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Maner Wealth, LLC
Part 2A of Form ADV: Firm Brochure
This brochure provides information about the qualifications and business practices of Maner
Wealth, LLC. If you have any questions about the contents of this brochure, please contact us at
517-323-7500 or by email at: info@manerwealth.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.
We are a registered investment adviser. Registration does not imply a certain level of skill or
training.
Additional information about Maner Wealth, LLC is also available on the SEC’s website at
www.advisorinfo.sec.gov. Maner Wealth, LLC’s CRD number is: 308146.
2425 E. Grand River Ave., Ste. 1
Lansing, MI 48912
517-323-7500
info@manerwealth.com
www.manerwealth.com
Version Date: April 29, 2026
Item 2: Material Changes
There have been the following material changes to report since our last annual update to this
firm brochure, which was on March 28, 2025.
Michael C. Nordmann is no longer an owner or Chief Compliance Officer of the
firm.
Steven Guipe is now the firm’s Chief Compliance Officer.
There are no additional material changes to report.
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Item 3: Table of Contents
Item 2: Material Changes .......................................................................................................................... 1
Item 3: Table of Contents .......................................................................................................................... 2
Item 4: Advisory Business ........................................................................................................................ 3
Item 5: Fees and Compensation ............................................................................................................... 5
Item 6: Performance-Based Fees and Side-By-Side Management ....................................................... 8
Item 7: Types of Clients ............................................................................................................................. 8
Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss ......................... 8
Item 9: Disciplinary Information ........................................................................................................... 15
Item 10: Other Financial Industry Activities and Affiliations ........................................................... 15
Item 11: Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading 16
Item 12: Brokerage Practices ................................................................................................................... 17
Item 13: Review of Accounts .................................................................................................................. 20
Item 14: Client Referrals and Other Compensation ............................................................................ 21
Item 15: Custody ...................................................................................................................................... 21
Item 16: Investment Discretion .............................................................................................................. 21
Item 17: Voting Client Securities ............................................................................................................ 22
Item 18: Financial Information ............................................................................................................... 23
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Item 4: Advisory Business
Introduction and Overview
This brochure contains important information. We encourage you to read it carefully and ask
questions if there is any information that you do not understand.
In this brochure, references to “we,” “us,” “our,” or “our firm” refer to Maner Wealth, LLC.
Individuals who serve as our managers, officers, employees, and investment adviser
representatives may also be referred to as our “advisers.” Our firm’s clients and prospective
clients are referred to as “you,” “your,” or “our clients.”
Maner Wealth, LLC is a Michigan-based investment adviser who was registered with the State
of Michigan from 2020 to 2024. We became registered with the Securities and Exchange
Commission in 2024. Our principal owners are Maner, Costerisan & Ellis, PC. Steven Guipe
serves as our Chief Compliance Officer.
Portfolio Management Services
We provide investment management services on both a discretionary and non-discretionary
basis that use various security investments such as: mutual funds; stocks; bonds; and other
types of securities. Through personal discussions we help establish your investment goals,
objectives and risk tolerance. With this information, we create and manage your individualized
portfolio. We will regularly monitor your portfolio and adjust it as determined by the financial
markets, world events and your financial situation.
Types of Advisory Services available through our Subadvisory Relationships
When appropriate for your situation, we may select a third-party manager to act as a
subadvisor for your account. When we do so, we will select a manager whose style and talent
best fits your individual needs and objectives. Your agreement with us gives us the authority to
hire or fire these managers on your behalf. Once a subadvisor is selected, we will continue to
monitor their performance. Some of the investment management services we offer are in the
form of model portfolios provided by Advisory Alpha, LLC (CRD# 158282), which invest in a
variety of diversified allocations structured towards a wide range of investment goals.
Variable Annuity Services
The subadvisor manages a series of portfolios on a fee-based variable annuity platform. This
allows for larger tax deferrals, and it allows you to consolidate variable annuity gains under a
single contract. With access to more than 350 subaccounts, all portfolio models are
appropriately managed and diversified according to the stated investment objective. The
platform charges a monthly flat fee, subaccounts are subject to their internal expenses, and we
charge a management fee.
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Retirement Plan Services
In conjunction with the advisory services offered by the subadvisor our turnkey retirement plan
platform provides qualified retirement plan sponsors with a flexible, yet easy solution that
includes significant fiduciary protection and powerful investment selections. We generally
serve as a 3(38) Investment Fiduciary but may serve in a 3(21)-capacity depending on your
needs. The key difference between these two types of fiduciaries is whether you engage us as a
discretionary manager. As a 3(38) manager, you give us discretionary authority to manage your
plan’s assets. This means you shift your fiduciary responsibility to us for the selection of your
investments. If you hire us as a 3(21) advisor, we will make recommendations, but it is
ultimately up to you, as the plan sponsor, to decide whether and how to act. As a 3(21) advisor,
we will not have discretion to invest and reinvest your assets without your prior consent. Thus,
as a 3(21) advisor, we will share responsibility for the selection of investments.
The subadvisor provides five professionally managed portfolio models for plan participants. All
five portfolio models are fully diversified and actively managed to maximize potential returns
at each risk level. Plan participants are also given the option of constructing their own
investment portfolios using a selection of ETFs. The professionally managed portfolios are
available at no additional expense.
