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Marble Wealth LLC
Form ADV Part 2A – Disclosure Brochure
Effective: April 6, 2026
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of Marble Wealth LLC (“Marble Wealth” or the “Advisor”). If you have any questions about the content
of this Disclosure Brochure, please contact the Advisor at (334) 679-4800.
Marble Wealth is a registered investment advisor with U.S. Securities and Exchange Commission (“SEC”). The
information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities
authority. Registration of an investment advisor does not imply any specific level of skill or training. This
Disclosure Brochure provides information about Marble Wealth to assist you in determining whether to retain the
Advisor.
Additional information about Marble Wealth and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 335291.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory
Persons of Marble Wealth. For convenience, the Advisor has combined these documents into a single disclosure
document.
Marble Wealth believes that communication and transparency are the foundation of its relationship with clients
and will continually strive to provide you with complete and accurate information at all times. Marble Wealth
encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you
may have with the Advisor.
Material Changes
The following material changes have been made to this Disclosure Brochure since the initial filing on March 31,
2025:
• The Advisor now offers digital asset management through Fidelity Digital Asset Services, LLC. Please
see Items 4, 8, and 12 for more information.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in our business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete
Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material
change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 335291. You
may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (334) 679-4800.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 2
Item 3 – Table of Contents
Item 1 – Cover Page ............................................................................................................................................... 1
Item 2 – Material Changes ..................................................................................................................................... 2
Item 3 – Table of Contents .................................................................................................................................... 3
Item 4 – Advisory Services ................................................................................................................................... 4
A. Firm Information ............................................................................................................................................................. 4
B. Advisory Services Offered .............................................................................................................................................. 4
C. Client Account Management .......................................................................................................................................... 6
D. Wrap Fee Programs ....................................................................................................................................................... 6
E. Assets Under Management ............................................................................................................................................ 6
Item 5 – Fees and Compensation ......................................................................................................................... 7
A. Fees for Advisory Services ............................................................................................................................................. 7
B. Fee Billing ....................................................................................................................................................................... 8
C. Other Fees and Expenses ............................................................................................................................................. 8
D. Advance Payment of Fees and Termination .................................................................................................................. 8
E. Compensation for Sales of Securities ............................................................................................................................ 9
Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 9
Item 7 – Types of Clients ..................................................................................................................................... 10
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 10
A. Methods of Analysis ..................................................................................................................................................... 10
B. Risk of Loss .................................................................................................................................................................. 10
Item 9 – Disciplinary Information ....................................................................................................................... 12
Item 10 – Other Financial Industry Activities and Affiliations ......................................................................... 12
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 12
A. Code of Ethics .............................................................................................................................................................. 12
B. Personal Trading with Material Interest ........................................................................................................................ 12
C. Personal Trading in Same Securities as Clients .......................................................................................................... 13
D. Personal Trading at Same Time as Client ................................................................................................................... 13
Item 12 – Brokerage Practices ............................................................................................................................ 13
A. Recommendation of Custodian[s] ................................................................................................................................ 13
B. Aggregating and Allocating Trades .............................................................................................................................. 14
Item 13 – Review of Accounts ............................................................................................................................ 14
A. Frequency of Reviews .................................................................................................................................................. 14
B. Causes for Reviews ..................................................................................................................................................... 14
C. Review Reports ............................................................................................................................................................ 15
Item 14 – Client Referrals and Other Compensation ........................................................................................ 15
A. Compensation Received by Marble Wealth ................................................................................................................. 15
B. Client Referrals from Solicitors ..................................................................................................................................... 15
Item 15 – Custody ................................................................................................................................................ 15
Item 16 – Investment Discretion ......................................................................................................................... 16
Item 17 – Voting Client Securities ...................................................................................................................... 16
Item 18 – Financial Information .......................................................................................................................... 16
Form ADV 2B – Brochure Supplements ........................................................................................................... 16
Privacy Policy ...................................................................................................................................................... 29
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 3
Item 4 – Advisory Services
A. Firm Information
Marble Wealth LLC (“Marble Wealth” or the “Advisor”) is a registered investment advisor with the U.S. Securities
and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the
laws of the State of Alabama. Marble Wealth was orgainized in June 2022 and became a registered investment
advisor in April 2025. Marble Wealth is owned by Matthew B. Murphy, CFP® (Partner, Chief Executive Officer),
Rebecca H. Baker, CFP®, CPA, CEPA® (Partner, Chief Operating Officer), and Adam M. Rogers, CFA® (Partner,
Chief Investment Officer), and operated by the same parties and Emily L. Farrior, Director of Operations and
Chief Compliance Officer.
This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by Marble Wealth. For information regarding this Disclosure Brochure, please contact Lauren
Farrior (Chief Compliance Officer) at (334) 679-4800.
B. Advisory Services Offered
Marble Wealth offers advisory services to individuals, high net worth individuals, families, trusts, estates,
businesses, charitable organizations, and retirement plans (each referred to as a “Client”). The Advisor provides
financial planning services and investment management services. These services are typically offered as a
combined wealth management engagement.
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness, and good faith towards each Client and seeks to mitigate conflicts
of interest. Marble Wealth’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more
information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
Wealth Management Services
Marble Wealth provides customized wealth management solutions for its Clients. This is achieved through
continuous personal Client contact and interaction while providing discretionary management and related
financial planning services. Marble Wealth works closely with each Client to identify their investment goals and
objectives as well as risk tolerance and financial situation in order to design a portfolio strategy.
