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JMAC Enterprises LLC dba Brick
House Strategic Wealth
Form ADV Part 2A – Disclosure Brochure
Effective: April 24, 2025
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of JMAC Enterprises LLC (“JMAC” or the “Advisor”). The Advisor conducts business under the practice
name (“doing business as” or “dba” name) Brick House Strategic Wealth. If you have any questions about the
content of this Disclosure Brochure, please contact the Advisor at (267) 753-7066.
JMAC 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 JMAC to assist you in determining whether to retain the Advisor.
Additional information about JMAC 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# 312710.
PA Office:
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7066 * Fax: (215) 860-1687
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7066 * Fax: 215-860-1687
Page 1
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 JMAC. For convenience, the Advisor has combined these documents into a single disclosure document.
JMAC 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. JMAC encourages all current
and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor.
Material Changes
There are the following Material Changes to this Disclosure Brochure since the last filing and distribution to Clients.
The firm has updated its ownership. (Item 4)
The firm has removed one of its DBAs. (Item 4)
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# 312710. You
may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (267) 753-7065.
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7066 * Fax: 215-860-1687
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Item 3 – Table of Contents
Contents
Form ADV Part 2A – Disclosure Brochure ....................................................................................................................... 1
Item 2 – Material Changes .............................................................................................................................................. 2
Item 3 – Table of Contents .............................................................................................................................................. 3
Item 4 – Advisory Services .............................................................................................................................................. 5
Item 5 – Fees and Compensation .................................................................................................................................... 7
Item 6 – Performance-Based Fees and Side-By-Side Management ............................................................................... 9
Item 7 – Types of Clients ................................................................................................................................................. 9
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ......................................................................... 10
Item 9 – Disciplinary Information ................................................................................................................................... 11
Item 10 – Other Financial Industry Activities and Affiliations ......................................................................................... 11
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................................. 12
Item 12 – Brokerage Practices ...................................................................................................................................... 12
Item 13 – Review of Accounts ....................................................................................................................................... 13
Item 14 – Client Referrals and Other Compensation ..................................................................................................... 14
Item 15 – Custody ......................................................................................................................................................... 15
Item 16 – Investment Discretion .................................................................................................................................... 15
Item 17 – Voting Client Securities ................................................................................................................................. 15
Item 18 – Financial Information ..................................................................................................................................... 15
Form ADV Part 2A – Appendix 1 ................................................................................................................................... 16
Item 2 – Material Changes ............................................................................................................................................ 17
Item 3 – Table of Contents ............................................................................................................................................ 17
Item 4 – Services Fees and Compensation ................................................................................................................... 17
Item 5 – Account Requirements and Types of Clients ................................................................................................... 19
Item 6 – Portfolio Manager Selection and Evaluation .................................................................................................... 19
Item 7 – Client Information Provided to Portfolio Managers .......................................................................................... 21
Item 8 – Client Contact with Portfolio Managers ............................................................................................................ 21
Item 9 – Additional Information ...................................................................................................................................... 21
Form ADV Part 2B – Brochure Supplement .................................................................................................................. 23
Item 2 – Educational Background and Business Experience......................................................................................... 23
Item 3 Disciplinary Information ....................................................................................................................................... 24
Item 4 – Other Business Activities ................................................................................................................................. 24
Item 5 – Additional Compensation ................................................................................................................................. 24
Item 6 – Supervision ...................................................................................................................................................... 25
Form ADV Part 2B – Brochure Supplement .................................................................................................................. 26
Item 2 – Educational Background and Business Experience ........................................................................................ 26
Item 3 – Disciplinary Information ................................................................................................................................... 27
Item 4 – Other Business Activities ................................................................................................................................. 27
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7066 * Fax: 215-860-1687
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Item 5 – Additional Compensation ................................................................................................................................. 27
Item 6 – Supervision ...................................................................................................................................................... 28
Form ADV Part 2B – Brochure Supplement .................................................................................................................. 29
Item 2 – Educational Background and Business Experience ........................................................................................ 29
Item 3 – Disciplinary Information ................................................................................................................................... 29
Item 4 – Other Business Activities ................................................................................................................................. 30
Item 5 – Additional Compensation ................................................................................................................................. 30
Item 6 – Supervision ...................................................................................................................................................... 30
Privacy Policy ................................................................................................................................................................ 31
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7066 * Fax: 215-860-1687
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Item 4 – Advisory Services
A. Firm Information
JMAC Enterprises LLC (“JMAC” or the “Advisor”) is a registered investment advisor with the U.S. Securities and
Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of
the Commonwealth of Pennsylvania. JMAC was founded in April 2017 and became a registered investment advisor
in February 2021. JMAC Enterprises LLC is owned by Brick House Advisory, Inc. Brick House Advisory is wholly
owned by Robert C. Macaulay.
The Advisor is operated by Robert C. Macaulay (Founder, Managing Principal, and Chief Compliance Officer). This
Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by JMAC. The Advisor conducts business under the practice name (“doing business as” or “dba”
name) Brick House Strategic Wealth.
B. Advisory Services Offered
JMAC offers wealth management services to individuals, high net worth individuals, trusts, estates, businesses,
retirement plans, and pension plans (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. JMAC's 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
JMAC 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 investment management of Client portfolios. These services are described below.
Investment Management Services – JMAC provides discretionary investment management services. JMAC works
closely with each Client to identify their investment goals, objectives, risk tolerance and financial situation to create
a portfolio strategy. JMAC will construct an investment portfolio consisting of exchange-traded funds (“ETFs”),
stocks, bonds, mutual funds, independent managers, and/or options to achieve the Client’s investment goals. The
Advisor may retain a Client’s legacy investments based on portfolio fit and/or tax considerations.
JMAC’s 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. JMAC
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.
JMAC evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. JMAC may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. JMAC 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. JMAC 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 JMAC 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.
Use of Independent Managers - JMAC may recommend that Clients utilize one or more unaffiliated investment
managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment
portfolio, based on the Client’s needs and objectives. The Advisor will perform initial and ongoing oversight and due
diligence over each Independent Manager to ensure the strategy remains aligned with Clients investment
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7066 * Fax: 215-860-1687
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objectives and overall best interests. The Client will be provided with the Independent Manager's Form ADV Part
2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures).