Financial Planning Services
Financial plans and financial planning may include but are not limited to: investment planning,
tax concerns, retirement planning, college planning, private placements, real estate transactions
and, for 401(k) plans, investment due diligence. These services are based on fixed, hourly, or
monthly fees and the final fee structure is documented in the planning agreement with our
clients.
Services Limited to Specific Types of Investments
We generally limit investment advice and/or money management to ETFs, mutual funds, and
market-linked certificate of deposits. However, we may use other securities (e.g. closed-end
mutual funds or variable annuities) to help diversify a portfolio when applicable.
Client-Tailored Services and Client-Imposed Restrictions
We offer the same suite of services to all of our clients. However, your specific financial goals
and their implementation depend on your Investment Policy Statement that outlines your
current situation (income, tax levels, and risk tolerance levels). This is used in conjunction with
gathered investment objective information to construct your plan and help select a portfolio that
matches your restrictions, needs, and targets.
You may impose restrictions on investing in certain securities or types of securities in
accordance with your values or beliefs. If you choose to impose restrictions on our portfolio
management, you should be aware that it could cause your account to underperform compared
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to similar portfolios that do not apply such restrictions. Accordingly, you may forego
opportunities for us to buy certain securities when it might otherwise be advantageous to do so,
or you may request us to sell securities for reasons when it might otherwise be disadvantageous
to do so.
Additionally, if your restrictions prevent us from properly servicing your account or require us
to deviate significantly from our standard suite of services, we reserve the right to end our
relationship with you.
Assets Under Management
Maner Wealth, LLC has assets under management as follows:
Discretionary Assets: Non-discretionary Assets:
Date
Calculated:
$ 299,490,655
$ 0
12/31/2025
Item 5: Fees and Compensation
Discretionary or AUM Fee Schedule
Total Assets Under Management
Annual Fee
All Assets Under Management
0.15% - 1.5%
We charge fees based on a percentage of your assets under management; however, we do
charge a minimum annual fee of at least $5,000.00. This fee arrangement applies to individual,
institutional, and retirement plan clients as well as subadvisory relationships. You are never
charged additional, separate fees outside of the total fee disclosed to you on your client
agreement to cover the fee sharing agreements associated with our subadvisory relationships.
The fees shared will not exceed any limit imposed by any regulatory agency.
Our fees are negotiable depending on your needs and complexity of your situation. In all cases,
the final fee schedule is outlined in the agreement that you sign. Generally, our fees are paid
monthly in arrears, and you may terminate your agreement with thirty (30) days’ written
notice. Some clients may be billed based on previous collection schedules, quarterly in arrears.
Because fees are charged in arrears, no refund policy is necessary. Fees associated with new
accounts are pro-rated based on the time invested. In addition, fees associated with cash-flows
(contributions and withdrawals) are pro-rated based on the timing of the cash flow. You may
terminate your accounts without penalty within five (5) business days of signing the client
agreement.
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Financial Planning, Fixed, Hourly, and Monthly Fee Schedule
Depending on the complexity of your situation and needs, the consultation fee is between $50
and $400 per hour for Hourly Financial Planning while Fixed Fee Financial Planning is
determined on a case-by-case basis ranging between $500 and $5,000.
Financial Planning provided on an ongoing basis will be charged a monthly fixed fee of either
$100 or $200 per month, in arrears. The fee will be determined upon engagement also
depending on the complexity of financial situation and needs during the month.
The fees are negotiable, and the final fee schedule will be outlined in the planning agreement
that you sign. Fees are typically paid in arrears upon completion; however, some Investment
Advisor Representatives may choose to require up to one-half of the fee (estimated hourly or
fixed) payable upon engagement with the balance generally being due upon delivery of the
financial plan or completion of the agreed upon services. You may terminate your agreement
without penalty within five (5) business days of signing the planning agreement.
Payment of Discretionary or AUM Fees
Advisory fees are generally withdrawn directly from your account with your written
authorization, including accounts established through a subadvisory arrangement. You may
remove this authorization for direct billing of fees at any time by notifying us or your custodian
in writing. Advisory fees may also be invoiced and billed directly to you on a monthly basis and
in arrears. You may select the billing method of your choice.
Payment of Financial Planning, Fixed & Hourly Fees
Financial Planning, Fixed, Hourly and Monthly fees may be paid via check or ACH upon
completion. In the event our services are terminated prior to completion, we will bill you based
on hours expended or the portion of the project already completed through the date of
termination.
Clients Are Responsible for Third Party Fees
You are responsible for the payment of all third-party fees (i.e., custodian fees, mutual fund
fees, transaction fees, etc.). Insurance products, such as annuities, may also have associated fees
and expenses. All third-party fees are separate and distinct from the fees and expenses that we
charge. Please see ITEM 12 of this brochure regarding brokerage practices.
ETFs and mutual funds typically charge their shareholders various transaction and operating
expense costs associated with the establishment and operation of the funds. These fees will
generally include a management fee, shareholder servicing, other fund expenses, and
sometimes a distribution fee.
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However, because of differences in distribution and often lower transaction costs, total
operating expense ratios for ETFs have been historically less than those for corresponding
mutual funds. These separate fees and expenses are disclosed in each fund’s prospectus, which
is available from the fund, or, we can provide it to you upon your request.
Consequently, for any type of fund investment, it is important for you to understand that you
are directly and indirectly paying two levels of advisory fees and expenses: you pay one layer of
fees to the fund and one layer of advisory fees and expenses to us. Generally speaking, most
funds may be purchased directly, without using our services or incurring our advisory fees.
