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ITEM 1 - COVER PAGE
Malaga Cove Capital, LLC
425 Via Corta
Suite 303
Palos Verdes Estates, CA 90274
www.MalagaCoveCapital.com
310-421-2141
Form ADV, Part 2A Brochure
February 13, 2026
This brochure provides information about the qualifications and business practices of Malaga Cove
Capital, LLC. If you have any questions about the contents of this brochure, please contact us at 310-
421-2141. 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.
Any reference to or use of the terms “registered investment adviser” or “registered,” does not imply
that Malaga Cove Capital, LLC or any person associated with Malaga Cove Capital, LLC has achieved
a certain level of skill or training.
www.adviserinfo.sec.gov
Additional information about Malaga Cove Capital, LLC (IARD#146959) is available on the SEC’s
website at
.
ITEM 2 - MATERIAL CHANGES
The purpose of this page is to inform you of any material changes since the previous version of this
brochure. If you are receiving this brochure for the first time this section may not be relevant to
you.
•
Since the last update filed on January 30, 2025, the following changes have been made:
Item 4 has been updated to disclose the firm’s current assets under management.
Malaga Cove Capital, LLC reviews and updates the brochure at least annually to make sure that it is
still current.
Malaga Cove Capital, LLC
ITEM 3- TABLE OF CONTENTS
ITEM 1 - COVER PAGE ........................................................................................................................... 1
ITEM 2 - MATERIAL CHANGES .............................................................................................................. 2
ITEM 3- TABLE OF CONTENTS ................................................................................................................ i
ITEM 4 - ADVISORY BUSINESS .............................................................................................................. 1
Description of Advisory Firm .................................................................................................................... 1
Advisory Services Offered ......................................................................................................................... 1
Investment Management Services ....................................................................................................... 1
ERISA Plan Services ............................................................................................................................... 2
Limitations on Investments .................................................................................................................. 3
Tailored Services and Client Imposed Restrictions ................................................................................... 3
Wrap Fee Programs .................................................................................................................................. 4
Assets Under Management ...................................................................................................................... 4
ITEM 5 - FEES AND COMPENSATION ..................................................................................................... 4
Fee Schedule ............................................................................................................................................. 4
Investment Management Services ....................................................................................................... 4
ERISA PLAN SERVICES ........................................................................................................................... 4
Billing Method .......................................................................................................................................... 5
Investment Management Services ....................................................................................................... 5
Other Fees and Expenses .......................................................................................................................... 5
Termination .............................................................................................................................................. 6
Other Compensation ................................................................................................................................ 6
ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ............................................. 6
ITEM 7 - TYPES OF CLIENTS ................................................................................................................... 6
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS .................................. 6
Methods of Analysis and Investment Strategies ...................................................................................... 6
Methods of Analysis for Selecting Securities ....................................................................................... 6
Investing Involves Risk .............................................................................................................................. 7
Specific Security Risks ............................................................................................................................... 7
General Risks of Owning Securities ...................................................................................................... 7
Equity Securities ................................................................................................................................... 8
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Debt Securities (Bonds) ........................................................................................................................ 8
Municipal Bonds ................................................................................................................................... 9
Municipal Bonds of a Particular State ................................................................................................ 10
Real Estate Investment Trusts ............................................................................................................ 10
American Depository Receipts (ADRs) ............................................................................................... 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 ............................................................................................................................................ 11
Code of Ethics Description ...................................................................................................................... 11
Investment Recommendations Involving a Material Financial Interest and Conflict of Interest ........... 12
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest .......... 12
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions
and Conflicts of Interest ......................................................................................................................... 12
Aggregation with Client Orders .......................................................................................................... 12
ITEM 12 - BROKERAGE PRACTICES ...................................................................................................... 13
How We Select Brokers/Custodians ................................................................................................... 13
Your Brokerage and Custody Costs .................................................................................................... 13
Products and Services Available to Us from Schwab ......................................................................... 13
Brokerage for Client Referrals ............................................................................................................ 15
Directed Brokerage ............................................................................................................................ 15
Aggregation and Allocation of Transactions ........................................................................................... 15
ITEM 13 - REVIEW OF ACCOUNTS ....................................................................................................... 15
Managed Account Reviews .................................................................................................................... 15
Account Reporting .................................................................................................................................. 16
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION................................................................ 16
Schwab Support Products and Services ............................................................................................. 16
Professional Referrals ......................................................................................................................... 16
ITEM 15 - CUSTODY ............................................................................................................................ 17
ITEM 16 - INVESTMENT DISCRETION .................................................................................................. 17
ITEM 17 - VOTING CLIENT SECURITIES ................................................................................................ 17
ITEM 18 - FINANCIAL INFORMATION .................................................................................................. 17
Form ADV, Part 2B Brochure Supplement ............................................................................................. i
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Alfred (“Al”) Charles Walsh III .............................................................................................................. ii
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ..................................................... ii
ITEM 3 - DISCIPLINARY INFORMATION ................................................................................................. ii
ITEM 4 - OTHER BUSINESS ACTIVITIES .................................................................................................. ii
ITEM 5 - ADDITIONAL COMPENSATION ................................................................................................ ii
ITEM 6 - SUPERVISION ......................................................................................................................... ii
Mark Wade Choate ............................................................................................................................. iii
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE .................................................... iii
ITEM 3 - DISCIPLINARY INFORMATION ................................................................................................ iii
ITEM 4 - OTHER BUSINESS ACTIVITIES ................................................................................................. iii
ITEM 5 - ADDITIONAL COMPENSATION ............................................................................................... iii
ITEM 6 - SUPERVISION ........................................................................................................................ iii
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ITEM 4 - ADVISORY BUSINESS
Description of Advisory Firm
Malaga Cove Capital, LLC (“Malaga,” “we,” “our,” or “us”) is a privately-owned Limited Liability
Company headquartered in Palos Verdes Estates, California. Malaga is a registered investment
adviser with the U.S. Securities and Exchange Commission.