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 – JMAC will typically provide a variety of financial planning and consulting services to
Clients. Services are offered in several areas of a Client’s financial situation, depending on their goals and
objectives. Financial planning services may 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,
estate planning, personal savings, education savings, asset protection, business planning, 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. For business consulting, JMAC
may make recommendations related to succession planning, protection analysis, employer benefits planning, and
executive compensation planning. JMAC may also refer Clients to an accountant, attorney or other specialists, as
appropriate for their unique situation.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for
investment 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.
Retirement Plan Advisory Services
JMAC may provide non-discretionary investment management through 3(21) retirement plan advisory services or
discretionary investment management through 3(38) retirement plan advisory services on behalf of retirement plans
(each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are
designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each
engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:
Investment Policy Statement (“IPS”) Support
• Vendor Analysis
• Employee Enrollment and Education Tracking
•
• Discretionary & Non-discretionary Investment Management
• Performance Reports
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
• Benchmarking Services
These services are provided by JMAC serving in the capacity as a fiduciary under the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan
Sponsor is provided with a written description of JMAC fiduciary status, the specific services to be rendered and all
direct and indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging JMAC to provide wealth management 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
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7066 * Fax: 215-860-1687
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Client. These services may include:
• Establishing an Investment Strategy – JMAC, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s goals and objectives.
• Asset Allocation – JMAC will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – JMAC will develop a portfolio for the Client that is intended to meet the stated goals
and objectives of the Client.
•
Investment Management and Supervision – JMAC will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
JMAC includes securities transaction fees, administrative fees, and custodial fees (herein “Covered Costs”)
together with its wealth management fees. Including these fees into a single asset-based fee is considered a “Wrap
Fee Program”. The Advisor sponsors the JMAC Wrap Fee Program solely as a supplemental disclosure regarding
the combination of fees A Wrap Fee Program may not be the lowest cost option if a Client were to pay for these
fees separately. Please see Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to this
Disclosure Brochure.
E. Assets Under Management
As of December 31, 2024, JMAC manages $918,779,505 in Client assets JMAC manages $912,117,066 on a
discretionary basis and $6,662,439 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 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 up to 1.50% annually based on
several factors, including: the scope and complexity of the services to be provided; the level of assets to be
managed; and the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting
requirements, portfolio restrictions and other complexities may be charged a higher fee.
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 JMAC will be independently valued by the Custodian. The Advisor will conduct periodic
reviews of the Custodian’s valuations.
Financial Planning Services
The Advisor typically offers financial planning services as part of its overall wealth management services. The
Advisor may also provide standalone financial planning or consulting services for an annual engagement fee
ranging from $2,500 to $25,000 per year. Fees may be negotiable based on the nature and complexity of the
services to be provided and the overall relationship with the Advisor. An estimate for total costs will be determined
prior to engaging for these services.
Use of Independent Managers
As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio utilizing one or more
Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an
Independent Manager. The Advisor will only earn its wealth management fee as described above. The Advisor may
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7066 * Fax: 215-860-1687
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allocate a portion of the advisory fee collected to the Independent Managers pursuant to the terms of the executed
agreement between the Advisor and the Independent Manager. In certain instances, the Client will be separately
charged an asset-based fee by the Independent Managers.
Retirement Plan Advisory Services
Retirement plan advisory fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the
agreement. Fees are based on the market value of assets under management at the end of the prior quarter.
Retirement plan advisory fees range up to 1.50% annually.
B. Fee Billing
Wealth Management Services
Wealth management fees are calculated by the Advisor or its delegate 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 JMAC 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 also review and compare the statement provided by the Advisor to
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 JMAC 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, fees are paid monthly or quarterly (“Billing Period”), in advance of each Billing
Period, pursuant to the terms of the financial planning agreement. The amount due is calculated by applying the
annual fee divided by twelve (12) or four (4) respectively.
Use of Independent Managers
For Client accounts implemented through an Independent Manager, the Client’s overall fees may include JMAC’s
wealth management fee (as noted above) plus the asset-based fees charged by the Independent Manager[s], as
applicable. In certain instances, the Independent Manager or the Advisor may assume responsibility for calculating
the Independent Managers asset-based fee and separately deduct the fees from the Client’s account[s].
Retirement Plan Advisory Services
Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the
Plan, depending on the terms of the retirement plan advisory agreement.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than JMAC, in connection with
investments made on behalf of the Client’s account[s]. JMAC includes Covered Costs as part of its overall wealth
management fee through the JMAC Wrap Fee Program. Securities transaction fees for Client-directed trades may
be charged back to the Client. Please see Item 4.D. above as well as Appendix 1 – Wrap Fee Program Brochure.
In addition, all fees paid to JMAC 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 JMAC, but would
not receive the services provided by JMAC 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 JMAC 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
JMAC 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
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7066 * Fax: 215-860-1687
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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 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 nontransferable without the Client’s prior consent.
Financial Planning Services
For standalone financial planning, the Advisor requires an advance payment 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 Advisor will refund any unearned, prepaid fees from the effective date of termination to the end of the Billing
Period. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior
consent.
Use of Independent Managers
If the Advisor has determined that an Independent Manager is no longer in the Client’s best interest, the Advisor will
have the discretion to terminate the relationship with the Independent Manager. The terms for termination are set
forth in the respective agreements between the Advisor and the Independent Managers.
Retirement Plan Advisory Services
JMAC is compensated for its retirement plan advisory services at the beginning of the quarter before services are
rendered. Either party may request to terminate a retirement plan advisory agreement, at any time, by providing
advance written notice to the other party. The Client shall be responsible for retirement plan advisory fees up to and
including the effective date of termination. 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 retirement plan
advisory agreement with the Advisor is non-transferable without the Client’s prior consent.
E. Compensation for Sales of Securities
JMAC 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.