Subadvisory Fees
When we use Advisory Alpha as a subadvisor, the fee we charge will include our advisory fee
and the advisory fee charged by Advisory Alpha. We do not retain any portion of their
subadvisory fee but pass it on to the subadvisor. Details of the Advisory Alpha’s fee, which is in
addition to our fee, will be disclosed to you in their disclosure brochure and related investment
advisory agreement. You should read both carefully and retain for your records.
Termination of Services
If you terminate your agreement with us, you must notify us in writing or transfer your assets
from the custodian. Similarly, if you work with a separate investment adviser and you
terminate that relationship, it will terminate our services as well. If we charge you in arrears, we
will bill your account for the portion of time that we managed your account or provided
services, and no refund of fee will be necessary.
Outside Compensation for the Sale of Securities to Clients
Our advisers may accept commissions associated with insurance-based products. This outside
compensation is independent of the products and services offered through our firm, will be
disclosed to you separately, and will be paid through other unaffiliated financial services firms
(e.g., a life insurance company or an insurance marketing organization).
Retirement Rollover Conflicts of Interest
When we recommend you rollover a retirement account for us to manage, this creates a financial
incentive because we charge a fee for our services. We attempt to mitigate the conflict of interest
by acting in your best interest and applying an impartial conduct standard to all rollovers. Please
note that you are not under any obligation to roll over a retirement account to an account managed
by us.
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Item 6: Performance-Based Fees and Side-By-Side Management
We do not accept performance-based fees or other fees based on a share of capital gains or
capital appreciation of your assets.
Item 7: Types of Clients
We generally provide investment advice and/or management supervisory services to the
following types of clients:
Individuals
High-Net-Worth Individuals
Defined Contribution & Defined Benefit Retirement Plans
Corporate and Institutional Investors
Minimum Account Size
There is no account minimum.
Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss
Methods of Analysis and Investment Strategies
We offer a variety of investment strategies designed for a wide range of investors with diverse
wealth management objectives. The typical structure of the portfolio offerings is a “fund of
funds” approach composed of ETFs and mutual fund holdings, but these strategies may also
include individual securities. On an ongoing basis, either we or our subadviser’s Investment
Team undertakes an extensive research process that re-evaluates the asset class selection, asset
allocation, holding selection, and portfolio rebalancing needs for each investment strategy.
Asset Class Selection – Properly defining and selecting the individual asset classes that are
consistent with the objectives of each strategy.
Asset Allocation – Implementing and adapting the asset class weightings as a result of each
strategy’s investment research and forecasting processes.
Holding Selection – Selecting, monitoring, and replacing the specific holdings based on a
disciplined process directed by the objective of each strategy.
Portfolio Rebalancing – Crafting and deploying an appropriate rebalancing approach based on
the intent of each strategy.
Modern Portfolio Theory - Modern Portfolio Theory proposes that investing in a predetermined
asset mix derived from the efficient frontier (dictated to achieve a specific client objective within
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a certain risk tolerance) and rebalancing with discipline, the portfolio is diversified across the
various asset classes to mitigate unnecessary risk. This also provides for a portfolio that can
operate without reliance on market timing and security selection; however, as with all equity
investments positive returns are not guaranteed. In conjunction to investing in a diversified
portfolio, each portfolio is constructed to meet specific parameters set forth in the individual
client’s investment policy statement and/or other documents. These parameters can include -
but are not limited to - tax efficiency, concentrated stock positions and management history.
Once again, the risk associated with a diversified portfolio is that each class has different levels
of risk and return, so each will behave differently over time and despite being diversified there
is no guarantee that an account will grow.
Risks Involved with Our Investment Strategies or Financial Planning Services
Market Risk – Many of the investments we utilize are largely influenced by the value of the
indices they track or the asset class they represent. As the index value or asset class changes in
response to news and general economic conditions of domestic, international, and
commodity/natural resource markets, in general, so will the value of the ETF or mutual fund.
This can result in a loss of your initial investment.
International Investment Risk - International investments may involve risk of capital loss from
unfavorable fluctuations in currency exchange rates, differences in generally accepted
accounting principles, or economic and political instability in other nations.
Emerging Markets Risk - Investments in emerging markets may be subject to a greater risk of loss
than investments in more developed markets. Emerging markets may be more likely to
experience inflation risk, political turmoil, and rapid changes in economic conditions than more
developed markets. Emerging markets often have less consistency in accounting and reporting
requirements, unreliable securities valuation, and greater risk associated with custody of
securities.
Income Risk - An ETF or mutual fund’s income may decline when interest rates fall. This decline
can occur because: (1) the ETF or mutual fund must invest in lower-yielding bonds as bonds in
its portfolio mature, (2) bonds in the underlying index are substituted, or (3) the ETF or mutual
fund otherwise needs to purchase additional bonds.
Interest-Rate Risk - Fluctuations in interest rates may cause investment prices to fluctuate. For
example, when interest rates rise, yields on existing bonds become less attractive, causing their
market values to decline.
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Liquidity Risk - Markets can also experience a decline in liquidity which can negatively impact
ETF, mutual fund, or market-linked certificate of deposit prices and increase the difficulty to
sell a position. The ability to purchase or sell large positions of these securities, due to possible
low trade volume, may take time.
Sector-Specific Risk - The value of investments that are concentrated in industry-specific sectors
have additional risks relative to broad market investments. These investments may decline due
to changes in the specific industry, such as government regulation or consumer trends.
