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4800 Hampden Lane, Suite 200
Bethesda, MD 20814
(301) 907-6794
http://www.macroviewim.com
Date of Brochure: February 25, 2026
This brochure provides information about the qualifications and business practices of MacroView
Investment Management LLC. If you have any questions about the contents of this brochure, please
contact Daniel Cohen at (301) 907-6795 or at dcohen@macroviewim.com. The information in this
brochure has not been approved or verified by the United States Securities and Exchange Commission or
by any state securities authority.
Additional information about MacroView Investment Management LLC is also available on the Internet at
www.adviserinfo.sec.gov. Clients can search this site by using the adviser’s name or by an identification
number known as a CRD number. The CRD number for MacroView Investment Management LLC is
149621.
Registration as an investment adviser does not imply a certain level of skill or training.
ITEM 2 - SUMMARY OF MATERIAL CHANGES
MacroView Investment Management LLC is required to disclose any material changes to this ADV
Part 2A here in Item 2. There are no material changes to disclose at this time.
ITEM 3 - TABLE OF CONTENTS
ITEM 2 - SUMMARY OF MATERIAL CHANGES .................................................................................................2
ITEM 3 - TABLE OF CONTENTS .........................................................................................................................2
ITEM 4 - ADVISORY BUSINESS .........................................................................................................................3
ITEM 5 - FEES AND COMPENSATION ...............................................................................................................6
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 ..................................9
ITEM 9 - DISCIPLINARY INFORMATION ......................................................................................................... 12
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ................................................. 12
ITEM 11 - CODE OF ETHICS, PARTICIPATION IN CLIENT TRANSACTIONS AND PERSONAL TRADING 12
ITEM 12 - BROKERAGE PRACTICES .............................................................................................................. 13
ITEM 13 - REVIEW OF ACCOUNTS ................................................................................................................. 16
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION ................................................................... 17
ITEM 15 - CUSTODY ........................................................................................................................................ 18
ITEM 16 - INVESTMENT DISCRETION ............................................................................................................ 18
ITEM 17 - VOTING CLIENT SECURITIES ........................................................................................................ 19
ITEM 18 - FINANCIAL INFORMATION ............................................................................................................. 19
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ITEM 4 - ADVISORY BUSINESS
1. Background
MacroView Investment Management LLC (“we” or “MacroView”) is an investment adviser that has
been registered with the U.S. Securities and Exchange Commission since June 2, 2010. The firm’s
principal owner is Daniel J. Cohen.
2. Services Provided
a. Personal Wealth Management
We offer personalized, discretionary investment management services, meaning we provide clients
with continuous and on-going supervision over their investment accounts and make trades in those
accounts when appropriate. We start by fully evaluating a client’s desires, goals, risk tolerances,
liquidity needs, and other essential characteristics. We then formulate an investment plan specific
to that client.
Clients are given the ability to impose reasonable restrictions on their separate accounts, including
specific investment selections and sectors. However, we will not enter into an investment advisory
relationship with anyone whose investment objectives may be considered incompatible with our
investment philosophy or strategies or where the prospective client seeks to impose unduly
restrictive investment guidelines. Furthermore, because MacroView cannot control the portfolio
management practices of mutual funds and ETFs, clients may not restrict the portfolio holdings of
such collective vehicles. Clients can, however, restrict the acquisition of specifically identified mutual
funds or ETFs or all mutual funds or ETFs generally.
b. Zoe Financial, Inc. Platform
MacroView has an agreement with Zoe Financial, Inc., an investment adviser firm registered with
the U.S. Securities and Exchange Commission, to utilize their administrative, back-office and
operational services to assist us in the management and servicing of our client accounts. Zoe
Financial, Inc. provides a wealth management platform that provides reporting, administrative, re-
balancing and other support services relating to the administration of the client accounts that we
decide to link and therefore administer through the Zoe Financial platform.
The recommendation of the Zoe Financial, Inc. platform is made on a non-discretionary basis and is
always based on each client’s individual needs.
We will tell you, verbally and in writing, if we use the Zoe Financial, Inc. platform to help administer
your account(s). We do not place all of our client accounts through the Zoe Financial, Inc. platform.
We most commonly use the platform as a way to efficiently deliver services to client investment
portfolios that are below our traditional minimum asset, or fee, levels for our core services.
Although not exhaustive, the following is a list of “back-office” (i.e., administrative, and operational
services) and management services provided by Zoe Financial, Inc.:
Maintenance and access to client dashboards.
Maintenance and access to advisor firm dashboards.
Training and assistance with new account forms and transaction paperwork.
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Monitor and assist with timely processing of custodial paperwork.
Prepare daily downloads from custodians.
Place approved trades through Apex as broker/dealer and custodians, including the ability to
perform manual and automated account rebalancing.
Prepare and review performance and positions reports.
Assist with paperwork archiving.
Collect and process investment advisory fees.
When Zoe Financial, Inc. is selected to help manage an account, Zoe Financial, Inc. will have
access to and authority on your account to place trades and make changes to the account as
directed by MacroView. Please refer to Item 16 – Investment Discretion for more information.
To participate in the Zoe Financial, Inc. platform, you must open an account with Apex Clearing
Corporation (“Apex”) to serve as broker/dealer and qualified custodian for your account. See Item
12 – Brokerage Practices for more information about Apex.
A complete description of Zoe Financial, Inc.’s services, practices and fees are provided in its Form
ADV Part 2A, a copy of which will be provided to you if Zoe Financial, Inc. is utilized to assist in the
management of your account.
c. Sub-Advisory Services
MacroView also makes its investment management services available to unaffiliated registered
investment advisers. In this regard, the unaffiliated adviser’s client establishes an investment
advisory relationship with the unaffiliated adviser and authorizes that primary adviser to delegate
the management of all or a portion of the client’s assets to MacroView as sub-adviser.