Marble Wealth typically construct an investment portfolio utilizing exchange-traded funds (“ETFs”) and individual
stocks. The Advisor may also allocate to unaffiliated money managers (See “Independent Managers” below),
and/or other types of investments, as appropriate, to meet the needs of the Client. The Advisor may retain certain
legacy investments based on portfolio fit and/or tax considerations.
Marble Wealth will select, recommend and/or retain mutual funds on a fund by fund basis. Due to specific
custodial and/or mutual fund company constraints, material tax consideration, and/or systematic investment
plans, Marble Wealth will select, recommend and/or retain a mutual fund share classes that do not have trading
costs when possible. These will in most cases be institutional share classes but in some cases may be share
classes with higher internal expense ratios than institutional share classes. Marble Wealth will seek to select the
lowest cost share class available that is in the best interest of each Client weighing the expected investment
pattern, expense ratios and potential ticket charges, and will ensure the selection aligns with the Client’s financial
objectives and stated investment guidelines.
Marble Wealth’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. Marble Wealth will construct, implement, and monitor the portfolio to ensure it meets the goals,
objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to
place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to
acceptance by the Advisor.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 4
Marble Wealth evaluates and selects investments for inclusion in Client portfolios only after applying its internal
due diligence process. Marble Wealth may recommend, on occasion, redistributing investment allocations to
diversify the portfolio. Marble Wealth may recommend specific positions to increase sector or asset class
weightings. The Advisor may recommend employing cash positions as a possible hedge against the market
movement. Marble Wealth may recommend selling positions for reasons that include, but are not limited to,
harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities,
overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating
cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
Digital Assets – The Advisor may assist interested Clients with establishing a digital currency account through
Fidelity Digital Asset Services, LLC (“FDAS”). FDAS is a platform for Digital Assets which the Advisor offers as a
possible portfolio management diversification strategy for Clients that express an interest in exposure to digital
assets. “Digital Asset” shall mean a digital asset (also called a “cryptocurrency,” “virtual currency,” “digital currency,”
or “digital commodity”), such as bitcoin, which is based on the cryptographic protocol of a computer network that
may be (i) centralized or decentralized, (ii) closed or open-source, and (iii) used as a medium of exchange and/or
store of value. Clients will establish a Digital Asset account and transfer funds into an account opened on the FDAS
platform.
Use of Independent Managers – Marble Wealth may recommend that Clients utilize one or more unaffiliated
investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a
Client’s investment portfolio, based on the Client’s needs and objectives. In certain instances, the Client may be
required to authorize and enter into a wealth management agreement with the Independent Manager[s] that
defines the terms in which the Independent Manager[s] will provide its services. The Advisor will perform initial
and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned
with Clients investment objectives and overall best interests. The Advisor will also assist the Client in the
development of the initial policy recommendations and managing the ongoing Client relationship. The Client,
prior to entering into an agreement with an Independent Manager, will be provided with the Independent
Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures).
Financial Planning Services
Marble Wealth will typically provide a variety of financial planning and consulting services to Clients as part of a
wealth management engagement. Services are offered in several areas of a Client’s financial situation,
depending on their goals and objectives. Generally, such financial planning services involve preparing a formal
financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives.
This planning or consulting may encompass one or more areas of need, including but not limited to, investment
planning, retirement planning, personal savings, education savings, insurance needs, and other areas of a
Client’s financial situation.
A financial plan developed for or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs. Marble Wealth may also refer
Clients to an accountant, attorney, or other specialists, as appropriate for their unique situation. For certain
financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation,
observations, and recommendations. For project-based or ad-hoc engagements, the Advisor may not provide a
written summary. Project-based financial plans or consultations are typically completed within six (6) months of
contract date, assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor
for wealth management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects
to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 5
Retirement Plan Advisory Services
Marble Wealth provides 3(21) retirement plan advisory services on behalf of the retirement plans (each a “Plan”)
and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist
the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants.
Each engagement is customized to the needs of the Plan and Plan Sponsor.
Services generally include:
Investment Policy Statement (“IPS”) Design and Monitoring
Investment Oversight
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
•
•
• Ongoing Investment Recommendation and Assistance
These services are provided by Marble Wealth serving in the capacity as a fiduciary under the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2),
the Plan Sponsor is provided with a written description of Marble Wealth’s fiduciary status, the specific services
to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging Marble Wealth to provide advisory services, each Client is required to enter into a written
advisory agreement with the Advisor that define the terms, conditions, authority, and responsibilities of the
Advisor and the Client. These services may include:
• Establishing an Investment Strategy – Marble Wealth, in connection with the Client, will develop a
strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Marble Wealth will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation, and tolerance for risk for each Client or unique
client goal.
• Portfolio Construction – Marble Wealth will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
• Wealth Management and Supervision – Marble Wealth will provide wealth management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Marble Wealth includes, in addition to transaction costs, custodial costs, other fees and expenses (herein
“Covered Costs together with its investment advisory fees. Including these fees into a single asset-based fee is
considered a “Wrap Fee Program”. The Advisor customizes its investment management services for its Clients.
The Advisor sponsors the Marble Wealth Wrap Fee Program solely as a supplemental disclosure regarding the
combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the
Client may pay more or less in total fees than if the Client paid its own transaction fees. Please see Appendix 1 –
Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure.
E. Assets Under Management
As of December 31, 2025, Marble Wealth manages $1,045,227,948 in Client assets, $913,221,243 of which are
managed on a discretionary basis and $132,006,705 of which are managed on a non-discretionary basis. Clients
may request more current information at any time by contacting the Advisor.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 6
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written
wealth management agreement with the Advisor.