Asset Class Allocation - The rise and fall of certain asset classes or their underlying securities or
commodities may not react according to predicted trends.
Active Management - This process concentrates on factors that are believed to lead to the quality
and future success of particular money managers. The risk assumed is that the manager will fail
to perform as expected.
Portfolio Rebalancing - Depending on the rebalancing strategy implemented, long-term or short-
term trading may be involved. Trading can affect investment performance, particularly through
increased brokerage and other transaction costs and taxes. Short-term trading generally holds
greater risk, and you should be aware that there is a material risk of loss using short-term
strategies.
Timing Risk - While it is likely that stocks will gain over the next two decades, this may not be
the case over the short-term. If you need to protect your principal investment over the short-
term, timing is an important risk to consider.
Political Risk - Government decisions may damage the value of your investments. Changes to
social security, benefits law, and tax law may impact your financial decisions. Any foreign
investments may be impacted by the decision of their local governments.
Foreign Risk – Foreign investments have additional risks relative to domestic investments. This
includes currency fluctuations, differences in accounting standards, different market exchanges,
potentially less liquidity, etc.
Tax Risks - Some of the products offered are subject to tax law that is complex and subject to
varying interpretations. Moreover, the effect of existing income tax laws and possible changes
in such laws will vary with the particular circumstances of each investor. Each prospective
investor should consult with and rely on his or her own tax professional with respect to the
possible tax consequences, including risks and advantages, of an investment.
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Real Estate Risks - Investments in real estate are subject to varying degrees of risk, including,
among other things, local conditions such as an oversupply of space or reduced demand for
properties, an inability to collect rent, vacancies, inflation and other increases in operating costs,
adverse changes in laws and regulations applicable to owners of real estate, and changing
market demographics.
Dilution Risks - Issuers of private placements may be required to raise additional capital. Future
issuance of additional securities could dilute the ownership stakes of issuer’s then-existing
owners; and there can be no assurance that the effects of such dilution will not be substantial.
Additionally, any new class units that might be issued in the future may negatively impact the
issuer’s then-existing owners.
Privately Held (Non publicly Traded) Investment Risks – Privately held companies typically hold
more risk to the investor than publicly traded companies as they do not fall under the same
regulatory requirements. As they are not publicly traded, an active market may not readily
exist, which means they lack liquidity. They also typically have substantial fees relative to other
types of investments. Additionally, investments in privately held companies or products have
differing tax ramifications which can be complex in nature.
Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.
Risks of Specific Securities Utilized in Our Strategies
Investing in securities such as ETFs, mutual funds, and structured products involves risk.
Seeking to obtain higher rates of return on investments typically entails accepting higher levels
of risk. We or your investment adviser will work with you to identify the balance of risk and
reward that is appropriate and comfortable for you. However, it is still your responsibility to
ask questions if you do not fully understand the risks associated with any investment or
investment strategy.
Also, while we strive to render our best judgment on your behalf, many economic and market
variables beyond our control can affect the performance of your investments and we cannot
ensure that your investments will be profitable, or no losses will occur in your investment
portfolio.
Past performance is one consideration with respect to any investment or investment adviser,
but it is not a predictor of future performance.
We will discuss with you the investment risks of ETFs and mutual funds to determine the
investment objectives that will guide your portfolio selection. We will explain and answer any
questions you have about these kinds of investments, which present special considerations.
ETFs are a type of security that derive their value from a basket of securities such as stocks,
bonds, commodities, or indices and are traded on exchanges during the day like individual
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stocks. Conversely, traditional mutual funds are priced once a day at the close of the market.
The value of your portfolio will fluctuate with the value of its underlying securities. ETFs trade
like a stock, and there may be brokerage commissions associated with buying and selling.
The investment options we offer primarily invest in passively managed funds which are
designed to seek the investment results that generally correspond to the price and yield of an
index; however, we may invest in actively managed ETFs and mutual funds. ETFs that are
actively managed do not just seek to passively track an index; instead, they seek to achieve a
specified investment objective using an active investment strategy.
Equity-based ETFs have a similar risk profile to those of equity mutual funds, while fixed
income-based ETFs have a risk profile that is similar to bond mutual funds. You should
anticipate that the value of an ETF’s shares will decline in correlation with any decline in the
value of its corresponding index. However, an ETF’s return may not match the return of the
index. Sometimes referred to as “tracking error,” expenses and other factors may affect the
performance of an ETF so that the ETF’s performance does not exactly match the performance
of their respective underlying indexes. The ETF may invest in small capitalization, mid-
capitalization, emerging markets, and international companies. These companies may
experience greater price volatility than larger, more established companies.
Exchange‐traded notes (ETNs) are issued as senior, unsecured, unsubordinated debt obligations
of an underlying bank or other financial institution. They are linked to the performance of an
index, underlying security, or commodity. ETNs trade on an exchange and are like ETFs in that
regard. However, unlike ETFs, ETNs carry credit risk related to the issuer’s ability to pay back
the note. While the performance of these securities is linked to the performance of an
underlying index, security, or commodity, an investor does not own any underlying assets
(which is the case with ETFs). It is, however, relying on the financial institution issuer’s promise
to make good on the terms of the ETN. This means that the market value of ETNs can be
adversely affected by downgrades in the creditworthiness to the underlying issuing financial
institution. In the extreme case that the issuer of the ETN goes bankrupt, you may lose your
entire investment because ETNs are unsecured debt instruments. In contrast, if an ETF were to
suffer bankruptcy or close, you would usually receive cash for the market value of the basket of
securities or, in the case of larger positions of $50,000 or more, you may request to take
distribution of the underlying securities.
