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Form ADV – Part 2
March 11, 2025
Liberty Private Client, LLC
Michael McCort
5237 Summerlin Commons BLVD #319
Fort Myers, Florida 33907
Telephone: 239-839-6552
This brochure provides information about the qualifications and business practices of
Liberty Private Client, LLC. If you have any questions about the contents of this
brochure, please contact us at 239-839-6552. The information in this brochure has not
been approved by the Securities and Exchange Commission (“SEC”) or any state
securities authority.
Additional information about Liberty Private Client, LLC is also available on the SEC’s
website at www.adviserinfo.sec.gov.
MATERIAL CHANGES:
This brochure represents a narrative style required by the Securities and Exchange
Commission as mandated by Release No. IA-3060. There have been no material changes
since last update March 2024.
TABLE OF CONTENTS
Contents
FEES AND COMPENSATION ........................................................................................ 4
PERFORMANCE FEES AND SIDE BY SIDE MANAGEMENT ............................... 5
TYPES OF CLIENTS ....................................................................................................... 5
METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS6
DISCIPLINARY INFORMATION ................................................................................. 7
OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ................. 7
CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING ......................................................... 7
REVIEW OF ACCOUNTS ............................................................................................... 9
CLIENT REFERRALS AND OTHER COMPENSATION .......................................... 9
CUSTODY .......................................................................................................................... 9
INVESTMENT DISCRETION ........................................................................................ 9
VOTING CLIENT SECURITIES.................................................................................. 10
FINANCIAL INFORMATION ...................................................................................... 10
REQUIREMENTS FOR STATE-REGISTERED INVESTMENT ADVISERS ...... 10
LEGAL OR DISCIPLINARY EVENTS ............................................................... 13
OTHER BUSINESS ACTIVITIES ..................................................................... 13
ADDITONAL COMPENSION ........................................................................... 13
ADVISORY BUSINESS
Liberty Private Client, LLC. (“Liberty Private" or “Advisor’) is a fee only
registered investment advisor that specializes in providing investment management
services to a select group of individuals and trusts. Advisor's founding member and
President is Michael McCort.
Liberty Private was formed in June 2019 and became a registered investment
advisor in September 2019, registered in the State of Florida and notice filed in
Pennsylvania May 2020. Liberty Private Client registered with the S.E.C July 1st, 2020.
Registration does not imply a certain level of skill or training. The answers provided in
the firm's initial Form ADV filing and this Form ADV 2 are prospective of the type of
business in which the firm intends to engage, to whom the firm intends to serve as
investment advisor, and the manner in which it intends to conduct its business. In April
of 2020 Liberty Private merged with Girard Private Investment Group, a Registered
Investment Advisory firm. Girard Private was started in 2015 by Richard Seidel, the
former founder of Girard Partners (now a subsidiary of Univest Corp. of PA). Mr.
McCort and Mr. Seidel have known each other for more than a decade and believed the
merger would be advantageous to clients from both firms. Liberty Private Client retained
all Girard Private employees and continued to maintain the Pennsylvania office
previously used by Girard Private. Mr. McCort and Mr. Seidel are the principal owners
of Liberty Private Client.
Liberty Private will meet with prospective clients and review their goals and
constraints, risk tolerance, time horizons and income needs. The Advisor tailors
portfolios to each individual’s circumstances and emphasizes asset allocation and security
selection. In creating asset allocation strategies, Advisor implements its strategy by
investing client assets in, common stocks, options, mutual funds, exchange traded funds,
bonds, preferred stocks, and other fixed income instruments. Clients may direct Liberty,
by written notice, to not invest in certain types of securities or individual holdings the
client may wish to restrict. Liberty had $246,903,131 in assets managed on a
discretionary basis and $0 assets managed on a non-discretionary basis as of December
31, 2024.
FEES AND COMPENSATION
Fees for investment management services are generally charged based on a
percentage of assets under management. Fees are payable when services are rendered.
Fees are calculated based on a schedule of 100 basis points per annum. Refer to Schedule
A below for specific fee breakdown. Advisor does not have a minimum fee. Fees
however can be negotiated based on special circumstances. For example, fees may be
discounted from those stated herein because of pre-existing or long-standing
relationships, anticipated client additions to assets under management, changing market
conditions or other reasons.