Certain Advisory Persons are also licensed as independent insurance professionals. As an independent insurance
professional, an Advisory Person will earn commission-based compensation for selling insurance products,
including insurance products they sell to Clients. Insurance commissions earned by Advisory Persons are separate
and in addition to our advisory fees. This practice presents a conflict of interest as the Advisory Person has an
incentive to recommend insurance products to Clients for the purpose of generating commissions rather than solely
based on the Client’s needs. Clients are under no obligation, contractually or otherwise, to purchase insurance
products through any Advisory Person affiliated with the Advisor. Please see Item 10 below.
Item 6 – Performance-Based Fees and Side-By-Side Management
JMAC does not charge performance-based fees for its wealth management services. The fees charged by JMAC
are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by
any Client.
JMAC 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
JMAC offers wealth management services to individuals, high net worth individuals, trusts, estates, businesses,
retirement plans, and pension plans. The amount of each type of Client is available on JMAC’s Form ADV Part 1A.
These amounts may change over time and are updated at least annually by the Advisor. JMAC generally requires a
minimum relationship size of $500,000. This amount may be waived or reduced at our sole discretion.
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7066 * Fax: 215-860-1687
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Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
JMAC primarily employs fundamental and technical analysis methods in developing investment strategies for its
Clients. Research and analysis from JMAC 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.
Technical analysis involves the analysis of past market data rather than specific company data in determining the
recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and
trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk
in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if
the trend will eventually reoccur, there is no guarantee that JMAC will be able to accurately predict such a
reoccurrence.
As noted above, JMAC generally employs a long-term investment strategy for its Clients, as consistent with their
financial goals. JMAC 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, JMAC 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. JMAC 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.
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7066 * Fax: 215-860-1687
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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 bidask
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.
Bond Risks
Bonds are 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
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.
Margin Borrowings
The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities
pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin
call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory
liquidation of the pledged securities to compensate for the decline in value.
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 JMAC or management persons. JMAC 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 backgrounds of the Advisor or Advisory Persons are
available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the
Advisor’s firm name or CRD#312710.
Item 10 – Other Financial Industry Activities and Affiliations
Insurance Agency Affiliations
Certain Advisory Persons are also licensed as independent insurance professionals. As an insurance professional,
an Advisory Person will receive customary commissions and other related revenues from the various insurance
companies whose products are sold. Advisory Persons are not required to offer the products of any particular
insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice
presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no
obligation to implement any recommendations made by an Advisory Person or the Advisor.
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7066 * Fax: 215-860-1687
Page 11
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
JMAC 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 JMAC (“Supervised Persons”). The Code was developed to
provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. JMAC and
its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of
JMAC’s 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 (267) 753-7065.
B. Personal Trading with Material Interest
JMAC allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. JMAC 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. JMAC does not have a material interest
in any securities traded in Client accounts.
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]).
C. Personal Trading in Same Securities as Clients
JMAC 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 JMAC 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 JMAC 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 JMAC, or any Supervised Person of JMAC, transact in any security to the detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
JMAC 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 JMAC to direct trades to the Custodian as agreed upon in the wealth management agreement.
Further, JMAC does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade
by-trade basis.
Where JMAC 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 Custodian recommended by the
Advisor and will not incur any extra fee or cost associated with using a custodian not recommended by JMAC.
However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged.
JMAC 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.
JMAC will generally recommend that Clients establish their account[s] at Trade-PMR, Inc. (“Trade-PMR”), and
Fidelity Brokerage Services LLC “(Fidelity)” (collectively “Custodian”). Trade-PMR clears trades and custodies
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7066 * Fax: 215-860-1687
Page 12
assets with First Clearing. First Clearing is a trade name used by Wells Fargo Clearing Services, LLC, a non-bank
affiliate of Wells Fargo & Company. Trade-PMR acts as an introducing broker on a fully disclosed basis. Trade-
PMR and Fidelity are FINRA registered broker-dealers and members of SIPC. JMAC maintains an institutional
relationship with Trade PMR and Fidelity, whereby JMAC receives certain economic benefits as detailed in Item 14
below.
Following are additional details regarding the brokerage practices of the Advisor:
Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor
1.
enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and
other services. JMAC does not participate in soft dollar programs sponsored or offered by any
brokerdealer/custodian. However, the Advisor receives certain economic benefits from the Custodian.
Please see Item 14 below.
Brokerage Referrals - JMAC does not receive any compensation from any third party in connection with
2.
the recommendation for establishing an account.
3.
Directed Brokerage - All Clients are required to utilize one of JMAC’s recommended Custodians. JMAC
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. JMAC will execute its transactions through the Custodian as
authorized by the Client. JMAC 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.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons of JMAC and
periodically by the Chief Compliance Officer of JMAC. Formal reviews are generally conducted at least annually or
more frequently depending on the needs of the Client.
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 JMAC 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 reports regarding their holdings, allocations, and performance.
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7066 * Fax: 215-860-1687
Page 13
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by JMAC
JMAC is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment product.
JMAC does not receive commissions or other compensation from product sponsors, broker-dealers or any un-
related third party. JMAC 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, JMAC may receive non-compensated referrals of new Clients from various third-parties.
Participation in Institutional Advisor Platform – Trade-PMR
JMAC has established an institutional relationship with Trade-PMR, Inc. (“Trade-PMR”) to assist the Advisor in
managing Client account[s]. Trade-PMR clears trades and custodies assets with First Clearing. First Clearing is a
trade name used by Wells Fargo Clearing Services, LLC, a non-bank affiliate of Wells Fargo & Company.
TradePMR acts as an introducing broker on a fully disclosed basis. Trade-PMR and First Clearing are FINRA
registered broker-dealers and members of SIPC. The Advisor receives access to software and related support
because the Advisor renders wealth management services to Clients that maintain assets at Trade-PMR. The
software and related systems support may benefit the Advisor, but not its Clients directly. 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 the Custodian creates a potential conflict of interest since these benefits
may influence the Advisor's recommendation of the Custodian over one that does not furnish similar software,
systems support, or services. Additionally, the Advisor may receive the following benefits from Trade-PMR: receipt
of duplicate Client confirmations and bundled duplicate statements; access to a trading desk that exclusively
services its institutional participants; access to block trading which provides the ability to aggregate securities
transactions and then allocate the appropriate shares to Client accounts; and access to an electronic
communication network for Client order entry and account information.