Commodities may provide protection against inflation and/or the inability of fiat currencies to
maintain their store of real value. Commodities may provide imperfect correlations relative to
other asset classes and serve to increase diversification for risk-tolerant portfolios. It is also
important to understand that commodity ETFs can be significantly affected by commodity
prices, world events, import controls, worldwide competition, government regulations, and
economic conditions.
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Market-linked certificates of deposit are bank issued certificates of deposit that are linked to a
particular market index in an effort to generate an increased return probability. Market-linked
CDs are insured by the FDIC up to applicable limits. Unless otherwise specified, other products
purchased through Advisory Alpha, LLC are not insured by the FDIC. Market-linked CDs are
not suitable for all investors. Prospective investors should carefully review the relevant offering
documents prior to investing. A guaranteed secondary market does not exist for MLCDs;
issuing banks and other parties may be willing to repurchase them prior to maturity. In
determining the value for such a repurchase, the issuer will consider multiple factors such as:
performance of the underlying markets, credit risk, time to maturity, and interest rates. This
value appears in client accounts, represents an estimate of the current repurchase value, and
may be at a substantial discount to an investor’s original investment. Market-linked CDs are
long-term investments designed to be held to maturity, at which point the issuing bank is
obligated to provide a value consistent with the terms of the investment. Additionally, in the
event of the owner’s death, most market-linked CDs offer the right to redeem prior to maturity
at the original investment amount.
Variable annuities are tax-deferred investments structured to convert a sum of money into a
series of payments over time. Variable annuity policies have limitations and are not viewed as
short-term liquid investments. An insurance company's fulfillment of a commitment to pay a
minimum death benefit, a schedule of payments, a fixed investment account guaranteed by the
insurance company, or another form of guarantee depends on the claims-paying ability of the
issuing insurance company. Any such guarantee does not affect or apply to the investment
return or principal value of the separate account and its subaccount. The financial ratings
quoted for an insurance company do not apply to the separate account and its subaccount. The
insurance company offering a variable life contract will charge several fees to investors,
including annual contract charges that compensate the insurance company for the cost of
maintaining and administering the variable life contract, mortality and expense risk (M&E Risk)
charges based on a percentage of a subaccount’s assets to cover costs associated with mortality
and expense risk, and administration fees that are based on a percentage of a subaccount’s
assets to cover the costs involved in offering and administering the subaccount. A variable life
investor will also be charged a front-end load by the insurance company on their initial
contribution, ongoing fees related to the management of the fund, and surrender charges if the
investor makes a withdrawal prior to a specified time. If the variable annuity subaccount is
invested in a money market fund, the money market fund is not FDIC-insured, may lose
money, and is not guaranteed by a bank or other financial institution.
A 529 Portfolio is a specific portfolio of securities created from 529 plan’s available investments.
In general, the data presented for a 529 Portfolio uses a weighted average of the underlying
holdings in the portfolio. Most 529 plans are invested in exchange-traded funds or open-end
mutual funds; however, other investment types are possible such as stable value funds,
certificates of deposit, and separate accounts. Before investing, an investor should consider
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whether the investor's or designated beneficiary's home state offers any state tax or other state
benefits such as financial aid, scholarship funds, and protection from creditors that are only
available for investments in such state's 529 qualified tuition program.
1031 Exchanges are governed by the IRS tax code associated with the deferral of capital gains on
the sale of an investment property when subsequently purchasing a “like-kind” property that is
the same in nature and character. Substantial fees and expenses could be incurred and there are
strict timing limitations imposed on these transactions. For example, if the transaction is not
properly constructed and executed in a timely manner, all tax benefits associated with the
transaction may be lost while potentially incurring additional tax liability. As 1031 exchanges
are based on real estate investments for which there may be no readily available market, there is
liquidity risk to the investor. Additionally, the following real estate investment risks are
possible: no guarantee of cash distributions; operational risks associated with property
management and ownership to the investor; risk of the property being overleveraged; tax risks;
interest rate risks; economic risks; risks of terrorism; environmental risks; liability risks; zoning,
city ordinance, and or legal compliance risks; title and escrow risks; credit risks; and risks of
obsolescence.
A Real Estate Investment Trust (REIT) is a company or investment trust that retains diverse
portfolios of real estate assets. Typically, these portfolios are sector-specific and include real
estate investments related to: Residential, Commercial, Healthcare, Office, and Industrial
property options. The risks involved with investing in REITs include the potential for excessive
fees, lack of liquidity, lack of share value transparency, distributions that may come from the
principal investment, and conflicts of interest related to REITs not having employees and
paying external managers high transaction fees/bonuses. It is important for investors to review
all offering materials in addition to discussing these products with their financial advisor in
order to have a strong understanding of exactly what they are agreeing to in order to mitigate
these risks.
A Private Placement is an offering of unregistered securities to a limited pool of investors.
Private placements are regulated by a series of U.S. Securities and Exchange Commission rules
under Regulation D and can issue varying amounts of securities based on the type of investor
they are selling them to (either accredited or non-accredited investors) without registering those
securities with the SEC. When non-accredited investors are involved, issuers of private
placements must disclose key information, such as financial statements, in addition to the
offering documents provided. Investors should review these documents carefully to understand
the risks, which could include, but are not limited to, a lack of liquidity, high transaction costs,
and potential tax ramifications. Private placements are generally considered riskier investments
and could expose the investor to the potential of full loss of principal.