Fees are billed and collected quarterly, in advance, based on the terms of the
written client agreement. Fees are calculated based on the closing market value of the
account, including cash and cash equivalents, on the last day of the previous calendar
quarter. Fees may be deducted from clients’ accounts directly with prior authorization
and direction from the client. In the event the advisory agreement is terminated, and the
Advisor has received unearned fees, the Advisor will prorate such fees and promptly
refund any unearned portion to the Client. The calculation of the Client's final bill is part
S
of the account closing process. Clients are provided with quarterly statements reflecting
all holdings and activity, including deduction of the Advisory fee.
With certain client investments (i.e. mutual funds, ETFs) the clients incur fees and
expenses that are charged to shareholders in these investments. These expenses are
disclosed in the investment’s prospectus, and may include, but are not limited to,
management fees, administration fees, and transaction charges associated with
purchasing and selling securities within the fund.
Custodians typically charge transaction fees for executing transactions on behalf
of a client and charge other additional fees for holding client assets, processing wire
requests, etc. Advisor does not share in any portion of the additional brokerage
fees/transaction charges or custody fees imposed by the custodian holding the Client
funds and securities. The Client should review all fees charged by Advisor and others to
fully understand the total amount of fees to be paid by the Client.
Advisory services can be terminated by either party (Advisor or Client) by giving
thirty days (30) prior written notice at any time during the Advisory agreement. Any
such notices shall not affect any obligation incurred prior to the termination. Likewise, in
the event that it is determined that a Client paid fees in advance, Liberty Private will pro-
rate any such fees and promptly refund any unearned fees as of the date of termination.
SCHEDULE A
Fees for services shall be as follows:
1.00% of assets per annum on the first $2 million in assets
0.75% of assets per annum on assets over $2 million to $5 million
Assets over $5 million subject to negotiation
PERFORMANCE FEES AND SIDE BY SIDE MANAGEMENT
Advisor does not presently charge performance fees for investment management.
TYPES OF CLIENTS
Advisor does require a minimum relationship size of $500,000, which may be
waived at the discretion of the advisor.
METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND
RISK OF LOSS
Liberty Private’s emphasizes asset allocation and security selection as important
factors affecting portfolio performance. The investment philosophy leads to
diversification among different asset classes, sectors, and types of investments. In
creating investment strategies, the Advisor utilizes a spectrum of domestic & foreign
securities including, but not limited to, common stocks, options, mutual funds, exchange
traded funds, taxable and tax-free fixed income instruments and cash equivalents.
Liberty Private utilizes the expertise of in house investment professionals and
may use the services of outside third parties to help with research and investment
analysis. Liberty Private will maintain an approved list of securities for investment of
client assets.
There are a number of risks associated with the investment strategies offered by
the Advisor. Generally, Clients are subject to stock market risk, which is the chance that
stock prices overall will decline. Stock markets tend to move in cycles, with periods of
rising prices and falling prices. Such risk may vary based on the percentage of stocks
owned in a given strategy or mutual fund.
Bonds are subject to interest rate risk, which is the chance that bond prices overall
will decline because of rising interest rates. Interest rate risk will vary based on the
percentage of bonds owned in a given strategy or mutual fund. In addition, long-term
bonds have a higher interest rate risk and are much more sensitive to interest rate changes
than are the prices of short-term bonds. Bonds are also subject to credit risk, the chance
that a bond issuer will fail to pay interest and principal in a timely manner or, that
negative perceptions of the issuer’s ability to make such payments will cause the price of
that bond to decline. Finally, some bonds may be subject to call risk. This is the chance
that in a declining interest rate environment the issuer of a bond will repay or call
securities with higher coupons before their maturity dates.
In addition, investments in specific asset classes entail different investment risks.
For example, small cap stocks tend to be more volatile than large or mid-cap stocks.
International stocks and emerging markets include risks due to currency fluctuations,
foreign taxes, political instability and possibility of illiquid markets. Real estate
investing includes risks such as declines in the value of real estate, changing economic
conditions, and changes in tax laws or property taxes. Commodities’ investing is also
highly volatile and subject to changing economic conditions and the vagaries of
speculators among other risks. Market Neutral and Long/Short strategies entail potential
liquidity risks and frequently higher fees.
Advisor utilizes a long-term approach to investing and will not attempt to time the
markets. Advisor will generally stay committed to its investment allocation and will not
seek to liquidate a portfolio to avoid market losses. Any strategic or tactical asset
allocations employed by the Advisor do not assure profit or protect against loss in
declining markets. Investing in securities involves risk of loss that clients should be
prepared to bear.
DISCIPLINARY INFORMATION
None of the firm’s officers or other employees has been involved in any legal or
disciplinary action with any federal or state statutory or regulatory agency. Likewise,
none of officers or other employees has ever been the subject of disciplinary action by
self-regulatory organizations.