Participation in Institutional Advisor Platform - Fidelity
JMAC has an arrangement with Fidelity through which Fidelity provides JMAC with Fidelity's "platform" services.
The platform services include, among others, brokerage, custodial, administrative support, record keeping, and
related services that are intended to support intermediaries like JMAC in conducting business and in serving the
best interests of their clients but that also benefit JMAC. Fidelity charges brokerage commissions and transaction
fees for effecting certain securities transactions (i.e., transactions fees are charged for certain no-load mutual
funds, commissions are charged for certain equity and debt securities transactions). Fidelity enables JMAC to
obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction
charges. Fidelity’s fees and commission rates are generally considered discounted from customary retail rates.
However, the commissions and/or transaction fees charged by Fidelity may be higher or lower than those charged
by other custodians and broker-dealers. As part of the arrangement, Fidelity also makes available to JMAC, at no
additional charge to us, certain research and brokerage services, including research services obtained by Fidelity
directly from independent research companies to manage accounts for which JMAC has investment discretion. As
a result of receiving these services for no additional cost, JMAC has an incentive to continue to use or expand the
use of Fidelity's services, which creates a conflict of interest. JMAC has examined this conflict and has determined
that the relationship is in the best interests of clients by conducting a qualitative and quantitative review of Fidelity’s
brokerage and custodial services. JMAC also periodically reviews the commissions charged and the services
provided by Fidelity and compares those with other broker-dealers.
B. Client Referrals from Solicitors
JMAC does not compensate non-advisory personnel (solicitors/promoters) for client referrals.
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7066 * Fax: 215-860-1687
Page 14
Item 15 – Custody
JMAC deducts its fees directly from client accounts. Clients should review statements provided by the Custodian
and compare to any reports provided by JMAC to ensure accuracy as the Custodian does not perform this review.
For more information about custodians and brokerage practices, see Item 12 - Brokerage Practices.
Additionally, the Advisor may have custody if the Client gives the Advisor the authority to move money from one
account to another account, also called a standing letter of authorization (SLOA) In order to avoid additional
regulatory requirements in these cases, the Custodian and the Advisor have adopted the safeguards specified by
the SEC to ensure that the money movements are completed in accordance with the Client’s instructions in lieu of
undergoing an annual audit.
Item 16 – Investment Discretion
JMAC 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 JMAC.
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 JMAC will be in accordance with each Client's investment
objectives and goals.
Item 17 – Voting Client Securities
JMAC accepts proxy-voting responsibility for Clients. In such instances, the Advisor will cast proxy votes only in a
manner it believes is consistent with its fiduciary duty to Clients of the Advisor.
The Advisor has engaged Broadridge Investor Communications Solutions, Inc. (“Broadridge”), a third-party,
independent proxy advisory firm, to provide it with research, analysis, and recommendations on the various proxy
proposals for the Client securities that the Advisor manages with the aim of maximizing shareholder value. In
engaging Broadridge for that purpose, the Advisor will review as necessary, Broadridge’s Proxy Paper Guidelines
for the current proxy voting season and will approve the summary of Broadridge’s positions on the voting positions
it recommends for the types of proposals most frequently presented, including: election and composition of
directors; financial reporting; compensation of management and directors; corporate governance structure and
antitakeover measures; and environmental and social risks to operations. The Advisor is in agreement with the
approach Broadridge has set forth in its current Proxy Paper Guidelines for voting proxies. Although the Advisor,
based on its approval of the positions in the Proxy Paper Guidelines, expects to vote proxies according to
Broadridge’s recommendations, certain issues may need to be considered on a case-by-case basis due to the
diverse and continually evolving nature of corporate governance issues. If such cases should arise, then the
Advisor will devote appropriate time and resources to consider those issues.
Where the Advisor is responsible for voting proxies on behalf of a Client, the Client cannot direct the Advisor’s vote
on a particular solicitation. The Client, however, can revoke the Advisor’s authority to vote proxies. In situations
where there may be a conflict of interest in the voting of proxies due to business or personal relationships that the
Advisor maintains with persons having an interest in the outcome of certain votes, the Advisor will take appropriate
steps, whether by following Broadridge’s third-party recommendation or otherwise, to ensure that proxy voting
decisions are made in what it believes is the best interest of its Clients and are not the product of any such conflict.
Item 18 – Financial Information
Neither JMAC, nor its management persons, have any adverse financial situations that would reasonably impair the
ability of JMAC to meet all obligations to its Clients. Neither JMAC, nor any of its Advisory Persons, have been
subject to a bankruptcy or financial compromise. JMAC 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.
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7066 * Fax: 215-860-1687
Page 15
JMAC Enterprises LLC dba Brick House Strategic Wealth
Form ADV Part 2A – Appendix 1
(“Wrap Fee Program Brochure”)
Effective: April 24, 2025
This Form ADV–A - Appendix 1 (“Wrap Fee Program Brochure”) provides information about the qualifications and
business practices for JMAC Enterprises LLC (“JMAC” or the “Advisor”) services when offering services pursuant to
a wrap program. The Advisor conducts business under the practice name (“doing business as” or “dba” name)
Brick House Strategic Wealth. This Wrap Fee Program Brochure shall always be accompanied by the JMAC
Disclosure Brochure, which provides complete details on the business practices of the Advisor. If you did not
receive the complete JMAC Disclosure Brochure or you have any questions about the contents of this Wrap Fee
Program Brochure or the JMAC Disclosure Brochure, please contact us at
(267) 753-7066.
JMAC is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Wrap Fee Program 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
Wrap Fee Program Brochure provides information about JMAC to assist you in determining whether to retain the
Advisor.
Additional information about JMAC and its advisory persons are available on the SEC’s website at
www.adviserinfo.sec.gov by searching for our firm name or by our CRD# 312710.