A. Fees for Advisory Services
Wealth Management Services
Wealth management fees are paid monthly, in advance of each monthly billing period, pursuant to the terms of the
wealth management agreement. Wealth management fees are based on average market value of assets under
management during prior month. Wealth management fees range from 0.35% to 1.00% annually. The fee in the
first month of service is prorated from the inception and asset funding of the account[s] to the end of the first month
based on the number of days in the period and the timing of asset transfers into the account[s].Fees may be
negotiable at the sole discretion of the Advisor. In certain circumstances, the Advisor may charge a fixed annual fee
for its services. The Client’s fees will take into consideration the aggregate assets under management with the
Advisor across all accounts to achieve the lower breakpoint above, unless otherwise agreed in writing. All securities
held in accounts managed by Marble Wealth will be independently valued by the Custodian. Marble Wealth will not
have the authority or responsibility to value portfolio securities. The Advisor will conduct periodic reviews of the
Custodian’s valuation to ensure accurate billing.
Cash Management Accounts – Account[s] that are invested solely in cash or cash equivalents will be charged at
an annual rate of 0.15% and billed as stated above. If an account becomes invested in other investments the full
wealth management rate above shall apply.
Clients may make additions to and withdrawals from their account[s] at any time, subject to Marble Wealth’s right to
terminate an account. Additions may be in cash or securities provided that Marble Wealth reserves the right to
liquidate any transferred securities or decline to accept particular securities into a Client’s account[s]. Clients may
withdraw account assets on notice to Marble Wealth, subject to the usual and customary securities settlement
procedures. However, Marble Wealth designs its portfolios as long-term investments, and the withdrawal of assets
may impair the achievement of a Client’s investment objectives. Marble Wealth may consult with its Clients about
the options and ramifications of transferring securities. However, Clients are advised that when transferred
securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (i.e.
contingent deferred sales charge) and/or tax ramifications.
Use of Independent Managers
As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio utilizing one or more
Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an
Independent Manager. The Advisor will only earn its wealth management fee as described above. Independent
Managers typically do not offer any fee discounts but may have a breakpoint schedule which will reduce the fee
with an increased level of assets placed under management with an Independent Manager. The Advisor will
allocate a portion of the advisory fee collected to the Independent Manager pursuant to the terms of the executed
agreement between the Advisor and the Independent Manager. If the Client is required to authorize and enter into
a wealth management agreement with an Independent Manage then the terms of such fee arrangements are
included in the Independent Manager’s disclosure brochure and applicable contract[s] with the Independent
Manager. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will not exceed
2.00% annually.
Retirement Plan Advisory Services
Fees for retirement plan advisory services are charged an annual asset-based fee of up to 0.50% and are billed in
advance or arrears, pursuant to the terms of the retirement plan advisory agreement. Certain Plans may be
charged a negotiated fixed fee. Retirement plan fees are based on the market value of assets under management
in the Plan. Fees may be negotiable depending on the size and complexity of the Plan.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 7
B. Fee Billing
Wealth Management Services
Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at
the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted
from the Client’s account[s] at the start of the respective monthly billing period. The amount due is calculated by
applying the daily rate (annual rate divided by the number of days in the year times the number of days in the
monthly billing period) to the average assets under management with the Advisor during the prior month. Clients will
be provided with a statement, generally monthly, from the Custodian reflecting the deduction of the management
fee. Clients provide written authorization permitting wealth management fees to be deducted by Marble Wealth to
be paid directly from their account[s] held by the Custodian as part of the wealth management agreement and
separate account forms provided by the Custodian.
Use of Independent Managers
For Client accounts implemented through an Independent Manager, the Client’s overall fees may include Marble
Wealth’s management fee (as noted above) plus management fees and/or platform fees charged by the
Independent Manager[s], as applicable. In certain instances, the Independent Manager or the Advisor may
assume responsibility for calculating the Client’s fees and deduct all fees from the Client’s account[s].
Retirement Plan Advisory Services
Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the
Plan, depending on the terms of the retirement plan advisory agreement. Fees are billable on either a monthly or
quarterly basis, pursuant to the terms of the retirement plan advisory agreement.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties in connection with investments made on behalf
of the Client’s account[s]. Marble Wealth includes Covered Costs as part of its overall investment advisory fee
through the Marble Wealth Wrap Fee Program. Please see Item 4.D. above as well as Appendix 1 – Wrap Fee
Program Brochure.
In addition, all fees paid to Marble Wealth for wealth management services are separate and distinct from the
expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are
described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees
for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and
a possible distribution fee. A Client may be able to invest in these products directly, without the services of
Marble Wealth but would not receive the services provided by Marble Wealth which are designed, among other
things, to assist the Client in determining which products or services are most appropriate for each Client’s
financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and
the fees charged by Marble Wealth to fully understand the total fees to be paid. Please refer to Item 12 –
Brokerage Practices for additional information. Additionally, as noted above, the Advisor will select share classes
that do not have trading costs when possible. These will in most cases be institutional share classes but in some
cases may be share classes with higher internal expense ratios than institutional share classes. Please refer to
Item 12 – Brokerage Practices for additional information.
D. Advance Payment of Fees and Termination
Wealth Management Services
Marble Wealth is compensated for its wealth management services in advance of the month in which services are
rendered. Either party may terminate the wealth management agreement, at any time, by providing advance written
notice to the other party. The Client may also terminate the agreement within five (5) business days of signing the
Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide
advisory services rendered to the point of termination, and such fees will be due and payable by the Client. Upon
termination, the Advisor will refund any unearned, prepaid fees from the effective date of termination through the
end of the month. The Client’s agreement with the Advisor is non-transferable without the Client’s prior consent.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 8
Use of Independent Managers
In the event that the Advisor has determined that an Independent Manager is no longer in the Client’s best interest
or a Client should wish to terminate their relationship with the Independent Manager, the terms for the termination
will be set forth in the respective agreements between the Client or the Advisor and the Independent Manager.