Malaga was founded in May of 2008 by Alfred (“Al”) C. Walsh, III and Mark Choate. Al Walsh is a
Principal and Managing Member at Malaga. Mark Choate is Chief Executive Officer at Malaga.
Al Walsh and Mark Choate both serve as portfolio managers providing individuals and high net
worth individuals with wealth management services. Our services include investment analysis, and
direct, full time investment execution and monitoring of clients’ assets.
Advisory Services Offered
Malaga offers the following services to advisory clients:
Investment Management Services
Malaga provides continuous and regular investment supervisory services on a discretionary basis.
Al Walsh and Mark Choate, Principal, work with clients and have the ongoing responsibility to
select and/or make recommendations, based upon the objectives of the client, as to specific
securities or other investments that they purchase or sell in client accounts.
Malaga may offer investment advice on any investment held by the client at the start of the advisory
relationship. Recommendations for new investments will typically include equity securities,
including stocks and foreign securities listed on US exchanges (ADRs) or foreign exchanges
(ordinaries). For clients in need of capital preservation Malaga may recommend fixed income
securities, including corporate and government bonds, commercial paper, and certificates of
deposit (CDs), money market funds and cash.
Item 16 - Investment Discretion
Malaga may offer advice on other investments held in a client’s portfolio at the beginning a
relationship with Malaga. There may also be additional types of investments that Malaga will
provide advice on if they are appropriate to address the individual needs, goals, and objectives of
the client or in response to client inquiry.
Tailored Services and
. For more
Item 5 - Fees and
We discuss our discretionary authority below under
Client Imposed Restrictions
information about the restrictions clients can put on their accounts, see
in this item below.
Compensation
We describe the Fees charged for investment management services below under
.
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ERISA Plan Services
Malaga provides service to qualified and non-qualified retirement plans including 401(k) plans,
403(b) plans, pension and profit sharing plans, cash balance plans, and deferred compensation
3(38) Investment Manager.
plans. Malaga acts as a 3(38) advisor:
Malaga can also act as an ERISA 3(38) Investment Manager in which it
has discretionary management and control of a given retirement plan’s assets. Malaga would then
become solely responsible and liable for the selection, monitoring and replacement of the plan’s
investment options.
1.
Fiduciary Services are:
Adviser has discretionary authority and will make the final decision regarding the initial
selection, retention, removal and addition of investment options in accordance with the
Plan’s investment policies and objectives. Adviser acknowledges that it is a fiduciary as
defined under ERISA.
Assist the Client with the selection of a broad range of investment options consistent
with ERISA Section 404(c) and the regulations thereunder.
Assist the Client in the development of an investment policy statement (“IPS”). The IPS
establishes the investment policies and objectives for the Plan. Client shall have the
ultimate responsibility and authority to establish such policies and objectives and to
adopt and amend the IPS.
Assist in monitoring investment options by preparing periodic investment reports that
document investment performance, consistency of fund management and conformance
to the guidelines set forth in the IPS and make recommendations to maintain, remove or
replace investment options.
Meet with Client on a periodic basis to discuss the reports and the investment
recommendations.
Provide discretionary investment advice to the Plan Sponsor with respect to the
selection of a qualified default investment alternative for participants who are
automatically enrolled in the Plan or who have otherwise failed to make investment
elections. The Client retains the sole responsibility to provide all notices to the Plan
participants required under ERISA Section 404(c) (5).
2.
Non-fiduciary Services are:
Assist in the education of Plan participants about general investment information and
the investment alternatives available to them under the Plan. Client understands the
Adviser’s assistance in education of the Plan participants shall be consistent with and
within the scope of the Department of Labor’s definition of investment education
(Department of Labor Interpretive Bulletin 96-1). As such, the Adviser is not providing
fiduciary advice as defined by ERISA to the Plan participants. Adviser will not provide
investment advice concerning the prudence of any investment option or combination of
investment options for a particular participant or beneficiary under the Plan.
Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding by the
employees.
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Adviser may provide these services or, alternatively, may arrange for the Plan’s other providers
to offer these services, as agreed upon between Adviser and Client.
3.
The Adviser has no responsibility to provide services related to the following types of assets
(“Excluded Assets”):
a.
b.
c.
d.
e.
f.
not
g.
Employer securities;
Real estate (except for real estate funds or publicly traded REITs);
Stock brokerage accounts or mutual fund windows;
Participant loans;
Non-publicly traded partnership interests;
Other non-publicly traded securities or property (other than collective trusts
and similar vehicles); or
Other hard-to-value or illiquid securities or property.
be included in calculation of Fees paid to the Adviser under this
Excluded Assets will
Agreement.
Limitations on Investments
In some circumstances, Malaga’s advice may be limited to certain types of securities.
Limitation by Plan Sponsor/Employer
In the event Malaga is managing assets within a retirement plan such as 401(k), or other employer
plan, Malaga will abide by the investment criteria established in the plan. Similarly, when we
provide services to participants in an employer-sponsored plan, the participant may be limited to
investing in securities included in the plan’s investment options. Therefore, Malaga can only make
recommendations to the client from among the available options, and will not recommend or invest
the client’s account in other securities, even if there may be better options elsewhere.