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Item 9: Disciplinary Information
In this section of our brochure, we must inform you of all material facts regarding any legal or
disciplinary events that are material to your evaluation of our firm or the integrity of our
management. We have no criminal or civil actions or administrative proceedings before any
regulatory agency, or self-regulatory organization events to disclose.
Item 10: Other Financial Industry Activities and Affiliations
Licensed Insurance Agents
Various investment adviser representatives of our firm are also licensed insurance agents. From
time to time, they can offer clients advice or products from those activities. You should be
aware that these services pay a commission and involve a conflict of interest, as commissionable
products can conflict with the fiduciary duties of a registered investment adviser. We seek to
lessen this conflict of interest by disclosing any commissions in advance.
Tax Preparation
Some investment advisor representatives or owners of our firm are also tax consultants,
certified public accountants, or retain ownership in a tax services business. From time to time,
they will offer clients services and advice relative to those activities. You should be aware that
these services can incur a fee separate and distinct from those related to the services provided
through Maner Wealth, LLC. As such, a conflict of interest could arise should a client utilize
these outside services alongside the investment advisory services offered through Maner
Wealth, LLC. We seek to lessen this potential conflict of interest by disclosing any fees in
advance.
1031 Qualified Intermediary Services
Members of firm ownership also retain ownership in a 1031 qualified intermediary services
business, AZM Investments, Inc., which facilitates Internal Revenue Code section 1031 tax-
deferred exchanges. You should be aware that with ownership in the qualified intermediary
services firm they will also retain or share all or a portion of the interest income earned on tax-
deferred exchange funds that are on deposit or held by the qualified intermediary and may also
charge various other fees relative to this service which are separate and distinct from any
services provided or fees charged by Maner Wealth, LLC. This represents a conflict of interest
should you need 1031 qualified intermediary services as your investment adviser may collect
additional fees by offering this service through AZM Investments, Inc. We seek to mitigate any
negative impact of this conflict by disclosing any fees charged for this service in advance.
Private Capital Firms
Members of firm ownership also retain partial ownership in outside private capital firms whose
business involves investing its assets in entrepreneurial activities and startup companies under
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the names Altruis Capital, LLC and Altruis Capital II, LLC. While these businesses operate
completely independently from Maner Wealth, LLC and the chances of your involvement with
them is unlikely, we want to ensure full transparency with you by disclosing that in our
ownership’s participation in these private capital firms, additional income and compensation
could be generated to them based on any success or profitability of the activities or businesses
those companies participate in. This creates a conflict of interest should any of those underlying
business ventures or activities be related to you or other clients. In an effort to mitigate this
conflict, should you ever be a participant in these activities, any fees, income, or expenses paid
to our ownership through these companies based on those activities will be disclosed to you in
advance of your participation.
Selection of Other Advisers or Managers and How We are Compensated for Those Selections
Occasionally, we select additional advisers or managers to serve as subadvisors for specific
clients. Please refer to ITEM 4: ADVISORY BUSINESS and ITEM 5: FEES AND
COMPENSATION for additional information on our use of third-party money managers.
Item 11: Code of Ethics, Participation or Interest in Client Transactions, and Personal
Trading
Code of Ethics
We have a written Code of Ethics that covers the following areas: Prohibited Purchases and
Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited
Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of
Directors, Outside Business Activities, Compliance Procedures, Compliance with Laws and
Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations,
Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and
Sanctions. Our Code of Ethics is available, free upon request, to you.
Participation or Interest in Client Transactions
We do not recommend that you buy or sell any security in which our company or one of our
related persons has a material financial interest.
Investing Personal Money in the Same Securities as Clients
From time to time, our advisers may buy or sell securities for themselves that they also
recommend to clients. This may provide an opportunity for our advisers to buy or sell the same
securities before or after recommending the same securities to you, resulting in our advisers
profiting from the recommendations, they provide to you. These transactions may create a
conflict of interest. We will always document any transactions that could be construed as
conflicts of interest, and our advisers will always transact your business before their own when
similar securities are being bought or sold. We often group all similar trade orders together into
block orders prior to execution. This may offer pricing advantages relative to trading each
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account individually. In these situations, trade orders for our advisers’ personal accounts may
be included and executed at the same share prices given to clients.
Item 12: Brokerage Practices
When you engage us for our portfolio management services, we generally require that you
establish an account at Charles Schwab & Co., Inc. (“Schwab”) to use their custody, brokerage,
and clearing services. As an SEC registered broker-dealer and member of FINRA/SIPC, Schwab
is a qualified custodian to hold your assets and execute transactions upon our instructions.
While we are not affiliated with them, the majority of our direct clients’ accounts are held there.
We ask that you give us a written direction in our Agreement to use them as your custodian.
Additionally, while we recommend that you use Schwab as your custodian/broker, you will
decide whether to do so and you will open your account with them by entering into a separate
account agreement directly with them. We do not open the account for you, although we may
assist you with the paperwork in doing so. Even though your account is maintained with them,
we will have discretion to use them or other brokers to execute trades for your account as
described below.