Marble Wealth will assist the Client with the termination and transition as appropriate.
Retirement Plan Advisory Services
Marble Wealth is compensated for its services at the either at the beginning or the end of the billing period. Either
party may request to terminate a retirement plan advisory agreement, at any time, by providing advance written
notice to the other party. The Client shall be responsible for retirement plan advisory fees up to and including the
effective date of termination. If collected in advance, the Advisor will refund any unearned, prepaid advisory fees
from the effective date of termination to the end of the billing period. The Client’s retirement plan services
agreement with the Advisor is non-transferable without the Client’s prior consent.
E. Compensation for Sales of Securities
Marble Wealth does not buy or sell securities to earn commissions and does not receive any compensation for
securities transactions in any Client account, other than the wealth management fees noted above.
Broker Dealer Affiliation
Certain Advisory Persons are also Registered Representatives of Sanctuary Securities, Inc. (“Sanctuary”).
Sanctuary is a registered broker-dealer (CRD# 205), member FINRA, SIPC. In one’s separate capacity as a
Registered Representative, the Advisory Person will implement securities transactions under Sanctuary and not
through the Advisor. In this capacity, the Advisory Person will receive commission-based compensation in
connection with the purchase and sale of securities, including 12b-1 fees for the sale of investment company
products. Compensation earned by the Advisory Person in one’s capacity as a Registered Representative is
separate and in addition to wealth management fees. This practice presents a conflict of interest because the
Advisory Person who is a Registered Representative has an incentive to effect securities transactions for the
purpose of generating commissions. Clients are not obligated to implement any recommendation provided by the
Advisor nor Advisory Persons. Neither the Advisor nor Advisory Persons will earn ongoing wealth management
fees in connection with any products or services implemented in the Advisory Person’s separate capacity as a
Registered Representative. Please see Item 10 below.
Insurance Agency Affiliation
Certain Advisory Persons are also licensed as independent insurance professionals. As an independent
insurance professional, an Advisory Person may earn commission-based compensation for selling insurance
products, including insurance products offered to Clients. Insurance commissions earned by the Advisory
Persons are separate and in addition to the Advisor’s fees. This practice presents a conflict of interest because
as an Advisory Person will have an incentive to recommend insurance products to a Client for the purpose of
generating commissions rather than solely based on the Client’s needs. Clients are under no obligation,
contractually or otherwise, to purchase insurance products through any Advisory Person affiliated with the
Advisor. Please see Item 10 below.
Item 6 – Performance-Based Fees and Side-By-Side Management
Marble Wealth does not charge performance-based fees for its wealth management services. The fees charged
by Marble Wealth are as described in Item 5 above and are not based upon the capital appreciation of the funds
or securities held by any Client.
Marble Wealth does not manage any proprietary investment funds or limited partnerships (for example, a mutual
fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its
Clients.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 9
Item 7 – Types of Clients
Marble Wealth offers advisory services to individuals, high net worth individuals, families, trusts, estates,
businesses, charitable organizations, and retirement plans. Marble Wealth generally does not impose a minimum
relationship size.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
Marble Wealth primarily employs fundamental and technical analysis methods in developing investment
strategies for its Clients. Research and analysis from Marble Wealth are derived from numerous sources,
including financial media companies, third-party research materials, professional data subscriptions, Internet
sources, and review of company activities, including annual reports, prospectuses, press releases and research
prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria
generally consists of ratios and trends that may indicate the overall strength and financial viability of the entity
being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong
investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a
potential investment, it does not guarantee that the investment will increase in value. Assets meeting the
investment criteria utilized in the fundamental analysis may lose value and may have negative investment
performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations
are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of
Accounts.
Technical analysis involves the analysis of past market data rather than specific company data in determining the
recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns
and trends, which may be based on investor sentiment rather than the fundamentals of the company. The
primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the
future. Even if the trend will eventually reoccur, there is no guarantee that Marble Wealth will be able to predict
such a reoccurrence accurately.
As noted above, Marble Wealth generally employs a long-term investment strategy for its Clients, as consistent
with their financial goals. Marble Wealth will typically hold all or a portion of a security for more than a year but
may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At
times, Marble Wealth may also buy and sell positions that are more short-term in nature, depending on the goals
of the Client and/or the fundamentals of the security, sector, or asset class.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. Marble Wealth will assist Clients in determining an
appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no
guarantee that a Client will meet their investment goals. Please see Item 8.B. for risks associated with the
Advisor’s investment strategies as well as general risks of investing.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that
the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis
may lose value and may have negative investment performance. The Advisor monitors these economic
indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s
review process are included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk, and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 10
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the
Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals,
or other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client
accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio
construction process. Following are some of the risks associated with the Advisor’s investment approach:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs
will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading
risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large
bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and
may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF
purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a
short time later.
Bond ETF Risks
Bond ETFs are subject to specific risks, including the following: (1) interest rate risks, i.e., the risk that bond
prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bonds time to maturity, and
the coupon rate of the bond. (2) reinvestment risk, i.e., the risk that any profit gained must be reinvested at a
lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation
increase at a rate that exceeds the income investment thereby decreasing the investors rate of return, (4) credit
default risk, i.e., the risk associated with purchasing a debt instrument which includes the possibility of the
company defaulting on its repayment obligation, (5) rating downgrades, i.e., the risk associated with a rating
agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to
repay its debt and (6) Liquidity Risks, i.e., the risk that a bond may not be sold as quickly as there is no readily
available market for the bond.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of
the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a
mutual fund is typically set daily; therefore, a mutual fund purchased at one point in the day will typically have the
same price as a mutual fund purchased later that same day.