PA Office:201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7066 * Fax: 215-860-1687
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7066 * Fax: 215-860-1687
Page 16
Item 2 – Material Changes
Form ADV –A - Appendix 1 (“Wrap Fee Program Brochure”) provides information about a variety of topics relating
to an Advisor’s business practices and conflicts of interest. This Wrap Fee Program Brochure discusses Wrap Fee
Programs offering by the Advisor.
Material Changes
There are the following Material Changes to this Disclosure Brochure since the last filing and distribution to Clients.
The firm has removed one of its DBAs. (Item 1)
Future Changes
From time to time, we may amend this Wrap Fee Program Brochure to reflect changes in our business practices,
changes in regulations and routine annual updates as required by the securities regulators. This complete Wrap
Fee Program Brochure (along with the complete JMAC Disclosure Brochure) or a Summary of Material Changes
shall be provided to each Client annually and if a material change occurs in the business practices of JMAC.
At any time, you may view this Wrap Fee Program Brochure and the current Disclosure Brochure on-line at the
SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching for our firm name or
by our CRD# 312710. You may also request a copy of this Wrap Fee Program Brochure at any time, by contacting
us at (267) 753-7065.
Item 3 – Table of Contents
Form ADV Part 2A – Appendix 1 – Wrap Fee Program Brochure ...................................................................... 16
Item 2 – Material Changes ..................................................................................................................................... 17
Item 3 – Table of Contents ..................................................................................................................................... 17
Item 4 – Services Fees and Compensation .......................................................................................................... 17
Item 5 – Account Requirements and Types of Clients........................................................................................ 19
Item 6 – Portfolio Manager Selection and Evaluation ......................................................................................... 19
Item 7 – Client Information Provided to Portfolio Managers .............................................................................. 21
Item 8 – Client Contact with Portfolio Managers ................................................................................................. 21
Item 9 – Additional Information ............................................................................................................................. 21
Privacy Policy ........................................................................................................................................................ 36
Item 4 – Services Fees and Compensation
A. Services
JMAC Enterprises LLC (“JMAC” or the “Advisor”) provides customized wealth management services for its Clients.
This Wrap Fee Program Brochure is provided as a supplement to the JMAC Disclosure Brochure (Form ADV 2A).
This Wrap Fee Program Brochure is provided along with the complete Disclosure Brochure to provide full details of
the business practices and fees when selecting JMAC as your investment advisor.
As part of the wealth management fees noted in Item 5 of the Disclosure Brochure, JMAC includes securities
transaction fees, administrative fees, and custodial fees (herein “Covered Costs”) as part of the overall wealth
management fee. Securities regulations often refer to this combined fee structure as a “Wrap Fee Program”. The
Advisor sponsors the JMAC Wrap Fee Program.
The sole purpose of this Wrap Fee Program Brochure is to provide additional disclosure relating the combination of
securities transaction fees into the single “bundled” wealth management fee. This Wrap Fee Program Brochure
references back to the JMAC Disclosure Brochure in which this Wrap Fee Program Brochure serves as an Appendix.
Please see Item 4 – Advisory Services of the Disclosure Brochure for details on JMAC’s investment
philosophy and related services.
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7066 * Fax: 215-860-1687
Page 17
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.
B. Program Costs
Advisory services provided by JMAC are offered in a wrap fee structure whereby Covered Costs are included in the
overall wealth management fee paid to JMAC. The level of trading in a Client’s account[s] may vary from year to
year but does not impact the annual cost to the Client as the costs are based on asset-based pricing with the
Custodian. The overall fee paid by the Client may be more or less than engaging for advisory services where the
transactions costs are borne separately by the Client. The cost of the Wrap Fee Program varies depending on
services to be provided to each Client, however, the Client is not charged more if there is higher trading activity or
other Covered Costs. A Wrap Fee structure presents a conflict of interest as an advisor has an incentive to limit
trading or utilize securities that do not have transaction fees. To mitigate this conflict, JMAC has entered into an
asset based pricing arrangement with the Custodian whereby securities transaction fees, administrative fees, and
custody fees are a flat basis point fee based on the level of assets the Advisor maintains with the Custodian.
Please see Item C of this brochure for information on additional transaction fees that may be charged by the
Custodian. Please see Item 5 – Fees and Compensation of the Disclosure Brochure for complete details on
fees.
C. Fees
Wealth management fees are calculated by the Advisor or its delegate 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 JMAC 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. 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 JMAC will be independently valued by the Custodian. The
Advisor will conduct periodic reviews of the Custodian’s valuations.
Clients are urged to also review and compare the statement provided by the Advisor to 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 JMAC 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.
For Client accounts implemented through an Independent Manager, the Client’s overall fee may include JMAC’s
wealth management fee (as noted above) plus the asset-based fees charged by the Independent Manager[s], as
applicable. In certain instances, the Independent Manager or the Advisor may assume responsibility for calculating
the Independent Managers asset-based fee and separately deduct the fees from the Client’s account[s].
As noted above, the Wrap Fee Program includes Covered Costs incurred in connection with the wealth management
services provided by JMAC. Under this Wrap Fee Program, JMAC includes securities transactions costs as part of
its overall wealth management fee. Some securities transaction fees for Client-directed trades may be charged back
to the Client due to custodial limitations. Clients may incur certain fees or charges imposed by third parties in
connection with investments made on behalf of the Client’s account[s].
In addition, all fees paid to JMAC for wealth management services or part of the Wrap Fee Program are separate
and distinct from the expenses charged by mutual funds and exchange-traded funds 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. The Client may also incur other costs
assessed by the Custodian or other parties for account related activity fees, such as wire transfer fees, fees for
trades executed away from the Custodian and other fees. The Advisor does not control nor share in these fees.
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7066 * Fax: 215-860-1687
Page 18
The Client should review both the fees charged by the fund[s] and the fees charged by JMAC to fully understand
the total fees to be paid. Please see Item 5.C. – Other Fees and Expenses in the Disclosure Brochure (included
with this Wrap Fee Program Brochure).