If the adviser determines that utilizing MacroView’s investment management services is in its
client’s best interest, the adviser assists the client in completing any paperwork necessary for
MacroView to assume its responsibilities regarding the account and provides all necessary
information to MacroView. Where MacroView agrees to accept a sub-advisory client, MacroView
will manage only those assets as to which it has been appointed as sub-adviser and will not
consider any other securities, cash or other investments owned by the client.
MacroView currently manages sub-advised assets through both Charles Schwab and Co., Inc
(“Schwab”). MacroView’s strategy consists of a mix of portfolios with varying levels of risk and
specific asset allocations.
The client’s primary investment adviser selects the allocation most suited to the client and instructs
MacroView accordingly. The primary adviser also monitors the client’s resources, needs, and risk
tolerance on an ongoing basis and directs MacroView to adjust the strategy allocation if doing so is
in the client’s best interest.
All sub-advised assets are held at the custodian selected by the primary adviser and all trades for
sub-advised accounts are affected through or with the broker-dealer selected by the primary adviser.
Please see Section I.5. below for more information.
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d. Use of Independent Third Party Managers
When determined appropriate and consistent with a client’s investment mandates, we will
recommend that certain portions of a client's portfolio be managed by independent third-party
managers or recommend direct investment with independent third-party managers, typically when
those managers demonstrate knowledge and expertise in a particular investment strategy.
Based on a client’s individual circumstances and needs, we will determine which selected money
manager's portfolio management style is appropriate for that client. Factors considered in making
this determination include account size, risk tolerance, and the investment philosophy of the
selected money manager. We encourage clients to review each third-party manager’s disclosure
document regarding the particular characteristics of any program and managers selected by us.
We will regularly and continuously monitor the performance of the selected money managers. If we
determine that a particular selected money manager is not providing sufficient management
services to the client or are not managing the client's portfolio in a manner consistent with the
client's investment objectives, we will remove the client's assets from that selected money manager.
e. Retirement Plan Consulting
MacroView offers fee based qualified retirement plan services that provide non-discretionary and
discretionary Investment Fiduciary Services to Sponsors and Trustees of qualified retirement plans.
MacroView will assist you in establishing a menu of mutual funds and / or models to offer to
participating employees of the qualified retirement plan. Employees will self-direct the investments
of their accounts within the plan.
As an ERISA 3(21) Investment Advisor, services are designed to allow the Sponsor to retain full
discretionary authority or control over assets of the Plan. We will solely be making
recommendations to the Sponsor. MacroView will recommend investments to the plan sponsor,
monitor the plan’s investments, suggest replacements as appropriate, develop and monitor risk-
based models comprised solely from the plan’s investment menu, provide investment advice with
respect to the selection of a Qualified Default Investment Alternative (“QDIA”), and provide
participant education. MacroView will provide guidance to the plan sponsor in meeting its fiduciary
responsibilities, including development of an investment policy statement. The Sponsor retains
decision making authority and may accept or reject any recommendations.
As an ERISA 3(38) Investment Manager, services are designed to allow the plan fiduciary to
delegate responsibility for managing, acquiring, and disposing of Plan assets that meet the
requirements of the Employee Retirement Income Security Act of 1974 (“ERISA”). If appointed as
an ERISA 3(38) Investment Manager, MacroView would have full discretionary authority to select,
monitor, and remove the investment options offered in a qualified retirement plan.
In either case, whether we are engaged as a 3(21) Investment Advisor or 3(38) Investment
Manager, we will perform investment services through our investment advisor representatives
(“IARs”), and will charge a fee for services rendered, as described in this Form ADV and the
Agreement.
MacroView may also provide Retirement Plan Consulting services that are designed to allow our
IARs to assist the Sponsor in meeting their fiduciary duties to administer the plan in the best
interests of plan participants and their beneficiaries. MacroView does not custody plan assets as
non-affiliated firms provide custodial services to the accounts.
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f. Financial Planning Services
MacroView offers financial planning to all its Personal Wealth Management clients. MacroView also
makes its financial planning services available à la carte to non-Personal Wealth Management
clients.
Financial planning is an evaluation of an individual’s current and future financial state using
currently known variables to attempt to predict future cash flows, asset values, and withdrawal
plans. Those who request this service receive advice designed to assist them in achieving their
financial goals and objectives.
We gather information from individuals through interviews and the review of various financial
documents provided by the client, including a confidential questionnaire completed by the client.
Information gathered includes current financial status, tax situation, future goals, and attitude
towards risk. We carefully review the information gathered and deliver our advice and
recommendations during meetings or telephone calls.
3. Assets Managed
As of December 31, 2025, MacroView had a total of $387,072,284 in assets under management. All
these assets are managed on a discretionary basis. In addition, MacroView provides Retirement
Plan consulting services totaling $78,598,477.
ITEM 5 - FEES AND COMPENSATION
1. Personal Wealth Management
We charge for investment management services based on a percentage of assets under
management. Our investment management fee for Personal Wealth Management accounts
generally does not exceed 1.5% annually and is negotiable depending on factors such as amount of
assets the client has in separate accounts under management with us, the amount of assets in
related separate accounts, our relationship with the client, and the complexity of the client’s
situation. We believe our fees for advisory services are reasonable with respect to the services
provided and the fees charged by other investment advisers offering similar services. However,
lower fees for comparable services may be available from other sources.
