with
Alternative Investments prior to investing.
Past performance is not a guarantee of future returns. Investing in securities and other investments involve
a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss
these risks with the Advisor.
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving 1102 Partners or its owner. 1102 Partners
values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence
on any advisor or service provider that the Client engages. The background of the Advisor or Advisory Person is
available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the
Advisor’s firm name or CRD# 313536.
Item 10 – Other Financial Industry Activities and Affiliations
The sole business of 1102 Partners is to provide investment advisory services to its Clients. Neither 1102 Partners
nor its Advisory Person is involved in other business endeavors. 1102 Partners does not maintain any affiliations
with other firms, other than contracted service providers to assist with the servicing of its Client’s accounts.
1102 Partners, LLC
57 East Delaware Place, Suite 2205 Chicago, IL 60611
Phone: (312) 488-9727
www.1102partners.com
Page 10
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
1102 Partners has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to
each Client. This Code applies to all persons associated with 1102 Partners (“Supervised Persons”). The Code was
developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each
Client. 1102 Partners and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each
Client. It is the obligation of 1102 Partners’ Supervised Persons to adhere not only to the specific provisions of the
Code, but also to the general principles that guide the Code. The Code covers a range of topics that address
employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (312) 488-
9727 or via email at info@1102partners.com.
B. Personal Trading with Material Interest
1102 Partners allows Supervised Persons to purchase or sell the same securities that may be recommended to
and purchased on behalf of Clients. 1102 Partners does not act as principal in any transactions. In addition, the
Advisor does not act as the general partner of a fund, or advise an investment company. 1102 Partners does not
have a material interest in any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
1102 Partners allows Supervised Persons to purchase or sell the same securities that may be recommended to
and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients
presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and
procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public
information controls); gifts and entertainment; outside business activities and personal securities reporting. When
trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The
fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more
advantageous terms than Client trades, or by trading based on material non-public information. This risk is
mitigated by 1102 Partners requiring reporting of personal securities trades by its Supervised Persons for review by
the Chief Compliance Officer (“CCO”). The Advisor has also adopted written policies and procedures to detect the
misuse of material, non-public information.
D. Personal Trading at Same Time as Client
While 1102 Partners allows Supervised Persons to purchase or sell the same securities that may be recommended
to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards.
At no time will 1102 Partners, or any Supervised Person of 1102 Partners, transact in any security to the
detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
1102 Partners does not have discretionary authority to select the broker-dealer/custodian for custody and execution
services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets
and authorize 1102 Partners to direct trades to the Custodian as agreed upon in the wealth management
agreement. Further, 1102 Partners does not have the discretionary authority to negotiate commissions on behalf of
Clients on a trade-by-trade basis.
Where 1102 Partners does not exercise discretion over the selection of the Custodian, it may recommend the
Custodian to Clients for custody and execution services. Clients are not obligated to use the recommended
Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not
recommended by 1102 Partners. However, the Advisor may be limited in the services it can provide if the
recommended Custodian is not engaged. 1102 Partners may recommend the Custodian based on criteria such as,
but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and
its reputation and/or the location of the Custodian’s offices.
1102 Partners, LLC
57 East Delaware Place, Suite 2205 Chicago, IL 60611
Phone: (312) 488-9727
www.1102partners.com
Page 11
1102 Partners will generally recommend that Clients establish their account[s] at Charles Schwab & Co., Inc.
(“Schwab”), a FINRA-registered broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified
custodian”. 1102 Partners maintains an institutional relationship with Schwab, whereby the Advisor receives
economic benefits from Schwab. Please see Item 14 below.
With certain Client custodial relationships, the Advisor may have the ability to place trades at one or more brokers
of its choice, which, in addition to providing trade execution, may provide 1102 Partners with proprietary investment
research products and/or services which assist 1102 Partners in its decision- making process. Such research
generally will be used to service all of the Advisor’s Clients, however, brokerage commissions paid by one Client
may be used to pay for research that is not used in managing that Client’s portfolio. The receipt of investment
research products and/or services as well as the allocation of the benefit of such investment research products
and/or services poses a conflict of interest because the Advisor does not have to produce or pay for the products or
services. These trades may be done at higher commissions than those charged by other brokers.
Following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor
enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and
other services. 1102 Partners does not participate in soft dollar programs sponsored or offered by any
broker-dealer/custodian. However, the Advisor receives certain economic benefits from its principal
Custodian. It also may receive research from brokers it uses for execution of trades that settle at other
custodians chosen by Clients.
2. Brokerage Referrals - 1102 Partners does not receive any compensation from any third party in connection with
the recommendation for establishing an account.
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where 1102 Partners will place
trades within the established account[s] at the Custodian designated by the Client. To note, not all advisers require
their clients to direct brokerage. Further, all Client accounts are traded within their respective account[s]. The
Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own
account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from
another Client’s account[s]). 1102 Partners will not be obligated to select competitive bids on securities transactions
and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the
Custodian.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution,
4) confidentiality and 5) skill required of the Custodian. 1102 Partners will execute its transactions through the
Custodian as authorized by the Client. 1102 Partners may aggregate orders in a block trade or trades when
securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading
day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold
by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or
other written statement. This must be done in a way that does not consistently advantage or disadvantage any
particular Clients’ accounts. Clients who choose a custodian other than the principal Custodian (Schwab) will not be
able to participate in such aggregate transactions.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by David M. Maley, Chief Investment
Officer and Chief Compliance Officer of 1102 Partners. Formal reviews are generally conducted at least annually or
more frequently depending on the needs of the Client.