Digital Assets Risks
Digital assets are highly speculative and volatile investments that may become illiquid at any time. Digital assets
are loosely regulated. Clients could lose the entire value of their investment in digital assets and is only suitable
for Clients with a high risk tolerance.
Margin Borrowings
The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities
pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin
call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory
liquidation of the pledged securities to compensate for the decline in value.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
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Past performance is not a guarantee of future returns. Investing in securities and other investments
involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to
discuss these risks with the Advisor.
Item 9 – Disciplinary Information
There are no legal, regulatory, or disciplinary events involving Marble Wealth or its management
persons. Marble Wealth values the trust Clients place in the Advisor. The Advisor encourages Clients to perform
the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the
Advisor and its Advisory Persons are available on the Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 335291.
Item 10 – Other Financial Industry Activities and Affiliations
Except as noted below, Marble Wealth does not maintain any affiliations with other firms, other than contracted
service providers to assist with the servicing of its Client’s accounts.
Broker-Dealer Affiliation
As noted in Item 5, certain Advisory Persons are also Registered Representatives of Sanctuary. In one’s separate
capacity as a Registered Representative, Advisory Persons will receive commissions for the implementation of
recommendations for commissionable transactions. Clients are not obligated to implement any recommendation
provided by the Advisory Person. Neither the Advisor nor Advisory Persons will earn ongoing investment advisory
fees in connection with any services implemented in the Advisory Person’s separate capacity as a Registered
Representative.
Insurance Agency Affiliations
As noted in Item 5, certain Advisory Persons are licensed insurance professionals. Implementations of insurance
recommendations are separate and apart from one’s role with the Advisor. As an insurance professional, the
Advisory Person may receive customary commissions and other related revenues from the various insurance
companies whose products are sold. Advisory Persons are not required to offer the products of any particular
insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This presents
a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation
to implement any recommendations made by an Advisory Person.
Use of Independent Managers
As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio with one or more
Independent Managers. The Advisor does not receive any compensation nor does this present a material conflict
of interest. The Advisor will only earn its wealth management fee as described in Item 5.A.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
Marble Wealth has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to
each Client. This Code applies to all persons associated with Marble Wealth (“Supervised Persons”). The Code
was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the
Client. Marble Wealth and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each
Client. It is the obligation of Marble Wealth’s Supervised Persons to adhere not only to the specific provisions of
the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address
employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (334) 679-
4800.
B. Personal Trading with Material Interest
Marble Wealth allows Supervised Persons to purchase or sell the same securities that may be recommended to
and purchased on behalf of Clients. Marble Wealth does not act as a principal in any transactions. In addition,
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 12
the Advisor does not act as the general partner of a fund or advise an investment company. Marble Wealth does
not have a material interest in any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
Marble Wealth allows Supervised Persons to purchase or sell the same securities that may be recommended to
and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to
Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through
policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material
non-public information controls); gifts and entertainment; outside business activities and personal securities
reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the
same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are
made with more advantageous terms than Client trades, or by trading based on material non-public information.
This risk is mitigated by Marble Wealth requiring reporting of personal securities trades by its Supervised
Persons for review by the Chief Compliance Officer (“CCO”). The Advisor has also adopted written policies and
procedures to detect the misuse of material, non-public information.
D. Personal Trading at Same Time as Client
While Marble Wealth allows Supervised Persons to purchase or sell the same securities that may be
recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or
traded afterward. At no time will Marble Wealth, or any Supervised Person of Marble Wealth, transact in
any security to the detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
Marble Wealth does not have discretionary authority to select the broker-dealer/custodian for custody and
execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard
Client assets and authorize Marble Wealth to direct trades to the Custodian as agreed upon in the wealth
management agreement. Further, Marble Wealth does not have the discretionary authority to negotiate
commissions on behalf of Clients on a trade-by-trade basis.
Where Marble Wealth does not exercise discretion over the selection of the Custodian, it may recommend the
Custodian[s] to Clients for custody and execution services. Clients are not obligated to use the Custodian
recommended by the Advisor and will not incur any extra fee or cost associated with using a custodian not
recommended by Marble Wealth. However, the Advisor may be limited in the services it can provide if the
recommended Custodian is not engaged. Marble Wealth may recommend the Custodian based on criteria such
as, but not limited to, the reasonableness of commissions charged to the Client, services made available to the
Client, and its reputation and/or the location of the Custodian’s offices. Marble Wealth will generally recommend
that Clients establish their account[s] at Fidelity Investments, Inc. and its related divisions and entities
(collectively “Fidelity”). Fidelity is a FINRA-registered broker-dealer and New York Stock Exchange/SIPC
member. Fidelity will serve as the Client’s “qualified custodian.” Marble Wealth maintains institutional
relationships with Fidelity, whereby the Advisor receives economic benefits from the Custodian. Clients investing
in Digital Assets must use FDAS for trade and execution purposes. Please see Item 14 below. Following are
additional details regarding the brokerage practices of the Advisor:
Marble Wealth has established an institutional relationship with Fidelity to assist the Advisor in managing Client
account[s]. Access to the Fidelity platform is provided at no charge to the Advisor. The Fidelity platform includes
brokerage, custody, administrative support, record keeping, technology, and related services designed to support
registered investment advisors like Marble Wealth in serving Clients. These services are intended to serve the
best interests of the Advisor’s Clients.