Fees are billed quarterly in arrears and calculated based on the net value of the account as
determined by the account custodian on the last day of the billing period. MIM will adjust the
management fee for capital inflows and outflows during the billed quarter. If an agreement for
services is executed mid-period, the initial fee is prorated based on the number of days those
services were provided. Likewise, if the advisory relationship is terminated during a billing period,
we charge a prorated fee based on the number of days those services were provided prior to the
date of the termination. The client can terminate our services immediately, at any time by providing
us with written notice. MacroView can terminate its relationship with a client upon 30 days’ advance
written notice.
In most cases, with client consent, fees are automatically deducted from the Personal Wealth
Management account by the account’s custodian, who then pays the fees directly to MacroView.
(Not all custodians permit this arrangement.) The custodian sends each client an account statement
at least quarterly showing all disbursements from the account, including MacroView’s advisory fees.
MacroView will buy shares of load, no-load or load-waived open-end mutual funds, closed-end funds,
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or exchange-traded funds for a client's account. In such cases, in addition to paying advisory fees
to MacroView, the client must pay a proportionate amount of the mutual fund's operating expenses,
including management fees paid to the fund's adviser. In addition, all Personal Wealth Management
accounts incur brokerage and other transaction costs and will, depending on the circumstances,
incur custody, account maintenance fees, mutual fund sales loads, or 12b-1 fees. Please refer to
Item 12 below for a discussion of our brokerage practices.
2. Portion of Fees Paid to Zoe Financial, Inc.
Zoe Financial Inc. charges MacroView an annual “minimum platform fee” of $24,000. In addition,
Zoe Financial, Inc. charges MacroView a “service fee” of 15 basis points on all of MacroView client
assets being administered and managed through the Zoe Financial, Inc. platform. Zoe Financial,
Inc. will receive the greater of the “minimum platform fee” or the total “service fee”. The “service fee”
is taken from the overall fee charged to clients by MacroView. In other words, Zoe Financial, Inc.
will receive a percentage of the fees charged by MacroView detailed in fee descriptions above.
However, it is our policy to not increase our advisory fee on accounts maintained through Zoe
Financial, Inc. to offset the portion they receive. Therefore, clients are subject to the same
MacroView fee schedule whether Zoe Financial, Inc. is used or not as client fees are not higher
because of our decision to use Zoe Financial, Inc.
When MacroView directs clients to utilize Apex Clearing, whether the client is on the Zoe Financial,
Inc. platform or not, Zoe Financial Inc. will debit 15 basis points from the “minimum platform fee”
which results in savings to MacroView. When we direct clients to Schwab or Fidelity, Zoe Financial,
Inc. does not debit 15 basis points from the “minimum platform fee”. This creates an economic
incentive for MacroView to direct clients to Apex instead of Schwab or Fidelity. This is a conflict of
interest because our recommendation to use Apex is based, at least in part, on MacroView’s
interest of saving money on the Zoe Financial, inc. “minimum platform fee” and not based solely on
the client’s interest of receiving best execution. Moreover, because we receive client leads and
prospects from Zoe Financial, Inc., we have an interest and incentive to recommend Zoe Financial
and Apex over other companies providing similar services. This is a conflict of interest.
MacroView has taken steps to manage its conflicts of interest arising from its agreements with Zoe
Financial, Inc. and Apex, whereby MacroView and its investment adviser representatives will not
exercise discretion with respect to selecting Zoe Financial, Inc. as a platform provider and using
Apex as qualified custodian. We will explain to clients the positives and negatives of using each as
they apply to the client’s unique, individual situation. We will make a recommendation to use Zoe
Financial, Inc. and/or Apex only when in the best interest of the individual client and without regard
to the financial interest of MacroView. Please refer to Item 12 – Brokerage Practices and Item 14 -
Client Referrals and Other Compensation for more information.
3. Sub-Advisory Services
Where MacroView acts as a sub-adviser, MacroView receives an annual fee of typically 0.30%, but
may be higher or lower depending on the particular sub-advisory relationship. In addition, where
properly authorized MacroView will take fees directly from the sub-advised accounts directly.
4. Use of Independent Third Party Managers
Where MacroView recommends a third-party investment manager/sub-advisor to its advisory
clients, and those clients use that sub-advisor’s services, MacroView’s advisory clients pays the sub-
advisor’s management fee directly and these fees are in addition to MacroView’s management
fees.
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5. Retirement Plan Consulting
Generally, MacroView fees for services to retirement plans are either a fixed fee ranging from $5,000
to $100,000 or 0.10% to 0.50% per annum based on a percentage of the gross market value of a
Plan’s assets on which MacroView provides consulting services. Any fees charged outside of the
above stated range must be approved by MacroView’s Chief Compliance Officer. Fees are
negotiable and will be determined by the scope and nature of the services provided, the amount of
assets in the Plan, the complexity of the Plan document and other factors.
Depending upon the capabilities and requirements of the Plan’s recordkeeper or custodian, we may
collect our Fees in arrears or in advance. Typically, Sponsors instruct the Plan’s recordkeeper or
custodian to automatically deduct our Fees from the Plan account; however, in some cases a
Sponsor may request that we send invoices directly to the Sponsor or recordkeeper/custodian.
Sponsors receiving Retirement Plan Services may pay more than or less than a client might
otherwise pay if purchasing the Retirement Plan Services separately or through another service
provider. There are several factors that determine whether the costs would be more or less,
including, but not limited to, the size of the Plan, the specific investments made by the Plan, the
number of or locations of Plan participants, services offered by another service provider, and the
actual costs of Retirement Plan Services purchased elsewhere. In light of the specific Retirement
Plan Services offered by us, the Fees charged may be more or less than those of other similar
service providers. In determining the value of the Account for purposes of calculating any asset-
based Fees, MacroView will rely upon the valuation of assets provided by Sponsor or the Plan’s
custodian or recordkeeper without independent verification.