Factors Used to Select Custodians and/or Broker-Dealers
We seek to use a broker who will hold your assets and execute transactions on terms that,
overall, are most beneficial when compared to other available service providers. We consider a
wide range of factors, including, but not limited to:
Combination of transaction execution 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, etc.).
Availability of investment research and tools that assist us in making investment
decisions. These include recent news, graphs, charts, historical earnings data, balance
sheet data, estimates of future earnings, and other information.
Quality of services, including additional reports that include gains and losses (both
realized and unrealized).
Competitiveness of the price of services (commission rates, margin interest rates, other
fees, etc.) and willingness to negotiate the prices. We believe TD Ameritrade’s brokerage
services are competitive with comparable firms for comparable services.
Reputation, financial strength, and stability.
Prior service to us and our other clients.
Availability of other products and services that benefit us, as discussed below (see
“Products and Services Available to Us”).
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Your Brokerage and Custody Costs
For our direct clients who have accounts at Schwab, they do not charge you separately for
custody services but are paid by charging you commissions or other fees on trades that they
execute or that settle into your account. We negotiated our commission rates with them on
behalf of all our clients and not with respect to any specific client. While these commission rates
may be higher than available from other discount and online brokers, we believe that the
additional services and investment reports provided are of more value to us and our clients
than with the lower-priced alternatives that provide fewer services. Therefore, we have Schwab
execute most individual securities trades for your account to minimize your trading costs. We
also use Schwab for most ETF and mutual fund transactions because they provide a wide array
of no-load or institutional class mutual fund shares with no transaction costs to our clients.
Generally, 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 in the section titled,
“Factors Used to Select Custodians and/or Broker-Dealers.”
In certain situations, the use of margin access through your respective Broker-Custodian may be
approved by us. In these cases, additional fees and interest on margin account balances may
apply. These fees and interest costs are separate and independent from any fees charged by or
paid to Maner Wealth. We receive no additional direct compensation as a result of any client’s
use of margin access at their Broker-Custodian. There are risks involved with utilizing margin
access including a potential drop in the underlying security value which will force the client to
deposit additional cash or securities to cover the maintenance margin call issued by the broker-
custodian. A brokerage firm has the right to increase the minimum amount required in a
margin account, sell your securities without notice, or sue you if a margin call is not fulfilled.
The use of margin is most suitable for sophisticated investors with a thorough understanding of
the risks and requirements involved.
Clients Directing Which Broker-Dealer/Custodian to Use
Directing us to use a specific brokerage firm could, in some transactions, result in higher
commissions and charges where we might otherwise go directly to a market maker in the
security. However, limiting the number of brokerage firms we regularly work with leads to
efficiencies that help us keep our advisory fees lower.
Products and Services Available to Us
We generally receive benefits of investment research and related services because our clients
use Schwab for their brokerage transactions and custodial services. All of these services are
research and client account-related and provided by Schwab on an unsolicited basis. The
research services made available may be used to benefit all clients’ accounts, as well as our
personal and proprietary accounts, which are not tied to a specific account’s brokerage activity
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or commission level achieved. We also do not receive referrals from brokerage firms in
exchange for recommending their services to our clients.
We have not and do not intend to enter into any contractual third-party soft-dollar
arrangements; for example, where we commit to place a specific level of brokerage commissions
with a specific firm and in return the brokerage firm pays for various research-related products
or services for us that are generally available for cash purchase.
Aggregating (Block) Trading for Multiple Client Accounts
We, or the selected sub-adviser, may aggregate orders for securities transactions for more than
one client based on our trade aggregation and allocation policy. In doing so, this process strives
to treat you fairly and will not favor one client or proprietary account over another client. When
executed, the aggregated orders will be allocated in accordance with policies and procedures
intended to achieve fair treatment. The purpose of aggregating orders is to obtain the same
price for each client in any given security, obtain better execution for the aggregated order than
might be achieved by processing each of the transactions separately, expedite the placement
and processing of trade orders, as well as for our administrative convenience.
Trade orders will not be aggregated for a client having a directed brokerage relationship with a
client who does not have a directed brokerage relationship with the same broker-dealer. A
consequence of not aggregating a client’s order with other orders for the same securities is that
the client may not obtain as good a price or as low a cost in a separate transaction as clients
whose orders have been aggregated.
Each account that participates in an aggregated order will receive the average share price for all
transactions in that security each business day. If permitted by the broker-dealer affecting the
transaction, transaction costs will be shared on a pro rata basis. Some broker-dealers charge
brokerage commissions to each participating client in accordance with the size of that client’s
part of the aggregated order, regardless of the total size of the aggregated order. If an
aggregated order is not filled in its entirety, it will be allocated among participating accounts on
a pro rata basis.
Trade Error Policy
We have the responsibility to process orders correctly, promptly, and in your best interest. We
have established an error correction policy to identify and correct any errors as promptly as
possible without disadvantaging you or benefiting us in any way. We have defined a “trade
error” as when we have purchased or sold a financial instrument for a client account and that
action is determined to have been a mistake and the error results in a financial gain or loss for
the client. Examples of errors may include:
Purchases or sales of an incorrect or unintended security or number of securities for
your account
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Purchases or sales of a security for the incorrect or unintended account
Purchases or sales of a security that you did not authorize or that are inconsistent with
applicable law or regulations (e.g., prohibited transaction under ERISA)
Purchase or sale transpositions (where an intended purchase is entered as a sale, or vice
versa)
Trade misallocations
If the error is our responsibility, the transaction will be corrected, and we will reimburse you for
any loss resulting from an inaccurate or erroneous order.