Tailored Services and Client Imposed
Malaga may also limit advice based on certain client-imposed restrictions. For more information
Restrictions
about the restrictions clients can put on their accounts, see
in this Item below.
Non-managed Assets
With respect to investment management services, Malaga will only be responsible for the
supervision and management of securities we recommend. Malaga will not be responsible for the
supervision or management of non-managed assets. Non-managed assets may include securities
held in a client’s account that is under management with Malaga that were:
1.
2.
3.
4.
Delivered into the account by the client;
Purchased by the client;
Purchased by Malaga at the request of the client as an accommodation; or
Designated by the client to be non-managed securities by written notification.
Tailored Services and Client Imposed Restrictions
Malaga generally seeks clients whose financial objectives are capital growth and appreciation. For
details see Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss. We make
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investment decisions for clients based on information the client supplies about their financial
situation, goals, and risk tolerance. Our recommendations may be limited if the client does not
provide us with accurate and complete information. It is the client’s responsibility to keep Malaga
informed of any changes to their investment objectives.
Malaga reserves the right to not accept and/or terminate management of a client’s account if we
feel that the client objectives are not in line with our investment strategies of capital growth and
appreciation.
Wrap Fee Programs
Malaga does not manage accounts as part of a wrap or bundled fee program.
Assets Under Management
Malaga has the following assets under management:
Discretionary Amounts:
Non-discretionary Amounts:
Date Calculated:
$310,929,712
$0
December 31, 2025
ITEM 5 - FEES AND COMPENSATION
Fee Schedule
Investment Management Services
Malaga charges advisory fees for investment management services. Malaga‘s advisory fees are
charged based on a percentage of the client’s total assets under management and range from 1.00%
to 2.00%, annually. The advisory agreement between Malaga and the client will state the client’s
annual fee. Our standard fee schedule may be negotiable based on a number of factors, which
include but are not limited to “grandfathered” accounts, related accounts, and other structures that
we may consider in special situations. We also manage some family and related accounts at a
discount or without charge.
ERISA PLAN SERVICES
The annual fees are based on the market value of the Included Assets and will not exceed 1%. The
initial fee will be based on the market value of the Plan assets as calculated by the custodian or
record keeper of the Included Assets on the first business day of the initial fee period and will be
due on the first business day of the fee period. If the services to be provided start any time other
than the first day of a quarter, the fee will be prorated based on the number of days remaining in
the initial fee period. Thereafter, the fee will be based on the market value of the Plan assets on the
last business day of the previous fee period (without adjustments for anticipated withdrawals by
Plan participants or other anticipated or scheduled transfers or distribution of assets) and will be
due the following business day. If this Agreement is terminated prior to the end of the fee period,
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Malaga shall be entitled to a prorated fee based on the number of days during the fee period
services were provided. Any unearned fees shall be refunded to the Plan or Plan Sponsor.
The compensation of Malaga for the services is described in detail in Schedule A of the ERISA Plan
Agreement. The Plan is obligated to pay the fees, however the Plan Sponsor may elect to pay the
fees. Malaga does not reasonably expect to receive any additional compensation, directly or
indirectly, for its services under this Agreement. If additional compensation is received, Malaga will
disclose this compensation, the services rendered, and the payer of compensation. Malaga will
offset the compensation against the fees agreed upon under this Agreement.
Billing Method
Investment Management Services
(Annual Rate) x (Total Assets Under Management at Quarter-End) / 4.
Malaga’s advisory fees are payable quarterly in advance at the beginning of each calendar quarter.
We charge one fourth of the annual fee each quarter based on the market value of the client’s
portfolio as of the last day of the prior calendar quarter. The formula used for the calculation is as
follows:
At our discretion, we
may make pro-rations for additions or withdrawals during a quarter. The client’s quarterly fee
calculation will reflect any pro-rated additions and/or reductions.
For new client accounts, the first payment is a pro-rata calculation payable at the beginning of the
first full quarter under management. The calculation will take into consideration the number of
(Result of Quarterly Calculation) x
days remaining in the quarter and the initial value of the portfolio. The formula used to calculate
(Days Remaining in Quarter) / (Total Number of Days in Quarter).
the initial advisory fee for the partial quarter would be as follows:
It is up to the client whether they wish to have the advisory fees withdrawn directly from their
custodian account or pay by check. With client authorization, Malaga will automatically withdraw
Malaga’s advisory fee from the client’s account held by an independent custodian. Typically, the
custodian withdraws advisory fees from the client’s account during the first month of each quarter
based on Malaga’s instruction. All clients will receive brokerage statements from the custodian no
less frequently than quarterly. The custodian statement will show the deduction of the advisory fee
for those clients who authorize the advisory fees to be withdrawn directly from their custodian
account. Clients who choose not to have advisory fees withdrawn directly from their custodian
account are expected to pay Malaga upon receipt of the invoice. The invoice will include the fee
calculation and amount due.
Other Fees and Expenses
Malaga’s fees do not include custodian fees. Clients pay all brokerage commissions, stock transfer
Item 12 -
fees, and/or other similar charges incurred in connection with transactions in accounts from the
Brokerage Practices
assets in the account, which are in addition to the fees client pays to Malaga. See
below for more information.
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Termination
Either party may terminate the advisory agreement at any time by providing written notice to the
other party. The client may terminate the agreement at any time by writing Malaga at our office.
Malaga will refund any prepaid, unearned advisory fees. Upon termination of the agreement the
(Fees Paid) x
client will receive a prorated refund of unearned advisory fees which will be calculated based on
(Days Remaining in Quarter)/(Total Number of Days in Quarter).
the date Malaga receives notification of the cancelation using the following formula:
Other Compensation
Malaga does not accept compensation for the sale of securities or other investment products.