OTHER FINANCIAL INDUSTRY ACTIVITIES AND
AFFILIATIONS
Neither Liberty Private Client nor Michael McCort engages in any other financial
industry activities and affiliations.
CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING
Advisor’s employees may buy or sell for themselves securities that they also
recommend to Clients, which can create a conflict of interest. Advisor has addressed this
potential conflict in its Code of Ethics. The Code of Ethics defines certain policies
adopted by the Advisor that relate to personal trading and business practices of
employees to ensure that the Advisor resolves any such conflicts and upholds it fiduciary
duty to Clients and place the interests of clients first. The Code of Ethics requires all
employees to report all personal securities transactions in Covered Securities for
themselves, as well as relatives residing with them, to the Advisor as they occur. The
Code of Ethics also requires the Compliance Officer or their designee to review all
transactions of employees in Covered Securities for compliance with the Code. Further,
the Code requires all employees to acknowledge their understanding of the Code and
their compliance with its provisions on an annual basis. A copy of the Code of Ethics is
available upon request.
BROKERAGE PRACTICES
The Advisor makes recommendations to clients regarding broker/dealers to be
used for transactions and the custody of client assets for which Advisor provides
Investment Supervisory Services. Our recommendations are based on the level of
customer service and support, the availability of mutual funds on the custodian platform,
and pricing to the client. The Advisor considers the reasonableness of the commissions
and other charges in light of the services provided. The Advisor monitors brokers for
their execution capabilities and the reasonableness of its fees. Advisor currently
recommends Charles Schwab.
In the event that a client was to direct the Advisor to use a different broker/dealer,
the Advisor may not be able to negotiate commissions and may not be able to obtain
volume discounts or best execution. Under these circumstances, clients who direct
Advisor to use a different broker/dealer may be charged different commission rates from
those Advisors negotiated with Charles Schwab.
Advisor provides services and benefits that are typically not available to Charles
Schwab retail investors. These benefits include the following products and services
provided without cost or at a discount: duplicate client statements and confirmations;
research related products and tools; the ability to have Advisory fees deducted directly
from client accounts; access to mutual funds with no transaction fees and to certain
institutional money managers; access to a trading desk serving Advisor participants;
access to block trading (which provides the ability to aggregate securities transactions for
execution and then allocate the appropriate shares to client accounts). Purchases or sales
of securities may be aggregated if the Advisor is able to obtain pricing more favorable to
clients by utilizing a block trade and allocating appropriate shares to client accounts
Charles Schwab may also have paid for business consulting and professional
services received by Advisor’s related persons and may also pay or reimburse expenses
(including travel, lodging, meals, and entertainment expenses) for Advisor’s personnel
to attend conferences or meetings relating to the program or to Charles Schwab’s
Advisor custody and brokerage services generally. However, neither the Advisor nor its
related persons have received any payments or reimbursements relating to business
consulting or professional services. Some of the products and services made available
by Charles Schwab through the program may benefit Advisor but may not benefit its
client accounts. These products or services may assist Advisor in managing and
administering client accounts, including accounts not maintained at Charles Schwab.
Other services made available by Charles Schwab are intended to help Advisor
manage and further develop its business enterprise. The benefits received by Advisor (or
its personnel) through participation in the program do not depend on the amount of
brokerage transactions directed to Charles Schwab. Clients should be aware, however,
that the receipt of economic benefits by Advisor or its related persons in and of itself
creates a potential conflict of interest and may indirectly influence Advisor’s
recommendation of Charles Schwab for custody and brokerage services.
Advisor endeavors to avoid trading errors, which can occur in the normal course
of business. When trading errors do occur, Advisor will absorb such loss, making the
client whole. If the error results in a gain, Advisor's custodian will donate the gain to
charity.
REVIEW OF ACCOUNTS
Accounts and portfolios are reviewed periodically by the Manager or his
designee(s). The accounts and portfolios are reviewed to determine whether holdings are
on the approved list, whether the portfolios are assigned to an appropriate model, and
whether the model is assigned in accordance with the client's investment policy
statement. If there are any exceptions, there should be notes reflecting the exceptions.
Clients will receive printed statements monthly from the custodian, Charles Schwab,
detailing holdings, and account activity. Clients will also have ongoing access to their
accounts directly through the Charles Schwab website. Additionally, clients will receive
printed statements from the Advisor on a quarterly basis detailing holdings and account
activity.