Unless we agree otherwise, no adjustments or refunds will be made in respect of any period for (i)
appreciation or depreciation in the value of the Plan account during that period or (ii) any partial
withdrawal of assets from the account during that period. If the Agreement is terminated by us or by
Sponsor, we will refund certain Fees to Sponsor to the extent provided in Section 8 of the
Agreement. Unless we agree otherwise, all Fees shall be based on the total value of the assets in
the account without regard to any debit balance.
All Fees paid to us for Retirement Plan Services are separate and distinct from the fees and
expenses charged by the designated plan investment options (mutual funds, group annuities,
separate accounts, collective investment trusts and exchange-traded funds) to their shareholders.
These fees and expenses are described in each investment's prospectus. These fees will generally
include a management fee, other expenses, and possible distribution fees. If the investment also
imposes sales charges, a client may pay an initial or deferred sales charge. The Retirement Plan
Services we provide may, among other things, assist the client in determining which investments
are most appropriate to each client's financial condition and objectives and to provide other
administrative assistance as selected by the client. Accordingly, the client should review both the
fees charged by the funds, the fund manager, the Plan's other service providers, and the fees
charged by us to fully understand the total amount of fees to be paid by the client and to evaluate
the Retirement Plan Services being provided.
In the event we receive any third-party payments or subsidies in connection with our Retirement
Plan Services, we will disclose such fees to Sponsors in accordance with ERISA and Department of
Labor regulations.
No increase in the Fees will be effective without prior written notice.
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6. Financial Planning Services
Financial planning services are included in the fee MacroView charges its Personal Wealth
Management clients. In the event MacroView is asked to provide financial planning services on an à
la carte basis, MacroView will charge either an hourly rate or a fixed amount based on the scope of
services provided. An hourly fee of no more than $500 per hour is charged by MacroView for
financial planning services under this arrangement. The minimum fixed fee is generally $500, and
the maximum fixed fee is generally no more than $10,000.
ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
This item does not apply to our business. We do not receive performance-based fees.
ITEM 7 - TYPES OF CLIENTS
MacroView provides investment advice to individuals, including high net worth individuals, and to
corporations or other business entities, non-profit organizations, and pension and profit-sharing
plans.
MacroView requires a $300,000 minimum to establish a Personal Wealth Management account,
although we are available to discuss and grant exceptions to this minimum based on a client’s
current and historical relationship with us or anticipated additional deposits to the account.
Clients can aggregate or “bundle” multiple accounts per person and multiple family members to
reach the required minimum.
MacroView also offers sub-advisory or consulting services to unaffiliated investment advisors as set
forth in Item 4, Section 2b and 2c above.
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
Our primary approach to investing is based on a long-term macroeconomic view of the economy.
From that highest level of analysis, we then develop diversified strategies designed to protect and or
grow, given our outlook. This is commonly referred to as a “top down” approach. In implementing
this approach, we employ several methods of analysis that include fundamental, technical, cyclical,
and charting analysis.
1. Strategies and Methods of Analysis
MacroView manages client assets using a predominantly top-down approach. MacroView pulls
from a large universe of investments and drills down into securities for use in client portfolios
utilizing performance related factors for actively and passively managed portfolios.
Each client’s portfolio will be invested according to that client’s investment objectives, which are
ascertained by fully evaluating a client’s desires, goals, risk tolerances, liquidity needs, and other
essential characteristics. Once MacroView ascertains the client’s objectives for the client’s
portfolio, MacroView develops a set of asset allocation guidelines that will aide in executing the
proper allocation strategy between accounts. Utilizing a performance-based analysis, MacroView
will base conclusions on predominantly publicly available research, such as regulatory filings, press
releases, competitor analyses, and in some cases research we receive from our custodian or other
market analyses.
The investment strategies that MacroView recommends are based on the needs of the client and
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are unique to each client. As a result, the asset allocation guidelines for one client may be similar
to or different from another client.
MacroView may periodically recommend changes to the investment strategies and client portfolios
to meet the guidelines of the asset allocation for an individual client’s objectives. It is important to
remember that because market conditions can vary greatly, asset allocation guidelines are not
necessarily strict rules. Rather, MacroView reviews accounts individually, and may deviate from the
guidelines as MacroView believes necessary.
When MacroView makes changes to an investment strategy, these changes may not be made
simultaneously. Rather, some accounts may be modified before others. This may result in
accounts being traded earlier inadvertently having an advantage over accounts traded later.
Additionally, as assets are transitioned from a client’s prior advisors to MacroView, clients may hold
legacy securities and may place restrictions on individual security types. Legacy securities are
those that a client owned prior to or separate from its MacroView portfolio. If a client transitions
mutual fund shares to MacroView that are not the lowest-cost share class, and MacroView is not
recommending disposing of the security altogether, MacroView will attempt to convert such mutual
fund share classes into the lowest-cost share classes the client is eligible for, taking into account
any adverse tax consequences associated with such conversion.
2. Third Party Managers
In some instances, MacroView can utilize other managers to assist in the management of client
assets. These managers are selected by MacroView after a process whereby MacroView
evaluates each manager’s investment performance, operations, and offerings to determine if the
manager would be a fit for MacroView clients. This process continues on an ongoing basis,
throughout the time the client works with the third-party manager. Prior to referring any client to
another manager, MacroView will confirm that such manager is registered, or exempt from
registration, as an investment adviser.