D. Compensation
JMAC is the sponsor and portfolio manager of this Wrap Fee Program. JMAC receives wealth management fees
paid by Clients for participating in the Wrap Fee Program and pays the Custodian for the costs associated with the
normal trading activity in the Client’s account[s].
Item 5 – Account Requirements and Types of Clients
JMAC offers wealth management services to individuals, high net worth individuals, trusts, estates, businesses,
retirement plans, and pension plans. The amount of each type of Client is available on JMAC’s Form ADV Part 1A.
These amounts may change over time and are updated at least annually by the Advisor. JMAC generally requires
a minimum relationship size of $500,000 to effectively implement its investment process.
Item 6 – Portfolio Manager Selection and Evaluation
Portfolio Manager Selection
JMAC serves as sponsor and as portfolio manager for the services under this Wrap Fee Program.
Related Persons
JMAC personnel serve as portfolio managers for this Wrap Fee Program. JMAC does not serve as a portfolio
manager for any third-party Wrap Fee Programs.
Performance-Based Fees
JMAC does not charge performance-based fees for its wealth management services. The fees charged by JMAC
are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by
any Client. JMAC 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.
Supervised Persons
JMAC Advisory Persons serve as portfolio managers for all accounts, including the services described in this Wrap
Fee Program Brochure. Details of the advisory services provided are included in Item 4.A. of the Disclosure
Brochure.
Methods of Analysis
Please see Item 8 of the Disclosure Brochure (included with this Wrap Fee Program Brochure) for details on the
research and analysis methods employed by the Advisor.
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. JMAC 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.
201 S. State Street. Unit 2A, Newtown, PA 18940
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Page 19
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 bidask
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.
Bond Risks
Bonds are 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
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.
Margin Borrowings
The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities
pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin
call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory
liquidation of the pledged securities to compensate for the decline in value.
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. Please see Item 8.B. – Risk of Loss in the Disclosure Brochure for
details on investment risks.
Proxy Voting
JMAC accepts proxy-voting responsibility for Clients. In such instances, the Advisor will cast proxy votes only in a
manner it believes is consistent with its fiduciary duty to Clients of the Advisor.
The Advisor has engaged Broadridge Investor Communications Solutions, Inc. (“Broadridge”), a third-party,
independent proxy advisory firm, to provide it with research, analysis, and recommendations on the various proxy
proposals for the client securities that the Advisor manages with the aim of maximizing shareholder value. In
engaging Broadridge for that purpose, the Advisor will review as necessary, Broadridge’s Proxy Paper Guidelines
for the current proxy voting season and will approve the summary of Broadridge’s positions on the voting positions
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7066 * Fax: 215-860-1687
Page 20
it recommends for the types of proposals most frequently presented, including: election and composition of
directors; financial reporting; compensation of management and directors; corporate governance structure and
antitakeover measures; and environmental and social risks to operations. The Advisor is in agreement with the
approach Broadridge has set forth in its current Proxy Paper Guidelines for voting proxies. Although the Advisor,
based on its approval of the positions in the Proxy Paper Guidelines, expects to vote proxies according to
Broadridge’s recommendations, certain issues may need to be considered on a case-by-case basis due to the
diverse and continually evolving nature of corporate governance issues. If such cases should arise, then the
Advisor will devote appropriate time and resources to consider those issues.
Where the Advisor is responsible for voting proxies on behalf of a Client, the Client cannot direct the Advisor’s vote
on a particular solicitation. The Client, however, can revoke the Advisor’s authority to vote proxies. In situations
where there may be a conflict of interest in the voting of proxies due to business or personal relationships that the
Advisor maintains with persons having an interest in the outcome of certain votes, the Advisor will take appropriate
steps, whether by following Broadridge’s third-party recommendation or otherwise, to ensure that proxy voting
decisions are made in what it believes is the best interest of its Clients and are not the product of any such conflict.
Item 7 – Client Information Provided to Portfolio Managers
JMAC is the sponsor and sole portfolio manager for the Program. The Advisor does not share Client information
with other portfolio managers because it is the sole portfolio manager for this Wrap Fee Program. Please also see
the JMAC Privacy Policy (included after this Wrap Fee Program Brochure).
Item 8 – Client Contact with Portfolio Managers
JMAC is a full-service investment management advisory firm. Clients always have direct access to the Portfolio
Managers at JMAC.
Item 9 – Additional Information
A. Disciplinary Information and Other Financial Industry Activities and Affiliations
There are no legal, regulatory, or disciplinary events involving JMAC or management persons. JMAC 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 backgrounds of the Advisor or Advisory Persons are
available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the
Advisor’s firm name or CRD#312710.
Please see Item 9 of the JMAC Disclosure Brochure as well as Item 3 of each Advisory Person’s Brochure
Supplement (included with this Wrap Fee Program Brochure) for additional information on how to research the
background of the Advisor and its Advisory Persons.
Other Financial Activities and Affiliations
Please see Items 10 and 14 of the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Program
Brochure).
B. Code of Ethics, Review of Accounts, Client Referrals, and Financial Information
JMAC has implemented a Code of Ethics that defines our fiduciary commitment to each Client. This Code of Ethics
applies to all persons subject to JMAC’s compliance program (our “Supervised Persons”). Complete details on the
JMAC Code of Ethics can be found under Item 11 – Code of Ethics, Participation in Client Transactions and
Personal Trading in the Disclosure Brochure (included with this Wrap Fee Program Brochure).
Review of Accounts
Investments in Client accounts are monitored on a regular and continuous basis by Advisory Persons of JMAC
under the supervision of the Chief Compliance Officer (“CCO”). Details of the review policies and practices are
provided in Item 13 of the Form ADV Part 2A – Disclosure Brochure.
Other Compensation Participation in Institutional Advisor Platform – Trade-PMR
JMAC has established an institutional relationship with Trade-PMR, Inc. (“Trade-PMR”) to assist the Advisor in
201 S. State Street. Unit 2A, Newtown, PA 18940
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Page 21
managing Client account[s]. Trade-PMR clears trades and custodies assets with First Clearing. First Clearing is a
trade name used by Wells Fargo Clearing Services, LLC, a non-bank affiliate of Wells Fargo & Company.