CLIENT REFERRALS AND OTHER COMPENSATION
Liberty Private does not intend to enter into referral fee arrangement or engage
the services of independent solicitors.
CUSTODY
Liberty Private has limited custody of client funds since it debits client accounts
to collect fees. While this constitutes “custody” as defined in the Investment Advisors
Act, advisors like Liberty Private who have custody for this reason only, are exempt
from some additional requirements imposed on advisors who take physical custody of
cash or securities from clients. Liberty Private requires that Clients’ funds or securities
must be retained with a “qualified custodian” who provides at least quarterly statements,
either printed or delivered electronically to Clients. In addition to statements provided by
the custodian, Liberty Private provides quarterly statements to Clients. Clients are
encouraged to compare the information provided by Liberty Private with the information
provided in statements received from the qualified custodian. In the event of
discrepancies or questions, the Client is urged to contact the Advisor.
INVESTMENT DISCRETION
Liberty Private manages accounts primarily on a discretionary basis with full
authority to make purchase and sale decisions for client accounts. Discretionary authority
is reviewed with the client at multiple levels prior to implementation. It is detailed in
Section 1 (Services) of the Advisory Agreement signed by the client and is also part of
the Charles Schwab Advisor Authorizations (Directed Trading) signed and initialed by
the client. At a client’s request, Liberty Private may also enter into non-discretionary
agreements that require Client consultation/approval prior to enacting purchase or sale of
securities for the account. Liberty Private’s Investment Policy Statements also allow the
Clients to enumerate any specific exclusions, restrictions or special considerations in
managing either discretionary or non-discretionary accounts.
VOTING CLIENT SECURITIES
Liberty does not vote proxies. Clients receive proxies and other solicitations
directly from the qualified custodian. Clients may contact Advisor by phone should they
have any questions in regard to proxies or other solicitations.
FINANCIAL INFORMATION
Liberty does not have any financial condition that is reasonably likely to impair our
ability to meet contractual commitments.
REQUIREMENTS FOR STATE-REGISTERED INVESTMENT
ADVISERS
Liberty's principal's education and business background is described elsewhere in this
ADV Part 2.
Liberty’s principal's other business activities are described elsewhere in this ADV Part 2.
Liberty does not charge performance-based fees so the additional disclosures relating to
performance-based fees are not applicable.
Liberty and its management person have not been involved in an award or otherwise
found to be liable in any arbitration claim.
Liberty and its management person have not been involved in or otherwise found to
be liable in a civil, self-regulatory organization or administrative proceeding.
Brochure Supplement March 13, 2025
Liberty Private Client, LLC
Michael McCort
5237 SUMMERLIN COMMONS BLVD
#319
Ft Myers, Fl 33907
239-839-6552
This brochure supplement provides information about Michael W. McCort that
supplement’s Liberty Private Client LLC’s brochure. You should have received a
copy of that brochure. Please contact Deana Simcox, Chief Compliance Officer at
610-230-2930 if you did not receive Liberty Private Client, LLC’s brochure or if you
have any questions about the contents of this supplement. If a copy of this brochure
has not been provided at least 48 hours prior to signing the contract, the client has 5
business days to cancel the contract without any penalty.
Additional information about Michael McCort is available on the SEC’s website at
www.adviserinfo.sec.gov.
Michael McCort
President
Year of Birth - 1969
Education:
Delaware Valley College, Doylestown, PA - attended
Business Background:
Liberty Private Client, Fort Myers, FL
President, July 2019- present
Girard Partners Ltd., King of Prussia, PA
Vice President, Wealth Advisor - 2014 to July 12, 2019
Vice President & Senior Financial Analyst -2009 to 2014
Charles Schwab Bank, Fort Myers, FL.
VP & Financial Consultant - 2005 to 2009 Charles Schwab & Co.. Inc. Fort Myers, FL
VP & Financial Consultant - 1998 to 2009
Professional Designations/Licenses:
Mr. McCort has successfully completed the following Financial Industry Regulatory Authority
("FTNRA") examinations:
Series 7 - General Securities –expired
Representative Series 63 - Uniform -expired
Securities Agent State Law Series 66 –
Uniform Combined State Law
Series 65- Uniform Investment Advisor Law Exam
He also holds the following designations:
Accredited Asset Management Specialist (AAMS)
Financial Para planner Qualified Professional (FPQP)
The College for Financial Planning awards the Accredited Asset Management
Specialist designation to students who successfully complete the program, pass the
final examination, and comply with the Code of Ethics, which includes agreeing to
abide by the Standards of
Professional Conduct and Terms and Conditions.