3. Risk of Loss
It is important for you to know and remember that all investments carry risks. Investing in
securities involves risk of loss that clients should be prepared to bear. This includes loss of
original principal. Investors also must understand that the past performance of any security is not
indicative of future results. Do not assume that the future performance of any specific investment or
investment strategy will be profitable. MacroView does not represent or guarantee that a client’s
goals will be achieved.
Among the risks involved with our top-down approach to investing are misdiagnosing the economic
outlook and wrongly selecting investments that lose money and or perform poorly. Further,
depending on the different types of investments selected, there may be varying degrees of the
following risks:
Market Risk. Either the market as a whole, or the value of an individual company, goes
down, resulting in a decrease in the value of client investments. This is referred to as
systemic risk.
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Equity (Stock) Market Risk. Common stocks are susceptible to fluctuations and to volatile
increases/decreases in value as their issuers’ confidence in or perceptions of the market
change. Investors holding common stock (or common stock equivalents) of any issuer are
generally exposed to greater risk than if they hold preferred stock or debt obligations of the
issuer.
Company Risk. There is always a certain level of company or industry specific risk when
investing in stock positions. This is referred to as an unsystematic risk and can be reduced
through appropriate diversification. There is the risk that a company may perform poorly or
that its value may be reduced based on factors specific to it or its industry (e.g., employee
strike, unfavorable media attention).
Fixed Income Risk. Investing in bonds involves the risk that the issuer will default on the
bond and be unable to make payments. In addition, individuals depending on set amounts
of periodically paid income face the risk that inflation will erode their spending power. Fixed-
income investors receive set, regular payments that face the same inflation risk.
ETF and Mutual Fund Risk. ETF and mutual fund investments bear additional expenses
based on a pro-rata share of operating expenses, including potential duplication of
management fees. The risk of owning an ETF or mutual fund generally reflects the risks of
owning the underlying securities held by the ETF or mutual fund. Clients also incur
brokerage costs when purchasing ETFs.
Management Risk. Investments also vary with the success and failure of the investment
strategies, research, analysis, and determination of portfolio securities. If the strategies do
not produce the expected returns, the value of the investments will decrease.
Regulatory Risk. Changes in laws and regulations from any government can change the
value of a given company and its accompanying securities. Certain industries are more
susceptible to government regulation. Changes in zoning, tax structure or laws impact the
return on these investments.
Risks specific to private placements, sub-advisors, and other managers. If we invest some
of your assets with another advisor, including a private placement, there are additional risks.
These include risks that the other manager is not as qualified as we believe them to be, that
the investments they use are not as liquid as we would normally use in your portfolio, or that
their risk management guidelines are more liberal than we would normally employ.
Information Risk. All investment professionals rely on research in order to make conclusions
about investment options. This research is always a mix of both internal (proprietary) and
external (provided by third parties) data and analyses. Even an adviser who says they rely
solely on proprietary research must still collect data from third parties. This data, or outside
research is chosen for its perceived reliability, but there is no guarantee that the data or
research will be completely accurate. Failure in data accuracy or research will translate to a
compromised ability by the adviser to reach satisfactory investment conclusions.
Concentration Risk. While MacroView selects individual securities, including mutual funds,
for client portfolios based on an individualized assessment of each security, this evaluation
comes without an overlay of general economic or sector specific issue analysis. This means
that a client’s equity portfolio may be concentrated in a specific sector, geography, or sub-
sector (among other types of potential concentrations), so that if an unexpected event
occurs that affects that specific sector or geography, for example, the client’s equity
portfolio may be affected negatively, including significant losses.
Transition risk. As assets are transitioned from a client’s prior advisers to MacroView
there may be securities and other investments that do not fit within the asset allocation
strategy selected for the client. Accordingly, these investments will need to be sold in order
to reposition the portfolio into the asset allocation strategy selected by MacroView. However,
this transition process may take some time to accomplish. Some investments may not be
unwound for a lengthy period of time for a variety of reasons that may include unwarranted
low share prices, restrictions on trading, contractual restrictions on liquidity, or market-
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related liquidity concerns. In some cases, there may be securities or investments that are
never able to be sold. The inability to transition a client's holdings into recommendations of
the client's account values, as MacroView’s
MacroView may adversely affect
recommendations may not be able to be fully implemented.
Restriction Risk. Clients may at all times place reasonable restrictions on the management
of their accounts. However, placing these restrictions may make managing the accounts
more difficult, thus lowering the potential for returns.
Risks Related to Investment Term & Liquidity. Securities do not follow a straight line up in
value. All securities will have periods of time when the current price of the security is not an
accurate measure of its value. If you require us to liquidate your portfolio during one of
these periods, you will not realize as much value as you would have had the investment had
the opportunity to regain its value. Further, some investments are made with the intention of
the investment appreciating over an extended period of time. Liquidating these investments
prior to their intended time horizon may result in losses.
Excess Cash Balance Risk. Client accounts may have cash balances in excess of
$250,000, which is the insurance limit of the Federal Deposit Insurance Corporation. For
cash balances in excess of that amount, there is an enhanced risk that operation related
counterparty risk related to the account custodian could cause losses in the account. We
mitigate this risk by carrying cash balances in amounts either subject to protection or as
limited as you, the client, directs. You may elect to participate in a “cash sweep” program
through your account custodian which automatically moves excess cash from your
investment account into a cash account and then invests that cash into cash-based
investments, such as money market funds. We do not receive compensation of any kinds
for facilitating your participation in such cash sweep accounts.
ITEM 9 - DISCIPLINARY INFORMATION
This item does not apply to us. There are no legal or disciplinary events that are material to a client’s
evaluation of our business or the integrity of our management.