Malaga’s only compensation is the advisory fees clients pay to Malaga.
ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
Malaga does not charge performance based fees. Performance based fees are those based on a share
of capital gains on or capital appreciation of the assets of a client.
ITEM 7 - TYPES OF CLIENTS
Malaga offers discretionary investment advisory services to individuals, high net worth individuals,
trusts and estates, and individual participants of retirement plans. In addition, we offer advisory
services to charitable organizations and businesses.
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK
OF LOSS
Methods of Analysis and Investment Strategies
Malaga generally seeks clients whose financial objectives are capital growth and appreciation.
Typically Malaga’s clients’ risk attitude will fall in the medium to high volatility range. Clients
understand that their investments may come with additional risk. Clients that do not seek these
types of investments will be referred to other advisors. Clients established prior to Malaga making
the decision to only manage accounts with the objective of capital growth and appreciation will be
grandfathered in to continue receiving services. Malaga utilizes primarily equity securities when
developing a client’s portfolio.
Client portfolios with similar investment objectives and asset allocation goals may own different
securities. Timing and tax factors also influence Malaga’s investment decisions. Clients who buy or
sell securities on the same day may receive different prices.
Methods of Analysis for Selecting Securities
Malaga may use fundamental and/or technical analysis in the selection of individual securities.
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Fundamental Analysis
Malaga may use a buy and hold investment strategy, utilizing fundamental analysis to make
individual security recommendations.
Technical Analysis
Malaga offers active portfolio management, utilizing technical analysis, in an effort to determine
market trends, support and resistance levels, logical profit objectives and exit points.
Long-Term Holdings
Malaga’s strategy consists of purchasing, holding, and rebalancing a diversified portfolio of publicly
traded equities and periodically bonds. Malaga typically intends to hold these investments for over
a year except when sales are necessary to rebalance the portfolio or to fund replacement
acquisitions. When selecting publicly traded equities, Malaga may focus on the potential for income
and/or growth, depending on the client’s investment objectives.
Malaga does not attempt to time the market nor do we attempt to capture short-term gains. Short
term buying and selling of securities is limited to those cases where a purchase has resulted in an
unanticipated gain or loss in which we believe that a subsequent sale is in the best interest of the
client.
Investing Involves Risk
should be prepared to bear that risk.
Investing in securities involves risk of loss, and clients
Prior to entering into an agreement with Malaga, the client should carefully consider:
1.
2.
3.
4.
That investing in securities involves risk of loss which clients should be prepared to bear;
That securities markets experience varying degrees of volatility;
That over time the client’s assets may fluctuate and at any time be worth more or less than
the amount invested; and
That clients should only commit assets that they feel are currently unneeded and available
to Malaga for investment on a long-term basis. This is typically a minimum of five to seven
years.
Specific Security Risks
General Risks of Owning Securities
The prices of securities held in client accounts and the income they generate may decline in
response to certain events taking place around the world. These include events directly involving
the issuers of securities held in a client’s account, conditions affecting the general economy, and
overall market changes. Other contributing factors include local, regional, or global political, social,
or economic instability and governmental or governmental agency responses to economic
conditions. Finally, currency, interest rate, and commodity price fluctuations may also affect
security prices and income.
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Equity Securities
Equity securities represent an ownership position in a company. Equity securities typically consist
of common stocks. The prices of equity securities fluctuate based on, among other things, events
specific to their issuers and market, economic and other conditions. For example, prices of these
securities can be affected by financial contracts held by the issuer or third parties (such as
derivatives) relating to the security or other assets or indices.
There may be little trading in the secondary market for particular equity securities, which may
adversely affect Malaga's ability to value accurately or dispose of such equity securities. Adverse
publicity and investor perceptions, whether or not based on fundamental analysis, may decrease
the value and/or liquidity of equity securities.
Money Market Funds
Money market funds have relatively low risks, compared to other mutual funds (and most other
investments). By law, they can invest in only certain high quality, short-term investments issued by
the U.S. Government, U.S. corporations, and state and local governments. Money market funds try to
keep their net asset value (NAV), which represents the value of one share in a fund, at a stable $1.00
per share. However, the NAV may fall below $1.00 if the fund’s investments perform poorly.
Investor losses have been rare, but they are possible. Money market funds pay dividends that
generally reflect short-term interest rates, and historically the returns for money market funds
have been lower than for either bond or stock funds. That is why “inflation risk,” the risk that
inflation will outpace and erode investment returns over time, can be a potential concern for
investors in money market funds.
Debt Securities (Bonds)
Periodically, Malaga will recommend debt securities. Debt securities are used by issuers to borrow
money and generally, issuers pay investors periodic interest and repay the amount borrowed either
periodically during the life of the security and/or at maturity. Some debt securities, such as zero
coupon bonds, do not pay current interest, but are purchased at a discount from their face values
and their values accrete over time to face value at maturity. The market prices of debt securities
fluctuate depending on such factors as interest rates, credit quality and maturity. In general, market
prices of debt securities decline when interest rates rise and increase when interest rates fall. The
longer the time to a bond’s maturity, the greater its interest rate risk.
Certain additional risk factors relating to debt securities include:
Reinvestment Risk
When interest rates are declining, investors have to reinvest their interest income and any return of
principal, whether scheduled or unscheduled, at lower prevailing rates.
Inflation Risk
Inflation causes tomorrow’s dollar to be worth less than today’s; in other words, it reduces the
purchasing power of a bond investor’s future interest payments and principal, collectively known
as “cash flows.” Inflation also leads to higher interest rates, which in turn leads to lower bond
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prices. Inflation-indexed securities such as Treasury Inflation Protection Securities (TIPS) are
structured to remove inflation risk.