TradePMR acts as an introducing broker on a fully disclosed basis. Trade-PMR and First Clearing are FINRA
registered broker-dealers and members of SIPC. The Advisor receives access to software and related support
because the Advisor renders wealth management services to Clients that maintain assets at Trade-PMR. The
software and related systems support may benefit the Advisor, but not its Clients directly. 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 the Custodian creates a potential conflict of interest since these benefits
may influence the Advisor's recommendation of the Custodian over one that does not furnish similar software,
systems support, or services. Additionally, the Advisor may receive the following benefits from Trade-PMR: receipt
of duplicate Client confirmations and bundled duplicate statements; access to a trading desk that exclusively
services its institutional participants; access to block trading which provides the ability to aggregate securities
transactions and then allocate the appropriate shares to Client accounts; and access to an electronic
communication network for Client order entry and account information.
Participation in Institutional Advisor Platform - Fidelity
JMAC has an arrangement with Fidelity through which Fidelity provides JMAC with Fidelity's "platform" services.
The platform services include, among others, brokerage, custodial, administrative support, record keeping, and
related services that are intended to support intermediaries like JMAC in conducting business and in serving the
best interests of their clients but that also benefit JMAC. Fidelity charges brokerage commissions and transaction
fees for effecting certain securities transactions (i.e., transactions fees are charged for certain no-load mutual
funds, commissions are charged for certain equity and debt securities transactions). Fidelity enables JMAC to
obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction
charges. Fidelity’s fees and commission rates are generally considered discounted from customary retail rates.
However, the commissions and/or transaction fees charged by Fidelity may be higher or lower than those charged
by other custodians and broker-dealers. As part of the arrangement, Fidelity also makes available to JMAC, at no
additional charge to us, certain research and brokerage services, including research services obtained by Fidelity
directly from independent research companies to manage accounts for which JMAC has investment discretion. As
a result of receiving these services for no additional cost, JMAC has an incentive to continue to use or expand the
use of Fidelity's services, which creates a conflict of interest. JMAC has examined this conflict and has determined
that the relationship is in the best interests of clients by conducting a qualitative and quantitative review of Fidelity’s
brokerage and custodial services. JMAC also periodically reviews the commissions charged and the services
provided by Fidelity and compares those with other broker-dealers.
Client Referrals from Solicitors
If a Client is introduced to JMAC by an unaffiliated party, JMAC may pay that solicitor a referral fee in accordance
with the requirements of Rule 206(4)-1 of the Investment Advisers Act of 1940, and any corresponding state
securities law requirements. Any such referral fee shall be paid solely from the wealth management fees earned by
JMAC and shall not result in any additional charge to the Client.
Financial Information
Neither JMAC, nor its management persons, have any adverse financial situations that would reasonably impair the
ability of JMAC to meet all obligations to its Clients. Neither JMAC, nor any of its Advisory Persons, have been
subject to a bankruptcy or financial compromise. JMAC 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.
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7066 * Fax: 215-860-1687
Page 22
Form ADV Part 2B – Brochure Supplement
for
Robert C. Macaulay Founder, Managing Principal, and Chief Compliance
Officer
Effective: April 24, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Robert C. Macaulay (CRD# 1936227) in addition to the information contained in the JMAC Enterprises LLC
(“JMAC” or the “Advisor”, CRD# 312710) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the JMAC Disclosure Brochure or this Brochure
Supplement, please contact us at (267) 753-7066.
Additional information about Mr. Macaulay 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# 1936227.
Item 2 – Educational Background and Business Experience
Robert C. Macaulay, born in 1966, is dedicated to advising Clients of JMAC as a Founder, Managing Principal, and
Chief Compliance Officer. Mr. Macaulay earned a Bachelor of Business Administration from University of
Pennsylvania. Additional information regarding Mr. Macaulay’s employment history is included below.
Employment History:
Founder, Managing Principal, and Chief Compliance Officer, JMAC Enterprises LLC
Registered Representative, Wells Fargo Advisors Financial Network, LLC
Registered Representative, Wells Fargo Clearing Services, LLC
Registered Representative, Wells Fargo Advisors LLC
Financial Advisor, Wachovia Securities LLC
Senior Vice President - Investments, Prudential Securities
03/2021 to Present
03/2018 to 04/2021
11/2016 to 03/2018
05/2009 to 11/2016
07/2003 to 05/2009
05/2001 to 07/2003
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
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7065 * Fax: 215-860-1687
Page 23
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®.
Item 3 Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Macaulay. Mr. Macaulay 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. Macaulay.
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. Macaulay.
However, we do encourage you to independently view the background of Mr. Macaulay on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
1936227.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mr. Macaulay is also a licensed insurance professional. Implementations of insurance recommendations are
separate and apart from Mr. Macaulay’s role with JMAC. As an insurance professional, Mr. Macaulay will receive
customary commissions and other related revenues from the various insurance companies whose products are
sold. Mr. Macaulay is not required to offer the products of any particular insurance company. Commissions
generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in
recommending certain products of the insurance companies. Clients are under no obligation to implement any
recommendations made by Mr. Macaulay or the Advisor. Mr. Macaulay spends approximately 5% of his time per
month in this capacity.
Item 5 – Additional Compensation
Mr. Macaulay has additional business activities where compensation is received that are detailed in Item 4 above.
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7065 * Fax: 215-860-1687
Page 24
Item 6 – Supervision
Mr. Macaulay serves as a Founder, Managing Principal, and Chief Compliance Officer of JMAC. Mr. Macaulay can
be reached at (267) 753-7066.
JMAC has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in
meeting their fiduciary obligations to Clients of JMAC. Further, JMAC is subject to regulatory oversight by various
agencies. These agencies require registration by JMAC and its Supervised Persons. As a registered entity, JMAC
is subject to examinations by regulators, which may be announced or unannounced. JMAC 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.
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7065 * Fax: 215-860-1687
Page 25
Form ADV Part 2B – Brochure Supplement
for
Morgan E. Macaulay Lead Advisor
Effective: April 24, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Morgan E. Macaulay (CRD# 6091926) in addition to the information contained in the JMAC Enterprises LLC
(“JMAC” or the “Advisor”, CRD# 312710) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the JMAC Disclosure Brochure or this Brochure
Supplement, please contact us at (267) 753-7065.