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Certain of MacroView’s professionals in their individual capacities, are licensed insurance agents
with various insurance companies, and in such capacity, may recommend, on a fully disclosed
basis, the purchase of certain insurance products. A conflict of interest exists to the extent that
MacroView or its representatives recommend the purchase of insurance products where
MacroView or its representatives receive insurance commissions or other additional compensation,
rather than on a client’s needs. The receipt of additional fees or commissions for insurance is
therefore a conflict of interest, and clients should be aware of this conflict when considering whether
to engage MacroView to implement any insurance recommendations. MacroView attempts to
mitigate this conflict of interest by disclosing the conflict to clients and informing the clients that they
are always free to purchase insurance products or estate planning through other agents that are not
affiliated with MacroView, or to determine not to purchase the insurance product at all. MacroView
also attempts to mitigate the conflict of interest by requiring employees to acknowledge in the firm’s
Code of Ethics, their individual fiduciary duty to the clients of MacroView, which requires that
employees put the interests of clients ahead of their own. Commissions from the sale of insurance
products will not be used as a credit against or to offset advisory fees.
ITEM 11 - CODE OF ETHICS, PARTICIPATION IN CLIENT TRANSACTIONS AND PERSONAL
TRADING
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1. Code of Ethics
We have adopted a Code of Ethics as required by Rule 204A-1 under the Investment Advisers Act
of 1940 (the “Advisers Act”). This Code, which applies to all our officers, members, and employees
(our “supervised persons”), addresses the fiduciary duties of care and loyalty that we, as an
investment adviser, owe to our clients. In this regard, the Code of Ethics requires all supervised
persons to conduct business with the highest level of ethical standards, to avoid all circumstances
that might negatively affect or appear to negatively affect our clients’ best interests, and to comply
with all federal securities laws. The Code also covers our insider trading and personal securities
transactions policies and procedures and addresses the importance of safeguarding our clients’
personal and financial information.
Once employed by or affiliated with MacroView, and at least annually thereafter, all supervised
persons sign an acknowledgement that they have read, understand, and agree to comply with
MacroView’s Code of Ethics. If a client wishes to review MacroView’s Code of Ethics in its entirety,
MacroView will send a copy promptly upon written request.
2. Personal Trading
Our supervised persons are permitted to buy or sell securities or have an interest or position in a
security for their personal accounts that we also recommend to clients. As these situations
represent a conflict of interest, we have developed written supervisory procedures that include
personal investment and trading policies for all our supervised persons. These policies and
procedures include the following:
Associated persons cannot prefer their own interests to those of our clients
Associated persons cannot purchase or sell any security for their personal accounts prior to
implementing transactions for client accounts
Associated persons cannot buy or sell securities for their personal accounts when those
decisions are based on information obtained as a result of their employment, unless that
information is also available to the investing public upon reasonable inquiry
We maintain records of all securities holdings of our supervised persons. These records are
reviewed on a regular basis by our Chief Compliance Officer.
Any supervised person who fails to observe our policies, or who violates any applicable law or rule is
subject to sanctions up to and including termination.
ITEM 12 - BROKERAGE PRACTICES
1. Directed Brokerage and Best Execution
We recommend, but do not require, clients to establish accounts at Schwab, Fidelity Investments,
and/or National Financial Services LLC (“Fidelity”) and to direct us to affect their portfolio trades
through such accounts. (Not all advisers make such recommendations to their clients.). In addition
to Schwab and Fidelity, clients may establish accounts with Apex Clearing Corporation (“Apex”) as
part of the Zoe Wealth Platform discussed above in Item 5. Schwab, Fidelity, and Apex’s brokerage
commissions may not be the lowest in the industry, but they are reasonable in view of execution
quality, the level of service provided to clients and the brokerage and research services we receive.
To ensure that our recommendation of Schwab, Fidelity and Apex continues to be in our clients’
best interest, we will periodically monitor their execution performance, services, prices, and
commissions.
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Part of our agreement with Zoe Financial, Inc. is a financial incentive for us to recommend Apex
over other qualified custodians including Schwab and Fidelity. Zoe Financial, Inc. will lower/offset
the fees they charge for their platform and lead-generation services when we direct clients to use
Apex. Please see Item 5 – Fees and Compensation and Item 14 - Client Referrals and Other
Compensation for information. This is a conflict of interest. MacroView has taken steps to manage
its conflicts of interest arising from its agreements with Zoe Financial, Inc. and Apex, whereby
MacroView and its investment adviser representatives will not exercise discretion with respect to
selecting Zoe Financial, Inc. as a platform provider and using Apex as qualified custodian. We will
explain to clients that positives and negatives of using each as they apply to the client’s unique,
individual situation. We will make a recommendation to use Zoe Financial, Inc. and/or Apex only
when in the best interest of the individual client and without regard to the financial interest of
MacroView.
When performing sub-advisory services, we use, but are not limited to Schwab, Fidelity, and Apex
as the custodian. However, it is up to the unaffiliated investment adviser to determine the custodian
that we sub-advise through.
Clients may open accounts and direct us to affect their portfolio trades through a different broker-
dealer or bank, subject to our approval. Under these circumstances, we generally will not negotiate
or monitor commissions or execution costs for clients.
2. Research and Other Soft-Dollar Benefits
We receive research and ancillary brokerage and administrative products and services from
Schwab and Fidelity in consideration of the amount of our clients’ Personal Wealth Management
assets custodied at that firm. We do not commit to generate any level of commissions in order to
obtain these products and services, which include software and other technology that:
Provide access to client account data (such as trade confirmation and account statements)
Facilitate trade execution (and allocation of aggregated trade orders for multiple client
accounts)
Provide research, pricing information, and other market data
Facilitate payment of our fees from client accounts
Assist with back-office functions, recordkeeping, and client reporting
MacroView also receives unsolicited investment research from other broker-dealers, whether or not
we trade client accounts through those firms.