Interest Rate And Market Risk
Debt securities may be sensitive to economic changes, political and corporate developments, and
interest rate changes. Periods of economic change and uncertainty also can be expected to result in
increased volatility of market prices and yields of certain debt securities. For example, prices of
these securities can be affected by financial contracts held by the issuer or third parties (such as
derivatives) relating to the security or other assets or indices.
Credit Risk
If the issuer of a debt security defaults on its obligations to pay interest or principal or is the subject
of bankruptcy proceedings, the account may incur losses or expenses in seeking recovery of
amounts owed to it.
Liquidity and Valuation Risk
There may be little trading in the secondary market for particular debt securities, which may affect
adversely the account's ability to value accurately or dispose of such debt securities. Adverse
publicity and investor perceptions, whether or not based on fundamental analysis, may decrease
the value and/or liquidity of debt securities.
Malaga attempts to reduce the risks described above through diversification of the client’s portfolio
and by credit analysis of each issuer, as well as by monitoring broad economic trends and corporate
and legislative developments, but there can be no assurance that we will be successful in doing so.
Credit ratings for debt securities provided by rating agencies reflect an evaluation of the safety of
principal and interest payments, not market value risk. The rating of an issuer is a rating agency's
view of past and future potential developments related to the issuer and may not necessarily reflect
actual outcomes. There can be a lag between the time of developments relating to an issuer and the
time a rating is assigned and updated.
Municipal Bonds
Periodically, Malaga will recommend municipal bonds. Municipal bonds are debt obligations
generally issued to obtain funds for various public purposes, including the construction of public
facilities. Municipal bonds pay a lower rate of return than most other types of bonds. However,
because of a municipal bond’s tax-favored status, investors should compare the relative after-tax
return to the after-tax return of other bonds, depending on the investor’s tax bracket. Investing in
municipal bonds carries the same general risks as investing in bonds in general. Those risks include
interest rate risk, reinvestment risk, inflation risk, market risk, call or redemption risk, credit risk,
and liquidity and valuation risk. Investing in municipal bonds carries risk unique to these types of
bonds, which may include:
Legislative Risk
The risk that a change in the tax code could affect the value of taxable or tax-exempt interest
income.
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Tax-Bracket Changes
Municipal bonds generate tax-free income, and therefore pay lower interest rates than taxable
bonds. Investors who anticipate a significant drop in their marginal income tax rate may be better
served by the higher yield available from taxable bonds.
Liquidity Risk
The risk that investors may have difficulty finding a buyer when they want to sell and may be
forced to sell at a significant discount to market value. Liquidity risk is greater for thinly traded
securities such as lower-rated bonds, bonds that were part of a small issue, bonds that have
recently had their credit rating downgraded or bonds sold by an infrequent issuer. Municipal bonds
may be less liquid than other bonds.
Credit Risk
The risk that a borrower will be unable to make interest or principal payments when they are due
and therefore default. To reduce investor concern, many municipal bonds are backed by insurance
policies guaranteeing repayment in the event of default.
Municipal Bonds of a Particular State
Municipal bonds are debt obligations generally issued to obtain funds for various public purposes,
including the construction of public facilities. Because the fund invests in securities issued by
California municipalities, the fund is more susceptible to factors adversely affecting issuers of
California securities than a comparable municipal bond mutual fund that does not concentrate its
investments in a single state. For example, in the past, California voters have passed amendments to
the state's constitution and other measures that limit the taxing and spending authority of
California governmental entities, and future voter initiatives may adversely affect California
municipal bonds.
Real Estate Investment Trusts
Periodically, Malaga will recommend clients invest in securities issued by real estate investment
trusts (REITs), which primarily invest in real estate or real estate-related loans. Equity REITs own
real estate properties, while mortgage REITs hold construction, development and/or long-term
mortgage loans. The values of REITs may be affected by changes in the value of the underlying
property of the trusts, the creditworthiness of the issuer, property taxes, interest rates, tax laws and
regulatory requirements, such as those relating to the environment. Both types of REITs are
dependent upon management skill and the cash flows generated by their holdings, the real estate
market in general and the possibility of failing to qualify for any applicable pass-through tax
treatment or failing to maintain any applicable exceptive status afforded under relevant laws.
American Depository Receipts (ADRs)
Periodically, Malaga will recommend clients ADRs. An ADR is a stock that trades in the United
States but represents a specified number of shares in a foreign corporation. ADRs are bought and
sold on American markets just like regular stocks, and are issued/sponsored in the U.S. by a bank or
brokerage. ADRs are subject to risks of investing in foreign securities, including, but not limited to,
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less complete financial information available about foreign issuers, less market liquidity, more
market volatility and political instability. In addition, currency exchange-rate fluctuations affect the
U.S. dollar-value of foreign holdings. Dividends may be paid on some ADRs and ordinary shares of
foreign securities and many foreign countries impose dividend withholding taxes up to 30%.
Depending on a custodian’s ability to reclaim any withheld foreign taxes on dividends, taxable
accounts may be able to recoup a portion of these taxes by use of the foreign tax credit. However,
tax-exempt accounts, to the extent they pay any foreign withholding taxes, may not be able to
utilize the foreign tax credit and, therefore, may be unable to recover any foreign taxes withheld on
dividends of foreign securities or ADRs.
ITEM 9 - DISCIPLINARY INFORMATION
Malaga does not have any disciplinary information to disclose.
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Malaga does not offer any other services or have any affiliates in the financial industry.