1102 Partners, LLC
57 East Delaware Place, Suite 2205 Chicago, IL 60611
Phone: (312) 488-9727
www.1102partners.com
Page 12
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least
annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result
of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or
withdrawals in the Client’s account[s]. The Client is encouraged to notify 1102 Partners if changes occur in the
Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may
be triggered by material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage
statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the
Custodian’s website so that the Client may view these reports and their account activity. Client brokerage
statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also
provide Clients with periodic written reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by 1102 Partners
1102 Partners is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment
product. 1102 Partners does not receive commissions or other compensation from product sponsors, broker-dealers
or any un-related third party. 1102 Partners may refer Clients to various unaffiliated, non-advisory professionals (e.g.
attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its
Clients. Likewise, 1102 Partners may receive non-compensated referrals of new Clients from various third-parties.
Participation in Institutional Advisor Platform
1102 Partners has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit,
a division of Schwab dedicated to serving independent advisory firms like 1102 Partners. As a registered
investment advisor participating on the Schwab Advisor Services platform, 1102 Partners receives access to
software and related support without cost because the Advisor renders investment management services to Clients
that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but
not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at
all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic
benefits from a custodian creates a potential conflict of interest since these benefits may influence the Advisor's
recommendation of this custodian over one that does not furnish similar software, systems support, or services.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of Client’s funds and securities. Through
Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able
to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and
other investments without having to adhere to investment minimums that might be required if the Client were to
directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology,
research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts,
the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with
Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may
not directly benefit all Clients.
Services that May Only Benefit the Advisor – Schwab also offers other services and financial support to 1102
Partners that may not benefit the Client, including: educational conferences and events, consulting services, and
discounts for various service providers. Access to these services creates a financial incentive for the Advisor to
recommend Schwab, which results in a conflict of interest. 1102 Partners believes, however, that the selection of
Schwab as Custodian is in the best interests of its Clients.
1102 Partners, LLC
57 East Delaware Place, Suite 2205 Chicago, IL 60611
Phone: (312) 488-9727
www.1102partners.com
Page 13
B. Client Referrals from Promoters
The Advisor does not compensate, either directly or indirectly, any affiliated or unaffiliated parties (“Promoters”) for
Client referrals.
Item 15 – Custody
The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place all
assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and securities
and direct the Advisor to utilize that Custodian for security transactions in the account[s]. The Client should review
statements provided by the Custodian, as the Custodian does not perform this review. For more information about
custodians and brokerage practices, see Item 12 – Brokerage Practices.
If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have
custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have
adopted safeguards to ensure that the money movements are completed in accordance with the Client’s
instructions.
Item 16 – Investment Discretion
1102 Partners generally has discretion over the selection and amount of securities to be bought or sold in Client
accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be
subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to
by 1102 Partners. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of
such authority will be evidenced by the Client's execution of a wealth management agreement containing all
applicable limitations to such authority. All discretionary trades made by 1102 Partners will be in accordance with
each Client's investment objectives and goals.
When the Advisor does not have discretion over the selection and amount of securities to be bought or sold in Client
accounts without obtaining prior approval from the Client. The Advisor will contact the Client and obtain approval prior
to executing trades or allocating investment assets.
Item 17 – Voting Client Securities
1102 Partners does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements
directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client
retains the sole responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither 1102 Partners, nor its management, have any adverse financial situations that would reasonably impair the
ability of 1102 Partners to meet all obligations to its Clients. Neither 1102 Partners, nor any of its Advisory Persons,
have been subject to a bankruptcy or financial compromise. 1102 Partners is not required to deliver a balance
sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for
services to be performed six months or more in the future.
1102 Partners, LLC
57 East Delaware Place, Suite 2205 Chicago, IL 60611
Phone: (312) 488-9727
www.1102partners.com
Page 14
Form ADV Part 2B – Brochure Supplement
for
David M. Maley, CFP®
Founder, Chief Investment Officer, and Chief Compliance Officer
Effective: September 18, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of David
M. Maley, CFP® (CRD# 1332635) in addition to the information contained in the 1102 Partners, LLC (“1102
Partners” or the “Advisor”, CRD# 313536) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the 1102 Partners Disclosure Brochure or this
Brochure Supplement, please contact us at (312) 488-9727 or by email at info@1102partners.com.
Additional information about Mr. Maley is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 1332635.
1102 Partners, LLC
57 East Delaware Place, Suite 2205 Chicago, IL 60611
Phone: (312) 488-9727
www.1102partners.com
Page 15
Item 2 – Educational Background and Business Experience
David M. Maley, CFP®, born in 1960, is dedicated to advising Clients of 1102 Partners as the Founder, Chief
Investment Officer, and Chief Compliance Officer. Mr. Maley earned an MBA from University of Chicago in 1984.