MacroView uses at least some of the ancillary products and services it receives through these
various soft-dollar arrangements in the management of all our accounts, not just those whose
commissions pay for the services. In other words, soft-dollar benefits are not allocated to accounts
in proportion to the commission credits the accounts generate. While MacroView’s receipt of these
services in connection with client portfolio transactions benefits clients by enabling us to make more
informed investment decisions and to do so more efficiently, this arrangement also confers a benefit
on MacroView, because we do not have to produce or pay for the services, we receive this way.
Thus, we have an incentive to recommend broker-dealers based on our interest in receiving
research and other products rather than on our clients’ interests in receiving most favorable
execution.
To protect our clients’ interests, MacroView has adopted policies and procedures designed to
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ensure that our soft-dollar practices either qualify for the safe harbor established under Section 28(e)
of the Securities Exchange Act of 1934 or have been authorized by our clients. We periodically
monitor our receipt and use of ancillary services to ensure that our portfolio trading practices remain
in our clients’ interests.
3. Brokerage for Client Referrals
MacroView does not recommend particular broker-dealers in exchange for referrals of advisory clients.
4. Trade Aggregation and Order of Executions
a. ETFs/Mutual Funds/Individual Equities
MacroView is committed to treating all clients fairly. Because we generally buy highly liquid
securities for our clients, we believe it is unlikely that clients would be disadvantaged by the order in
which their trades are executed. Nevertheless, to mitigate the risk of individual accounts’ receiving
disparate treatment, we effect discretionary trades for Personal Wealth Management accounts in
one of two ways:
Simultaneous Trades – Building Out Portfolios
When we invest for clients beyond regular maintenance or rebalancing (i.e., new clients or
significant deposits), we first trade those accounts custodied at Schwab or Fidelity. In the event we
are trading at both custodians, we alternate between the two as to which trades are executed first.
After completing trades through Schwab and Fidelity we execute for accounts at other custodians.
Block Trades for Existing Portfolios
When we purchase or sell the same securities at the same time for all clients for whom such
transactions are suitable, we often aggregate orders into a “block” or “bundled” trade, because it is
the most efficient way to execute and allocate these trades. Under this procedure, transactions for
each security are averaged as to price and are allocated among our clients in proportion to the
purchase and sale orders placed for each client account on any given day.
Orders for the accounts of MacroView’s supervised persons will be aggregated with those of the
firm’s clients. If a block order is only partially filled, and a pro rata allocation would result in the
purchase or sale of too few shares to justify the trade commission, the firm’s supervised persons
will not receive an allocation until all client orders have been filled. In the event we are block trading
at both Schwab and Fidelity we alternate between the two custodians as to which trades are
executed first.
Please note that clients who have directed us to use a custodian other than Schwab or Fidelity are
not able to participate in block trades, and we typically place their directed trades after placing the
block trades.
b. Trading Individual Bonds
Buying Bonds
To ensure best execution when purchasing bonds, MacroView attempts to consult multiple price
sources before completing the transaction. For example, if a third-party broker shows us a bond that
we want at a particular price, we refer to the pricing at the custodian for comparison. If we purchase
through a third-party (not the custodian), the client may be subject to additional trade-away fees
charged by the custodian.
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Allocating Bonds
Depending on the size of a particular bond purchase, not all clients in need of a bond may be part
of the trade allocation. There are times when a new client will receive bonds at a faster rate than
other clients who already have a larger percentage of their account already invested in bonds. The
goal here is to make reasonable and fair efforts to invest a new client’s potentially relatively large
cash balance.
Selling Bonds
To ensure best execution when selling a bond, MacroView sends the bond out to the “street” where
we will seek multiple bids before completing the transaction. If we choose to execute the trade
through a third party (instead of the client’s custodian), the client may be subject to additional trade-
away fees charged by the custodian.
5. Sub-Advisory Services
a. Trading Equities
When trading equity positions, we follow generally the same methodology as we do for our
Separately Managed Accounts. MacroView will exercise full discretion in applying those trades.
b. Trading Fixed Income
When trading fixed income in accounts containing sub-advised assets, we will follow the same
methodology as we do for our Separately Managed Accounts in I.4.b. There are times when a new
client will receive bonds at a faster rate than other clients who already have a larger percentage of
their account already invested in bonds. The goal here is to make reasonable and fair efforts to invest
a new client’s potentially relatively large cash balance.
6. Agency Cross Transactions
When MacroView needs to raise cash for an advisory client, we may sell a bond from that client’s
portfolio and buy the bond into another client’s portfolio. When conducting this cross-transaction, the
recipient will receive the bond at the current market price.
Most of MacroView’s cross transactions are trade-aways executed through a third party (not the
custodian). When MacroView crosses a bond, the custodian will charge the seller and buyer each a
trade-away fee. Note: all trade aways (even if not a cross transaction) are subject to the custodian’s
additional fee.
ITEM 13 - REVIEW OF ACCOUNTS
1. Account Reviews
Accounts (for any service we provide) are reviewed regularly and the underlying securities are
continuously monitored. Changes in the market or in individual securities can also trigger more
frequent reviews. During the review process, we check performance and risk measures in relation
to the clients’ goals, objectives, and risk tolerances.
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2. Account Reports
Personal Wealth Management clients receive confirmations and statements from the account
custodians at least quarterly. In addition, MacroView provides those clients with a periodic position
and performance report on all accounts. Clients are urged to compare the statements received from
the account custodian with the reports received from MacroView and contact either the custodian or
MacroView with any questions.