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING
Code of Ethics Description
The affiliated persons (affiliated persons include employees and/or independent contractors) of
Malaga have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth
standards of conduct expected of Malaga affiliated persons and addresses conflicts that may arise.
The Code defines acceptable behavior for affiliated persons of Malaga. The Code reflects Malaga and
its supervised persons’ responsibility to act in the best interest of their Client.
One area which the Code addresses is when affiliated persons buy or sell securities for their
personal accounts and how to mitigate any conflict of interest with our Clients. We do not allow any
affiliated persons to use non-public material information for their personal profit or to use internal
research for their personal benefit in conflict with the benefit to our Clients.
Malaga’s policy prohibits any person from acting upon or otherwise misusing non-public or inside
information. No advisory representative or other affiliated person, officer or director of Malaga may
recommend any transaction in a security or its derivative to advisory Clients or engage in personal
securities transactions for a security or its derivatives if the advisory representative possesses
material, non-public information regarding the security.
Malaga’s Code is based on the guiding principle that the interests of the Client are our top priority.
Malaga’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to our
Clients and must diligently perform that duty to maintain the complete trust and confidence of our
Clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of
either affiliated persons or the company.
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The Code applies to “access” persons. “Access” persons are affiliated persons who have access to
non-public information regarding any Clients' purchase or sale of securities, or non-public
information regarding the portfolio holdings of any reportable fund, who are involved in making
securities recommendations to Clients, or who have access to such recommendations that are non-
public.
Malaga will provide a copy of the Code of Ethics to any Client or prospective Client upon request.
Investment Recommendations Involving a Material Financial Interest and Conflict of
Interest
Malaga and its affiliated persons do not recommend to Clients securities in which we have a
material financial interest.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest
Malaga and its affiliated persons may buy or sell securities that are also held by Clients. In order to
mitigate conflicts of interest such as trading ahead of Client transactions, affiliated persons are
required to disclose all reportable securities transactions as well as provide Malaga with copies of
their brokerage statements.
The Chief Compliance Officer of Malaga is Al Walsh. He reviews all trades of the affiliated persons
each quarter. The personal trading reviews ensure that the personal trading of affiliated persons
does not front run or disadvantage trading for Clients.
Client Securities Recommendations or Trades and Concurrent Advisory Firm
Securities Transactions and Conflicts of Interest
Malaga does not have a material financial interest in any securities being recommended. However,
affiliated persons may buy or sell securities at the same time they buy or sell securities for Clients.
In order to mitigate conflicts of interest such as front running, affiliated persons are required to
disclose all reportable securities transactions as well as provide Malaga with copies of their
brokerage statements.
The Chief Compliance Officer of Malaga is Al Walsh. He reviews all trades of the affiliated persons
each quarter. The personal trading reviews ensure that the personal trading of affiliated persons
does not front run or disadvantage trading for Clients.
Participation or Interest in Client Transactions and Personal Trading
Aggregation with Client Orders
1.
Advisor may aggregate purchases and sales and other transactions made for the account
with purchases and sales and transactions in the same securities for other Clients of
Advisor. All clients participating in the aggregated order shall receive an average share
price with all other transaction costs shared on a pro-rated basis.
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ITEM 12 - BROKERAGE PRACTICES
Clients must maintain assets in an account at a “qualified custodian,” generally a broker-dealer or
bank. We recommend that our clients use Schwab Advisor Services™ a division of Charles Schwab &
Co., Inc. (“Schwab”), a registered broker-dealer, member SIPC, as the qualified custodian. We are
independently owned and operated, and unaffiliated with Schwab. Schwab will hold your assets in a
brokerage account, and buy and sell securities when we instruct them to.
While we recommend that you use Schwab as custodian/broker, you will decide whether to do so
and will open your account with Schwab by entering into an account agreement directly with them.
We do not open the account for you, although we may assist you in doing so.
How We Select Brokers/Custodians
We seek to recommend a custodian/broker who will hold your assets and execute transactions on
terms that are, overall, most advantageous when compared to other available providers and their
services. We consider a wide range of factors, including, among others:
1.
2.
3.
4.
5.
6.
7.
Products
8.
9.
10.
Combination of transaction execution services and asset custody services (generally
without a separate fee for custody)
Capability to execute, clear, and settle trades (buy and sell securities for your account)
Capability to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded
funds [ETFs], etc.)
Availability of investment research and tools that assist us in making investment decisions
Quality of services
Competitiveness of the price of those services (commission rates, other fees, etc.) and
willingness to negotiate the prices
Reputation, financial strength, and stability
Prior service to us and our other clients
and Services Available to Us From Schwab
Availability of other products and services that benefit us, as discussed below (see
)
Your Brokerage and Custody Costs
How We Select Brokers/Custodians
).
For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately
for custody services. However, Schwab receives compensation by charging you commissions or
other fees on trades that it executes or that settle into your Schwab account. We have determined
that having Schwab execute most trades is consistent with our duty to seek “best execution” of your
trades. Best execution means the most favorable terms for a transaction based on all relevant
factors, including those listed above (see
Products and Services Available to Us from Schwab
Schwab Advisor Services™ (formerly called Schwab Institutional®) is Schwab’s business serving
independent investment advisory firms like us. They provide Malaga and our clients with access to
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its institutional brokerage, trading, custody, reporting, and related services, many of which are not
typically available to Schwab retail customers. Schwab also makes available various support
services. Some of those services help us manage or administer our clients’ accounts; others help us
manage and grow our business. Schwab’s support services generally are available on an unsolicited
basis (we don’t have to request them) and at no charge to us as long as our clients collectively
maintain a total of at least $10 million of their assets in accounts at Schwab. If our clients
collectively have less than $10 million in assets at Schwab, Schwab may charge us quarterly service
fees of $1,200.