The College for Financial Planning awards the Financial Para Planner Qualified
Professional designation to students who successfully complete the program, pass
the final examination, sign a code of ethics commitment, fill out a declaration
form, and complete a three-month internship.
Legal or Disciplinary Events:
Mr. McCort has no legal or disciplinary events to report.
Other Business Activities:
Mr. McCort has no other business activities to report.
Additional Compensation:
Mr. McCort receives no additional compensation or economic benefits that
require disclosure
Supervision:
Mr. McCort is supervised by Deana Simcox, Chief Compliance Officer who can be
reached at 610-230-2930.
Brochure Supplement
March 13, 2025
Richard B. Seidel
Liberty Private Client
125 Strafford Ave
Room 116
Wayne, PA 19087
610-230-2930
This brochure supplement provides information about Richard B. Seidel that
supplement’s Liberty Private Client, LLC’s brochure. You should have received a
copy of that brochure. Please contact Deana Simcox Chief Compliance Officer at 610-
230-2930 if you did not receive Liberty Private LLC’s brochure or if you have any
questions about the contents of this supplement.
Additional information about Richard B. Seidel is available on the SEC’s website at
www.adviserinfo.sec.gov.
Richard B. Seidel
Chairman
Year of Birth: 1941
Education:
St. John’s University, New York, New York, 1966, JD
Georgetown University, Washington, DC - 1963, B.A.
Business Background:
Liberty Private Client, LLC, Ft Myers, FL
Chairman May 2020-present
Girard Private Investment Group, LLC, Naples, FL
Chairman, 2015 to May 2020
RB Seidel & Associates, Naples, FL
Founder, 2014 to Present
Girard Partners Ltd., King of Prussia, PA
Chairman, 1995 to 2014
Girard Capital, LLC, King of Prussia, PA
Chairman, 2009 to 2014
Professional Designations/Licenses:
Mr. Seidel has successfully completed the following Financial Industry Regulatory
Authority (“FINRA”) examinations:
Series 7 – General Securities Representative
Series 24 – General Securities Principal
Series 63 – Uniform Securities Agent State Law
Series 65 – Uniform Investment Advisers Law
Legal or Disciplinary Events:
Mr. Seidel has no legal or disciplinary events to report.
Other Business Activities:
Mr. Seidel is also the founder and owner of a law firm, Seidel & Associates. Seidel & Associates
provides wills, estate planning, estate settlements, and other estate related services. Seidel &
Associates may refer business to Advisor and Advisor may refer business to Seidel & Associates.
Referral fees are not anticipated to be paid in connection with these referrals.
Additional Compensation:
Mr. Seidel receives no fees.
Supervision:
Mr. Seidel is an employee and registered person of Liberty Private Client, LLC. Mr. Seidel
is supervised by Deana Simcox, Chief Compliance Officer who can be reached at 610-230-
2930 and Michael McCort, President, can be reached at 839-239-6552.
Brochure Supplement
March 13, 2025
Ashlyn Smith
Liberty Private Client
125 Strafford Ave
Room 116
Wayne, PA 19087
610-230-2930
This brochure supplement provides information about Ashlyn Smith that supplement’s
Liberty Private Client’s brochure. You should have received a copy of that brochure.
Please contact Deana Simcox, Chief Compliance Officer at 610-230-2930 if you did not
receive Liberty Private Client's brochure or if you have any questions about the contents of
this supplement.
Additional information about Ashlyn Smith is available on the SEC’s website at
www.adviserinfo.sec.gov.
Ashlyn Smith
Research Analyst
Year of Birth: 1998
Education:
Salisbury University May 2020 B. A.
Business Background:
JP Morgan Chase & Co.
Trade Lifecycle Specialist August 2022- December 2023
Vanguard, US
Financial Tax Associate April 2021-July 2022
Liberty Private Client, Wayne, PA
Portfolio Manager & Research Analyst, January 2023- present
Professional Designations/Licenses:
Series 65 – Uniform Securities Agent State Law
Legal or Disciplinary Events:
Ms. Smith has no legal or disciplinary events to report.
Other Business Activities:
Ms. Smith has no other business activities to report.
Additional Compensation:
Ms. Smith receives no additional compensation or economic benefits that require disclosure.
Supervision:
Ms. Smith activities are supervised by Michael McCort, the President, who can be reached
at (239-275-2538) and Deana Simcox, Chief Compliance Officer, who can be reached at
(610-239-2930).