Additional information about Ms. Macaulay is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 6091926.
Item 2 – Educational Background and Business Experience
Morgan E. Macaulay, born in 1993, is dedicated to advising Clients of JMAC as a Lead Advisor. Ms. Macaulay
earned a Bachelor of Science from Pennsylvania State University. Additional information regarding Ms. Macaulay’s
employment history is included below.
Employment History:
Lead Advisor, JMAC Enterprises LLC
Registered Representative, Wells Fargo Advisors Financial Network, LLC
Portfolio Administrator, Wells Fargo Advisors, LLC
Supply Planning Analyst, Johnson & Johnson
03/2021 to Present
03/2018 to 04/2021
01/2018 to 03/2018
06/2015 to 01/2018
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
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7065 * Fax: 215-860-1687
Page 26
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®.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Ms. Macaulay. Ms. Macaulay has never
been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Ms. Macaulay.
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 Ms. Macaulay.
However, we do encourage you to independently view the background of Ms. Macaulay on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD#
6091926.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Ms. Macaulay is also a licensed insurance professional. Implementations of insurance recommendations are
separate and apart from Ms. Macaulay’s role with JMAC. As an insurance professional, Ms. Macaulay will receive
customary commissions and other related revenues from the various insurance companies whose products are
sold. Ms. Macaulay is not required to offer the products of any particular insurance company. Commissions
generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in
recommending certain products of the insurance companies. Clients are under no obligation to implement any
recommendations made by Ms. Macaulay or the Advisor. Ms. Macaulay spends approximately 5% of her time per
month in this capacity.
Item 5 – Additional Compensation
Ms. Macaulay has additional business activities where compensation is received that are detailed in Item 4 above.
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7065 * Fax: 215-860-1687
Page 27
Item 6 – Supervision
Ms. Macaulay serves as a Lead Advisor of JMAC and is supervised by Mr. Robert Macaulay, the Chief Compliance
Officer. Mr. Macaulay can be reached at (267) 753-7065.
JMAC has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in
meeting their fiduciary obligations to Clients of JMAC. Further, JMAC is subject to regulatory oversight by various
agencies. These agencies require registration by JMAC and its Supervised Persons. As a registered entity, JMAC
is subject to examinations by regulators, which may be announced or unannounced. JMAC 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.
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7065 * Fax: 215-860-1687
Page 28
Form ADV Part 2B – Brochure Supplement
for
L. Connor Macaulay Lead Advisor
Effective: April 24, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of L.
Connor Macaulay (CRD# 6813076) in addition to the information contained in the JMAC Enterprises LLC (“JMAC”
or the “Advisor”, CRD# 312710) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or
if you have any questions about the contents of the JMAC Disclosure Brochure or this Brochure Supplement,
please contact us at (267) 753-7065.
Additional information about Mr. Macaulay 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# 6813076.
Item 2 – Educational Background and Business Experience
L. Connor Macaulay, born in 1996, is dedicated to advising Clients of JMAC as a Wealth Advisor. Mr. Macaulay
earned a Bachelors of Science in Agribusiness Management from Pennsylvania State University in 2019.
Additional information regarding Mr. Macaulay’s employment history is included below.
Employment History:
Lead Advisor, JMAC Enterprises LLC
Wealth Advisor, JMAC Enterprises LLC
Portfolio Administrator, Wells Fargo Advisors Financial Network, LLC
Intern, Wells Fargo Advisors Financial Network, LLC
Intern, Wells Fargo Clearing Services, LLC
09/2024 to present
04/2021 to Present
06/2019 to 04/2021
06/2018 to 08/2018
06/2017 to 08/2017
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Macaulay. Mr. Macaulay 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. Macaulay.
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. Macaulay.
However, we do encourage you to independently view the background of Mr. Macaulay on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
6813076.
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7065 * Fax: 215-860-1687
Page 29
Item 4 – Other Business Activities
Mr. Macaulay is dedicated to the investment advisory activities of JMAC’s Clients. Mr. Macaulay does not have any
other business activities.
Item 5 – Additional Compensation
Mr. Macaulay is dedicated to the investment advisory activities of JMAC’s Clients. Mr. Macaulay does not receive
any additional forms of compensation.
Item 6 – Supervision
Mr. Macaulay serves as a Wealth Advisor of JMAC and is supervised by Robert Macaulay, the Chief Compliance
Officer. Mr. Macaulay can be reached at (267) 753-7065.
JMAC has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in
meeting their fiduciary obligations to Clients of JMAC. Further, JMAC is subject to regulatory oversight by various
agencies. These agencies require registration by JMAC and its Supervised Persons. As a registered entity, JMAC
is subject to examinations by regulators, which may be announced or unannounced. JMAC 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.
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7065 * Fax: 215-860-1687
Page 30
Privacy Policy
Effective: March 2, 2022
Our Commitment to You
JMAC Enterprises LLC (“JMAC” 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. JMAC (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.
JMAC 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
Account applications and forms
Other advisory agreements and legal documents
Transactional information with us or others
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.
How do we share your information?
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7065 * Fax: 215-860-1687
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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
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
JMAC does not disclose, and does not intend to disclose, personal
information with affiliated or 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 JMAC 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.
Affiliates’ Everyday Business Purposes
JMAC does not disclose, and does not intend to disclose, personal
information with affiliated third parties regarding your transactions,
experiences, and creditworthiness.
Yes
Yes
No
Not Shared
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
JMAC 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.
State-Specific Regulations
California
In response to a California law, to be conservative, we assume accounts with California addresses do not want us to
disclose personal information about you to non-affiliated third parties, except as permitted by California law. We also limit
the sharing of personal information about you with our affiliates to ensure compliance with California privacy laws.
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 (267) 753-7065.
201 S. State Street. Unit 2A, Newtown, PA 18940
Phone: (267) 753-7065 * Fax: 215-860-1687
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