Following is a more detailed description of Schwab’s support services:
Services That Benefit You
Schwab’s institutional brokerage services include access to a broad range of investment products,
execution of securities transactions, and custody of client assets. The investment products available
through Schwab include some to which we might not otherwise have access or that would require a
significantly higher minimum initial investment by our clients. Schwab’s services described in this
paragraph generally benefit you and your account.
Services That May Not Directly Benefit You
Schwab also makes available to us other products and services that benefit us but may not directly
benefit you or your account. These products and services assist us in managing and administering
our clients’ accounts. They include investment research, both Schwab’s own and that of third
parties. We may use this research to service all or a substantial number of our clients’ accounts,
including accounts not maintained at Schwab. In addition to investment research, Schwab also
makes available software and other technology that:
1.
2.
3.
4.
5.
Provide access to client account data (such as duplicate trade confirmations and account
statements)
Facilitate trade execution and allocate aggregated trade orders for multiple client accounts
Provide pricing and other market data
Facilitate payment of our fees from our clients’ accounts
Assist with back-office functions, recordkeeping, and client reporting
Services That Generally Benefit Only Us
Schwab also offers other services intended to help us manage and further develop our business
enterprise. These services include:
1.
2.
3.
4.
Educational conferences and events
Consulting on technology, compliance, legal, and business needs
Publications and conferences on practice management and business succession
Access to employee benefits providers, human capital consultants, and insurance providers
Schwab may provide some of these services itself. In other cases, it will arrange for third-party
vendors to provide the services to us. Schwab may also discount or waive its fees for some of these
services or pay all or a part of a third party’s fees. Schwab may also provide us with other benefits,
such as occasional business entertainment of our personnel.
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Our Interest in Schwab’s Services
The availability of these services from Schwab benefits us because we do not have to produce or
purchase them. We do not have to pay for Schwab’s services so long as our clients collectively keep
a total of at least $10 million of their assets in accounts at Schwab. Beyond that, these services are
not contingent upon us committing any specific amount of business to Schwab in trading
commissions. The $10 million minimum may give us an incentive to recommend that you maintain
your account with Schwab, based on our interest in receiving Schwab’s services that benefit our
business rather than based on your interest in receiving the best value in custody services and the
most favorable execution of your transactions. This is a potential conflict of interest. We believe,
however, that our selection of Schwab as custodian and broker is in the best interests of our clients.
As part of our fiduciary duty to clients, Malaga endeavors at all times to put the interests of our
clients first. Clients should be aware, however, that the receipt of economic benefits by Malaga or
our related persons in and of itself creates a potential conflict of interest and may indirectly
influence Malaga's recommendation of Schwab for custody and brokerage services. Malaga
How We Select Brokers/Custodians
primarily support our selection of Schwab by the scope, quality, and price of Schwab’s services (see
, above) and not Schwab’s services that benefit only us.
Brokerage for Client Referrals
Malaga does not receive client referrals from any broker-dealer or third party in exchange for using
that broker-dealer or third party.
Directed Brokerage
In the event that a client directs Malaga to use a particular broker- dealer for all trading, it should
be understood that under these circumstances best execution may not be achieved. As Malaga will
not have authority to negotiate commissions, obtain volume discounts. In addition, under these
circumstances a disparity in commission charges may exist between the commissions charged to
other clients.
Aggregation and Allocation of Transactions
Item 11 -
Aggregation with Client Orders
We describe our aggregation practices in detail under
above.
ITEM 13 - REVIEW OF ACCOUNTS
Managed Account Reviews
We manage portfolios on a continuous basis and generally review all positions in client accounts at
least quarterly. We offer account reviews to clients on an annual basis. Clients may choose to
receive reviews in person, by telephone, or in writing. Al Walsh and/or Mark Choate, who are both
Principals at Malaga, conduct reviews based on a variety of factors. These factors may include but
are not limited to stated investment objectives, economic environment, outlook for the securities
markets, and the merits of the securities in the accounts.
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In addition, we may conduct a special review of an account based one or more of the following:
1.
2.
3.
4.
A change in the client’s financial objectives, guidelines and/or financial situation
Changes in diversification
Tax considerations
Material cash deposits or withdrawals
Account Reporting
Each client receives a written statement from the custodian that includes an accounting of all
holdings and transactions in the account for the reporting period. Malaga may also provide
additional reporting, such as portfolio holdings and performance, as agreed upon by Malaga and the
client on a case-by-case basis.
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION
Schwab Support Products and Services
Item 12 – Brokerage Practices
We receive an economic benefit from Schwab in the form of the support products and services it
makes available to us and other independent investment advisors whose clients maintain their
accounts at Schwab. These products and services, how they benefit us, and the related conflicts of
interest are described above (see
). We do not base particular
investment advice, such as buying particular securities for our clients, on the availability of
Schwab’s products and services to us.
Professional Referrals
Malaga may refer clients to unaffiliated professionals for specific needs, such as insurance planning,
mortgage brokerage, real estate sales, and estate planning. In turn, these professionals may refer
clients to Malaga for investment management needs. At Malaga, we do not have any agreements
with individuals or companies that we refer clients to, and we do not receive any compensation for
these referrals. However, it could be concluded that Malaga is receiving an indirect economic
benefit from the arrangement, as the relationships are mutually beneficial.