If there is a loss due to a trade error that we make, we will correct the mistake at our cost and
the error will not be reflected in a loss to your account. If a trade error results in a gain, the gain
will be retained by Schwab and given to charitable causes.
Item 13: Review of Accounts
Frequency and Nature of Periodic Reviews and Who Makes Those Reviews
We, or the selected sub-adviser, will review and may rebalance each account to ensure that the
allocation does not drift substantially from the model allocation. Our representatives review
your accounts at least annually. These individuals are the chief advisors and are instructed to
review your investments based on your investment policies and risk tolerance levels. All our
clients are assigned to these reviewers. All financial planning accounts are reviewed upon
financial plan creation and plan delivery by the investment adviser representatives of the firm.
Factors That Will Trigger a Non-Periodic Review of Client Accounts
Reviews may be triggered by material market, economic, or political events, or, when requested
by you, due to changes in your financial situation (such as retirement, termination of
employment, physical move, or inheritance).
Content and Frequency of Regular Reports Provided to Clients
Discretionary or AUM Services - You will receive at least quarterly reports from the custodian.
This is a written report that details your account including transactions, fees and commissions,
assets held, and asset value.
Financial Planning, Fixed, & Hourly Services - You are provided with a one-time investment or
financial plan concerning your financial situation. After the presentation of the plan, there are
no further reports. You may request additional plans or reports for a fee.
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Item 14: Client Referrals and Other Compensation
Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales
Awards or Other Prizes)
As outlined in Item 12, we receive some economic benefits from Schwab. However, we do not
receive any other economic benefit, directly or indirectly, from any third party for advice
rendered to our clients.
Compensation to Non – Advisory Personnel for Client Referrals
We do not have arrangements to compensate other non-advisory persons to make solicitations
on our behalf.
Item 15: Custody
Custody, as it applies to investment advisors, has been defined by regulators as having access
or control over client funds and/or securities. In other words, custody is not limited to
physically holding client funds and securities. If an investment adviser has the ability to access
or control client funds or securities, the investment adviser is deemed to have custody and must
ensure proper procedures are implemented.
We are deemed to have custody of client funds and securities whenever we are given the
authority to have fees deducted directly from client accounts. However, this is the only form of
custody we will ever maintain. It should be noted that authorization to trade in client accounts
is not deemed by regulators to be custody.
For accounts in which we are deemed to have custody, we have established procedures to
ensure all client funds and securities are held at a qualified custodian in a separate account for
each client under that client’s name. Clients, or an independent representative of the client, will
direct, in writing, the establishment of all accounts and therefore are aware of the qualified
custodian’s name, address, and the manner in which the funds or securities are maintained.
Finally, account statements are delivered directly from the qualified custodian 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 against reports received from us. When
clients have questions about their account statements, they should contact us or the qualified
custodian preparing the statement.
Item 16: Investment Discretion
When providing asset management services, we maintain trading authorization over your
account and can provide management services on a discretionary basis. When discretionary
authority is granted, we will have the authority to determine the type of securities and the
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amount of securities that can be bought or sold for your portfolio without obtaining your
consent for each transaction.
You may also grant us discretionary authority to establish and/or terminate a relationship with
a subadviser for purposes of managing the account or a portion of the account. In this situation,
you will grant the subadviser selected by us with the discretionary authority (in the sole
discretion of the subadviser without first consulting with you) to make all decisions to buy, sell,
or hold securities, cash, or other investments for such portion of the account managed by the
subadviser.
If your account is managed on a discretionary basis, discretionary authority is granted in
writing from you at the beginning of our advisory relationship in the agreement you sign. Also,
you will sign an agreement with your custodian which generally includes a limited power of
attorney granting the necessary authority to direct and implement the investment and
reinvestment of the assets in your account but restricts our ability or the subadviser’s ability (if
applicable) to direct the assets outside of your account.
We generally do not have discretionary authority to determine the broker, dealer, or the
commission rates paid for your transactions. You will have the ability to place reasonable
restrictions on the types of investments that may be purchased in your account. You may also
place reasonable limitations on the discretionary power granted to us so long as the limitations
are specifically set forth or included as an attachment to the client agreement.
If you decide to grant trading authorization on a non-discretionary basis, we will be required to
contact you prior to implementing changes in your account. Therefore, you will be contacted
and required to accept or reject our investment recommendations including:
The security being recommended
The number of shares or units
Whether to buy or sell
Once the above factors are agreed upon, we will be responsible for making decisions regarding
the timing of buying or selling an investment and the price at which the investment is bought or
sold. If your accounts are managed on a non-discretionary basis, you need to know that if we
are not able to reach you or you are slow to respond to our request, it can have an adverse
impact on the timing of trade implementations, and we may not achieve the optimal trading
price.
Item 17: Voting Client Securities
We do not vote proxies. However, your custodian will forward the proxy voting materials
directly to you. We recommend that you direct all proxy questions to the issuer of the security.
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Item 18: Financial Information
We are required to provide you with certain financial information or disclosures about our
financial condition if we have financial commitments that impair our ability to meet contractual
and fiduciary commitments to our clients. We have not been the subject of a bankruptcy
proceeding and do not have any financial commitments that would impair our ability to meet
any contractual or fiduciary commitments to you. Additionally, as part of these required
disclosures please note that we do not charge more than $1200 in fees per client, six months or
more in advance.
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