Fidelity may charge securities transaction fees for effecting certain securities transactions. Fidelity enables the
Advisor to obtain certain no-load mutual funds without securities transaction fees and other no-load funds at
nominal transaction charges. Fidelity’ transaction fee rates are generally considered discounted from customary
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 13
retail brokerage rates. However, the transaction fees charged by Fidelity may be higher or lower than those
charged by other custodians and broker-dealers. Please see Item 14 below for additional information.
Following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor
enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and
other services. Marble Wealth does not participate in soft dollar programs sponsored or offered by any
broker-dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian.
Please see Item 14 below.
2. Brokerage Referrals - Marble Wealth does not receive any compensation from any third party in connection
with the recommendation for establishing an account.
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis,” where Marble Wealth will place
trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts
are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade
of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e.,
purchase of a security into one Client account from another Client’s account[s]). Marble Wealth will not be
obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest
available transaction costs. These costs are determined by the Custodian.
A Client may pay a commission that is higher than another qualified custodian might charge to effect the same
transaction. The Advisor has determined in good faith that the commissions charged by Fidelity are reasonable in
relation to the value of the brokerage and research services received. In seeking best execution, the determinative
factor is not necessarily the lowest possible cost, but whether the transaction represents the best qualitative
execution, taking into consideration the full range of the Custodian’s services, including the value of research
provided, execution capability, commission rates, and responsiveness. Accordingly, although the Advisor will seek
competitive rates, to the benefit of all Clients, it may not necessarily obtain the lowest possible commission rates
for specific Client account transactions. Although the investment research products and services that may be
obtained by the Advisor will generally be used to service all of the Advisor’s Clients, they may not equally benefit all
Clients. Please also see Item 14.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of
execution, 4) confidentiality and 5) skill required of the Custodian. Marble Wealth will execute its transactions
through the Custodian as authorized by the Client. Marble Wealth may aggregate orders in a block trade or
trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the
same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually
purchased or sold by the close of each business day must be allocated in a manner that is consistent with the
initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage
or disadvantage any particular Clients’ accounts.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons of Marble
Wealth and periodically by the CCO. Formal reviews are generally conducted at least annually or more frequently
depending on the needs of the Client.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least
annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 14
result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large
deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Marble Wealth if changes
occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan.
Additional reviews may be triggered by material market, economic, or political events.
C. Review Reports
The Client will receive brokerage statements generally monthly from the Custodian. These brokerage statements
are sent directly from the Custodian to the Client. The Client may also establish electronic access to the
Custodian’s website so that the Client may view these reports and their account activity. Client brokerage
statements will include all positions, transactions, and fees relating to the Client’s account[s]. The Advisor may
also provide Clients with periodic reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by Marble Wealth
Marble Wealth is a fee-based advisory firm that is compensated solely by its Clients and not from any investment
product. Marble Wealth does not receive commissions or other compensation from product sponsors, broker-
dealers or any unrelated third party. Marble Wealth may refer Clients to various unaffiliated, non-advisory
professionals (e.g., attorneys, accountants, estate planners) to provide certain financial services necessary to meet
the goals of its Clients. Likewise, Marble Wealth may receive non-compensated referrals of new Clients from
various third-parties.
Participation in Institutional Advisor Platform
As noted in item 12, Marble Wealth has established an institutional relationship with Fidelity and its affiliated
entities to assist the Advisor in managing Client account[s]. As part of the arrangement, Fidelity also makes
available to the Advisor, at no additional charge to the Advisor, certain research and brokerage services, including
research services obtained by Fidelity directly from independent research companies. The Advisor may also
receive additional services and support from Fidelity. As a result of receiving such services for no additional cost,
the Advisor may have an incentive to continue to use or expand the use of Fidelity's services. The Advisor
examined this potential conflict of interest when it chose to enter into the relationship with Fidelity and has
determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client obligations,
including its duty to seek best execution. Please see Item 12 above. The Advisor receives access to software and
related support without cost because the Advisor renders wealth management services to Clients that maintain
assets at Fidelity The software and related systems support may benefit the Advisor but not its Clients directly. In
fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients
should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest
since these benefits may influence the Advisor's recommendation of this Custodian over one that does not furnish
similar software, systems support, or services. In addition, Fidelity has provided the Advisor with financial support in
the launch of the Advisor and reimbursements for various third-party service providers.
B. Client Referrals from Solicitors
Marble Wealth does not engage paid solicitors for Client referrals.
Item 15 – Custody
The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place
all assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and
securities and direct the Advisor to utilize that Custodian for security transactions in the account[s]. The Client
should review statements provided by the Custodian, as the Custodian does not perform this review. For more
information about custodians and brokerage practices, see Item 12 – Brokerage Practices.
If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have
custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 15
adopted safeguards to ensure that the money movements are completed in accordance with the Client’s
instructions.
Item 16 – Investment Discretion
Marble Wealth generally has discretion over the selection and amount of securities to be bought or sold in Client
accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be
subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed
to by Marble Wealth. The discretionary authority will only be authorized upon full disclosure to the Client. The
granting of such authority will be evidenced by the Client's execution of a wealth management agreement
containing all applicable limitations to such authority. All discretionary trades made by Marble Wealth will be in
accordance with each Client's investment objectives and goals.