Mr. Maley also earned a BBA from University of Notre Dame in 1982. Additional information regarding Mr. Maley’s
employment history is included below.
Employment History:
1102 Partners, LLC, Founder, Chief Investment Officer, and Chief Compliance Officer
Ariel Investments, LLC, Senior Vice President
Maple Hill Capital Management, LLC, President and Chief Investment Officer
Harris Bank, Vice President, Portfolio Manager
Self Employed, Personal and Family Investments
Goldman Sachs, Vice President
04/2021 to Present
04/2009 to 07/2021
08/2002 to 04/2009
10/1992 to 03/2009
02/1992 to 10/1992
07/1984 to 02/1992
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 87,000 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 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 CFP Board’s
enforcement process, which could result in suspension or permanent revocation of their CFP®.
1102 Partners, LLC
57 East Delaware Place, Suite 2205 Chicago, IL 60611
Phone: (312) 488-9727
www.1102partners.com
Page 16
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Maley. Mr. Maley has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Mr. Maley.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Maley.
However, we do encourage you to independently view the background of Mr. Maley on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
1332635.
Item 4 – Other Business Activities
Board Member
Mr. Maley is a board member of Joseph Maley Foundation located in Indianapolis, IN. He spends approximately 1
hour or less a month during trading hours in his role as a board member.
Committee Member
Mr. Maley is a Finance and Investment Committee member of Thresholds, located in Chicago, IL. He spends
approximately 1-3 hours per month during trading hours in his role as a Committee member.
Item 5 – Additional Compensation
Mr. Maley has additional business activities listed in Item 4, but no additional compensation is received from those
activities.
Item 6 – Supervision
Mr. Maley serves as the Founder, Chief Investment Officer, and Chief Compliance Officer of 1102 Partners. Mr.
Maley can be reached at (312) 488-9727.
1102 Partners has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of 1102 Partners. Further, 1102 Partners is subject to
regulatory oversight by various agencies. These agencies require registration by 1102 Partners and its Supervised
Persons. As a registered entity, 1102 Partners is subject to examinations by regulators, which may be announced
or unannounced. 1102 Partners is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
1102 Partners, LLC
57 East Delaware Place, Suite 2205 Chicago, IL 60611
Phone: (312) 488-9727
www.1102partners.com
Page 17
Privacy Policy
Effective: September 18, 2026
Our Commitment to You
1102 Partners, LLC (“1102 Partners” or the “Advisor”) is committed to safeguarding the use of personal information
of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in
our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your private
information, and we do everything that we can to maintain that trust. 1102 Partners (also referred to as "we", "our"
and "us”) protects the security and confidentiality of the personal information we have and implements controls to
ensure that such information is used for proper business purposes in connection with the management or servicing
of our relationship with you.
1102 Partners does not sell your non-public personal information to anyone. Nor do we provide such information to
others except for discrete and reasonable business purposes in connection with the servicing and management of
our relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set forth
in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing
your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose
how we collect, share, and protect your personal information.
What information do we collect from you?
Driver’s license number
Date of birth
Social security or taxpayer identification number Assets and liabilities
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Other advisory agreements and legal documents
Transactional information with us or others
Account applications and forms
Investment questionnaires and suitability
documents
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural and
electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a
secure office environment. Our technology vendors provide security and access control over personal information
and have policies over the transmission of data. Our associates are trained on their responsibilities to protect
Client’s personal information.
We require third parties that assist in providing our services to you to protect the personal information they receive
from us.
1102 Partners, LLC
57 East Delaware Place, Suite 2205 Chicago, IL 60611
Phone: (312) 488-9727
www.1102partners.com
Page 18
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information.
Basis For Sharing
Do we share?
Can you limit?
Yes
No
No
Not Shared
Yes
Yes
No
Not Shared
Servicing our Clients
We may share non-public personal information with non-affiliated third
parties (such as administrators, brokers, custodians, regulators, credit
agencies, other financial institutions) as necessary for us to provide
agreed upon services to you, consistent with applicable law, including but
not limited to: processing transactions; general account maintenance;
responding to regulators or legal investigations; and credit reporting.
Marketing Purposes
1102 Partners does not disclose, and does not intend to disclose,
personal information with non-affiliated third parties to offer you services.
Certain laws may give us the right to share your personal information with
financial institutions where you are a customer and where 1102 Partners
or the client has a formal agreement with the financial institution. We will
only share information for purposes of servicing your accounts, not
for marketing purposes.
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent[s] or
representative[s].
Information About Former Clients
1102 Partners does not disclose and does not intend to disclose, non-
public personal information to non-affiliated third parties with respect to
persons who are no longer our Clients.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the
previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal
information other than as described in this notice unless we first notify you and provide you with an opportunity to
prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting
us at (312) 488-9727 or via email at info@1102partners.com.
1102 Partners, LLC
57 East Delaware Place, Suite 2205 Chicago, IL 60611
Phone: (312) 488-9727
www.1102partners.com
Page 19