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION
1. Client Referrals
In addition to the Zoe Financial platform services described in Items 4 & 5 of this brochure,
MacroView has also entered into an agreement with Zoe Financial, Inc. to receive referrals
generated from Zoe Financial, Inc.’s online marketing efforts (https://zoefin.com/). Zoe Financial,
Inc. is registered as an investment adviser firm with the U.S. Securities and Exchange Commission
and provides a lead generation service by directing potential investors to their website where
investors can view financial professionals that have signed up for the Zoe Financial, Inc. service,
including our firm and our affiliated persons.
This is a paid arrangement whereby we have agreed to compensate Zoe Financial, Inc. a fee for
each individual referred to us that becomes a client of MacroView. Individuals that contact Zoe
Financial, Inc. either directly or online will be connected with investment professionals and will then
decide which investment professional provider to consider.
Zoe Financial, Inc. does not proactively call or speak to individuals about MacroView but if an
individual contacts Zoe Financial, Inc. for a recommended financial provider, the individual could be
connected to MacroView if Zoe Financial. Inc. determines it could be a proper match based on their
criteria and methodology. At that time, Zoe Financial, Inc. will provide the individual with disclosures
(detailing among other things, the fee we pay to Zoe Financial, Inc.) along with a copy of our Form
ADV brochure.
Prospective clients have the option to contact us directly or ask Zoe Financial, Inc. to have us initiate
contact.
MacroView pays Zoe Financial, Inc. for its services based on the total fees paid to MacroView
pursuant to the services provided by MacroView to the client.
We pay Zoe Financial, Inc. a fee of up to 35 basis points (0.35%) of gross fees received on
an annual basis for the first $2 million of assets under management.
The fee is 10 basis points (0.10%) annually between $2 million to $10 million of assets under
management; and
Five basis points (0.05%) for assets under management in excess of $10 million of assets
under management.
If we charge the referred client an hourly or fixed fee for financial planning, we have agreed to pay
Zoe Financial, Inc., 30% of any revenue derived from such payments for services for a five-year
period.
When client assets are transferred to Apex Clearing (“Apex”) the 35-basis point per annum fee, on
the first $2 million of assets under management, will be reduced by 15-basis points. In those
situations, while the fee that MacroView pays to Zoe Financial is reduced by 15-basis points,
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MacroView will still pay the 15-basis point Zoe Wealth platform fee. In other words, MacroView is
always incurring a cost of 35-basis points (on the first $2 million of assets under management) for
clients referred by Zoe. When client assets are transferred to Schwab or Fidelity the entire 35-basis
points is attributable to a fee. When client assets are transferred to the Zoe Wealth Platform
utilizing Apex as the custodian only 20 basis is billed to MacroView as a fee and 15-basis points is
billed to MacroView as a platform fee. Please refer to the prior disclosures in Item 4 – Business
Activities and Item 12 – Brokerage Practices regarding Apex Clearing and the benefit we get from
Zoe Financial for recommending clients open accounts through Apex Clearing.
Individuals referred to MacroView by Zoe Financial, Inc. are not required or obligated in any way to
work with MacroView. The selection of an investment adviser is important and should not be based
solely on marketing or referrals, including referrals from Zoe Financial, Inc.
Individuals that find us through Zoe Financial, Inc. are free to work with any investment adviser or
financial professional of their own choosing.
2. Other Compensation
MacroView does not receive an economic benefit from anyone who is not a client for rendering our
services to clients, other than the soft-dollar arrangements described in Section 1 above.
ITEM 15 - CUSTODY
“Custody,” as it applies to investment advisers, is not limited to physically holding client funds and
securities. If an investment adviser can access or control client funds or securities, the investment
adviser is deemed to have custody for purposes of the Advisers Act. However, “custody” does not
include the ability to execute transactions in client accounts. MacroView is deemed to have custody
over a client’s account(s) when the client authorizes their custodian(s) to pay our advisory fees
directly via fee debit from the account(s). However, we do not maintain the physical possession of
client assets or have custody in any other way.
All funds and securities in client accounts are held at Schwab or Fidelity or another qualified
custodian (i.e., bank or broker-dealer). Clients or an independent representative of the client will
direct, in writing, the creation of all accounts and therefore, clients are aware of the qualified
custodian’s name, address and the way the funds or securities are maintained. The qualified
custodian delivers account statements to each client, or the client’s independent representative, at
least quarterly. Clients should carefully review those statements and are urged to compare the
statements with reports received from MacroView. When clients have questions about their account
statements, they should contact MacroView or the qualified custodian preparing the statement.
ITEM 16 - INVESTMENT DISCRETION
MacroView’s investment management services are rendered on a discretionary basis. This means
we make all decisions to buy, sell, or hold securities, cash, or other investments in the Personal
Wealth Management account in our sole discretion without consulting with the client before
implementing any transactions. Clients must provide written authorization for us to exercise this
discretionary authority. This written authorization is provided in the Asset Management Agreement
and custodial account paperwork. Clients can impose reasonable restrictions on managing their
accounts as described above.
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Notwithstanding the above, in rare circumstances, and for specific personal reasons, a client can
direct the purchase or sale of a specified security in his or her account. Such trades will be deemed
to be non-discretionary.
ITEM 17 - VOTING CLIENT SECURITIES
We do not vote proxies on behalf of our Personal Wealth Management accounts; nor do we act on
behalf of client accounts with regard to legal matters, including securities class actions involving
clients’ investments or the issuers thereof.
We understand that clients receive proxies and other solicitations directly from their custodian or
transfer agent.
ITEM 18 - FINANCIAL INFORMATION
This item is not applicable to us.
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