Item 17 – Voting Client Securities
Marble Wealth does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements
directly from the Custodian. The Advisor will assist in answering questions relating to proxies. However, the
Client retains the sole responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither Marble Wealth, nor its management, have any adverse financial situations that would reasonably impair
the ability of Marble Wealth to meet all obligations to its Clients. Neither Marble Wealth, nor any of its Advisory
Persons, have been subject to a bankruptcy or financial compromise. Marble Wealth is not required to deliver a
balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or
more for services to be performed six months or more in the future.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 16
Marble Wealth LLC
Form ADV Part 2A – Appendix 1
(“Wrap Fee Program Brochure”)
Effective: April 6, 2026
This Form ADV2A - Appendix 1 (“Wrap Fee Program Brochure”) provides information about the qualifications
and business practices for Marble Wealth LLC (“Marble Wealth” or the “Advisor”) services when offering services
pursuant to a wrap program. This Wrap Fee Program Brochure shall always be accompanied by the Marble
Wealth Disclosure Brochure, which provides complete details on the business practices of the Advisor. If you did
not receive the complete Marble Wealth Disclosure Brochure or you have any questions about the contents of
this Wrap Fee Program Brochure or the Marble Wealth Disclosure Brochure, please contact the Advisor at (334)
679-4800 or by email at info@marblewealth.com.
Marble Wealth is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”).
The information in this Wrap Fee Program Brochure has not been approved or verified by the SEC or by any
state securities authority. Registration of an investment advisor does not imply any specific level of skill or
training. This Wrap Fee Program Brochure provides information about Marble Wealth to assist you in determining
whether to retain the Advisor.
Additional information about Marble Wealth and its advisory persons are available on the SEC’s website at
www.adviserinfo.sec.gov by searching the Advisor’s firm name or CRD# 335291.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 17
Item 2 – Material Changes
Form ADV 2A - Appendix 1 provides information about a variety of topics relating to an Advisor’s business
practices and conflicts of interest. In particular, this Wrap Fee Program Brochure discusses the Wrap Fee
Program offered by the Advisor.
Material Changes
There have been no material changes to the content of this Wrap Fee Program Brochure since the initial filing on
March 31, 2025.
Future Changes
From time to time, the Advisor may amend this Wrap Fee Program Brochure to reflect changes in business
practices, changes in regulations or routine annual updates as required by the securities regulators. This
complete Wrap Fee Program Brochure (along with the complete Marble Wealth Disclosure Brochure) or a
Summary of Material Changes shall be provided to you annually and if a material change occurs in the business
practices of Marble Wealth.
At any time, you may view this Wrap Fee Program Brochure and the current Disclosure Brochure on-line at the
SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching for the Advisor’s
firm name or CRD# 335291. You may also request a copy of this Disclosure Brochure at any time, by contacting
the Advisor at (334) 679-4800 or by email at info@marblewealth.com.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 18
Item 3 – Table of Contents
Item 2 – Material Changes ................................................................................................................................... 18
Item 3 – Table of Contents .................................................................................................................................. 19
Item 4 – Services Fees and Compensation ....................................................................................................... 20
Item 5 – Account Requirements and Types of Clients ..................................................................................... 21
Item 6 – Portfolio Manager Selection and Evaluation ...................................................................................... 21
Item 7 – Client Information Provided to Portfolio Managers ........................................................................... 23
Item 8 – Client Contact with Portfolio Managers .............................................................................................. 23
Item 9 – Additional Information .......................................................................................................................... 23
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
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Item 4 – Services Fees and Compensation
A. Services
Marble Wealth provides customized investment advisory services for its Clients. This Wrap Fee Program
Brochure is provided as a supplement to the Marble Wealth Disclosure Brochure (Form ADV 2A). This Wrap Fee
Program Brochure is provided along with the complete Disclosure Brochure to provide full details of the business
practices and fees when selecting Marble Wealth as your investment advisor.
As part of the investment advisory fees noted in Item 5 of the Disclosure Brochure, Marble Wealth includes, in
addition to securities transaction fees, custodial costs, and other fees and expenses (herein “Covered Costs”) as
part of the overall investment advisory fee. Securities regulations often refer to this combined fee structure as a
“Wrap Fee Program”. The Advisor’s recommended Custodian does not charge securities transaction fees for
exchange-traded fund (“ETF”) and equity trades in Client accounts, but typically charges for mutual funds and
other types of investments. The Advisor sponsors the Marble Wealth Wrap Fee Program.
The sole purpose of this Wrap Fee Program Brochure is to provide additional disclosure relating the combination
of Covered Costs into a single “bundled” investment advisory fee. This Wrap Fee Program Brochure references
back to the Marble Wealth Disclosure Brochure in which this Wrap Fee Program Brochure serves as an
Appendix. Please see Item 4 – Advisory Services of the Disclosure Brochure for details on Marble
Wealth’s investment philosophy and related services.
B. Program Costs
Advisory services provided by Marble Wealth are offered in a wrap fee structure whereby Covered Costs are
included in the overall investment advisory fee paid to Marble Wealth. As the level of activity in a Client’s
account[s] may vary from year to year, the annual cost to the Client may be more or less than engaging for
advisory services where the Covered Costs are borne separately by the Client. The cost of the Wrap Fee
Program varies depending on services to be provided to each Client, however, the Client is not charged more if
there is higher trading activity or other Covered Costs. A Wrap Fee structure presents a conflict of interest as the
Advisor is incentivized to limit the number of trades placed in the Client’s account[s] or to utilize securities that do
not have transaction fees. As noted above, the Advisor’s recommended Custodian does not charge securities
transaction fees for ETF and equity trades in Client accounts, but typically charges for mutual funds and other
types of investments. As such, the Advisor is incentivized to utilize ETFs and other equity securities to limit the
overall cost to the Advisor. The Advisor will only place Client assets into a Wrap Fee Program when it is believed
to be in the Client’s best interest. Please see Item 5 – Fees and Compensation of the Disclosure Brochure
for complete details on fees.