Malaga only refers clients to professionals we believe are competent and qualified in their field. It is
ultimately the client’s responsibility to evaluate the provider. We will generally provide the client
with a list of professionals that the client can contact, and it is solely the client’s decision whether or
not to engage a recommended firm. Clients are under no obligation to purchase any products or
services through these professionals, and Malaga has no control over the services provided by
another firm. Clients who choose to engage these professionals will sign a separate agreement with
the other firm. Fees charged by the other firm are separate from and in addition to fees charged by
Malaga.
If the client desires, Malaga will work with these professionals or the client’s other advisers (such
as an accountant and/or attorney) to help ensure that the provider understands the client’s
investments and to coordinate services for the client. Malaga will never share information with an
unaffiliated professional unless first authorized by the client.
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ITEM 15 - CUSTODY
Malaga has limited custody of some of our clients’ funds or securities when the clients authorize us
to deduct our management fees directly from the client’s account. A qualified custodian (generally a
broker-dealer, bank, trust company, or other financial institution) holds clients’ funds and
securities. Clients will receive statements directly from your qualified custodian at least quarterly.
The statements will reflect the client’s funds and securities held with the qualified custodian as well
as any transactions that occurred in the account, including the deduction of Malaga’s fee. Clients
should carefully review the account statements you receive from your qualified custodian. When
clients receive statements from Malaga as well as from the qualified custodian, clients should
compare these two reports carefully. Clients with any questions about your statements should
contact us at the address or phone number on the cover of this brochure. Clients who do not receive
their statement from your qualified custodian at least quarterly should also notify us.
ITEM 16 - INVESTMENT DISCRETION
Malaga has full discretion to decide the specific security to trade, the quantity, and the timing of
transactions for client accounts. Malaga will not contact clients before placing trades in their
account, but clients will receive confirmations directly from the broker for any trades placed.
Clients grant us discretionary authority in the contracts they sign with us. Clients also give us
trading authority over their accounts when they sign the custodian paperwork.
Item – 12 Brokerage Practices
and
, above.
However, certain client-imposed conditions may limit Malaga’s discretionary authority, such as
Item 4 - Tailored Services and Client
where the client prohibits transactions in specific security types or directs Malaga to execute
Imposed Restrictions
transactions through specific broker-dealers. See also
ITEM 17 - VOTING CLIENT SECURITIES
Malaga does not vote proxies on securities. Clients are expected to vote their own proxies. The
Client will receive their proxies directly from the custodian of their account or from a transfer
agent.
When assistance on voting proxies is requested, Malaga will provide recommendations to the
Client. If a conflict of interest exists, it will be disclosed to the Client. If the Client requires assistance
or has questions, they can reach out to the investment advisor representatives of the firm at the
contact information on the cover page of this document.
ITEM 18 - FINANCIAL INFORMATION
Registered investment advisers are required, in this item, to provide clients with certain financial
information or disclosures about the firm’s financial condition. Malaga does not require the
prepayment of more than $1,200 in fees per client, six months or more in advance, and does not
foresee any financial condition that is, reasonably likely to impair our ability to meet contractual
clients.
commitments
to
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Form ADV, Part 2B Brochure Supplement
Individuals covered by this supplement include:
Alfred (“Al”) Charles Walsh, III
and
Mark Wade Choate
Malaga Cove Capital, LLC
425 Via Corta
Suite 303
Palos Verdes Estates, CA 90274
www.MalagaCoveCapital.com
310-421-2141
February 13, 2026
This brochure supplement provides information about Alfred (“Al”) Charles Walsh, III and Mark
Wade Choate that supplements the Malaga Cove Capital, LLC’s brochure. You should have already
received a copy of that brochure. Please contact Al Walsh if you did not receive our brochure or if
you have any questions about the contents of this supplement.
Additional information about Alfred (“Al”) Charles Walsh, III (CRD#2530231) and Mark Wade
Choate (CRD#46027) is available on the SEC’s website at www.adviserinfo.sec.gov.
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Alfred (“Al”) Charles Walsh III
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Alfred (“Al”) Charles Walsh, III
; Managing Member, Principal and Portfolio Manager, b. 1966
Education:
Oregon Institute of Technology – 1989, BS, Manufacturing Engineering
Business Background:
Malaga Cove Capital, LLC – Managing Member, Principal and Portfolio Manager, May 2008 to
Present
Smith Barney – Senior Vice President and Portfolio Manager, July 1994 to May 2008
ITEM 3 - DISCIPLINARY INFORMATION
Al Walsh has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
Al Walsh’s only business is providing investment advice through Malaga Cove Capital, LLC.
ITEM 5 - ADDITIONAL COMPENSATION
Al Walsh’s compensation comes from their regular salary and ownership of Malaga Cove Capital,
LLC.
ITEM 6 - SUPERVISION
Al Walsh is a Managing Member and Principal at Malaga Cove Capital, LLC and is not supervised by
any other individual.
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Mark Wade Choate
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Mark Choate
; Chief Executive Officer and Portfolio Manager, b. 1945
Education:
The University of Texas – 1966, BA
Business Background:
Malaga Cove Capital, LLC – Chief Executive Officer and Portfolio Manager, May 2008 to Present
Smith Barney – Senior Vice President and Senior Portfolio Manager, June 1974 to June 2007
ITEM 3 - DISCIPLINARY INFORMATION
Mark Choate has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
Mark Choate’s only business is providing investment advice through Malaga Cove Capital, LLC.
ITEM 5 - ADDITIONAL COMPENSATION
Mark Choate’s only compensation comes from their regular salary of Malaga Cove Capital, LLC.
ITEM 6 - SUPERVISION
Mark Choate is a Principal at Malaga Cove Capital, LLC and is not supervised by any other
individual.
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