C. Fees
Wealth management fees are paid monthly, in advance of each monthly billing period, pursuant to the terms of the
wealth management agreement. Wealth management fees are based on average market value of assets under
management during prior month. Wealth management fees range from 0.35% to 1.00% annually. The fee in the
first month of service is prorated from the inception and asset funding of the account[s] to the end of the first month
based on the number of days in the period and the timing of asset transfers into the account[s]. Fees may be
negotiable at the sole discretion of the Advisor. In certain circumstances, the Advisor may charge a fixed annual fee
for its services. The Client’s fees will take into consideration the aggregate assets under management with the
Advisor across all accounts to achieve the lower breakpoint above, unless otherwise agreed in writing. All securities
held in accounts managed by Marble Wealth will be independently valued by the Custodian. Marble Wealth will not
have the authority or responsibility to value portfolio securities. The Advisor will conduct periodic reviews of the
Custodian’s valuation to ensure accurate billing.
Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at
the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted
from the Client’s account[s] at the start of the respective monthly billing period. The amount due is calculated by
applying the daily rate (annual rate divided by the number of days in the year times the number of days in the
monthly billing period) to the average assets under management with the Advisor during the prior month. Clients will
be provided with a statement, generally monthly, from the Custodian reflecting the deduction of the management
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 20
fee. Clients provide written authorization permitting wealth management fees to be deducted by Marble Wealth to
be paid directly from their account[s] held by the Custodian as part of the wealth management agreement and
separate account forms provided by the Custodian.
In addition, all fees paid to Marble Wealth for wealth management advisory services or part of the Wrap Fee
Program are separate and distinct from the expenses charged by mutual funds and exchange-traded funds to
their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees
and expenses will generally be used to pay management fees for the funds, other fund expenses, account
administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. Securities
transaction fees for Client-directed trades will not be charged back to the Client. In connection with the
discretionary investment management services provided by Marble Wealth, the Client will incur other costs
assessed by the Custodian or other third parties, other than the Covered Costs noted above, such as custodial
costs, and other fees and expenses. The Advisor does not control nor share in these fees. The Client should
review both the fees charged by the fund[s] and the fees charged by Marble Wealth to fully understand the total
fees to be paid. Please see Item 5.C. – Other Fees and Expenses in the Disclosure Brochure (included with this
Wrap Fee Program Brochure).
D. Compensation
Marble Wealth is the sponsor and portfolio manager of this Wrap Fee Program. Marble Wealth receives
investment advisory fees paid by Clients for participating in the Wrap Fee Program and pays the Covered Costs
associated with the management of the Client’s account[s].
Item 5 – Account Requirements and Types of Clients
Marble Wealth offers investment advisory services to individuals, high net worth individuals, families, trusts,
estates, businesses, and retirement plans. Marble Wealth generally does not impose a minimum account size for
establishing a relationship. Please see Item 7 – Types of Clients in the Disclosure Brochure for additional
information.
Item 6 – Portfolio Manager Selection and Evaluation
Portfolio Manager Selection
Marble Wealth serves as sponsor and as portfolio manager for the services under this Wrap Fee Program.
Related Persons
Marble Wealth personnel serve as portfolio managers for this Wrap Fee Program. Marble Wealth does not serve
as a portfolio manager for any third-party Wrap Fee Programs.
Performance-Based Fees
Marble Wealth does not charge performance-based fees for its wealth management services. The fees charged
by Marble Wealth are as described in Item 5 above and are not based upon the capital appreciation of the funds
or securities held by any Client.
Marble Wealth does not manage any proprietary investment funds or limited partnerships (for example, a mutual
fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its
Clients.
Supervised Persons
Marble Wealth Advisory Persons serve as portfolio managers for all accounts, including the services described in
this Wrap Fee Program Brochure. Details of the advisory services provided are included in Item 4.A. of the
Disclosure Brochure.
Methods of Analysis
Please see Item 8 of the Disclosure Brochure (included with this Wrap Fee Program Brochure) for details on the
research and analysis methods employed by the Advisor.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 21
Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. Marble Wealth will assist Clients in determining an
appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no
guarantee that a Client will meet their investment goals. Please see Item 8.B. for risks associated with the
Advisor’s investment strategies as well as general risks of investing.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that
the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis
may lose value and may have negative investment performance. The Advisor monitors these economic
indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s
review process are included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client’s investment goals, financial situation, time horizon,
tolerance for risk, and other factors to develop an appropriate strategy for managing a Client’s account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client’s account[s]. The Advisor shall rely on the financial and other information provided by the
Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals,
or other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client
accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio
construction process. Following are some of the risks associated with the Advisor’s investment approach:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs
will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading
risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large
bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and
may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF
purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a
short time later.
Bond ETF Risks
Bond ETFs are subject to specific risks, including the following: (1) interest rate risks, i.e., the risk that bond
prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bonds time to maturity, and
the coupon rate of the bond. (2) reinvestment risk, i.e., the risk that any profit gained must be reinvested at a
lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation
increase at a rate that exceeds the income investment thereby decreasing the investors rate of return, (4) credit
default risk, i.e., the risk associated with purchasing a debt instrument which includes the possibility of the
company defaulting on its repayment obligation, (5) rating downgrades, i.e., the risk associated with a rating
agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to
repay its debt and (6) Liquidity Risks, i.e., the risk that a bond may not be sold as quickly as there is no readily
available market for the bond.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of
the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 22
mutual fund is typically set daily; therefore, a mutual fund purchased at one point in the day will typically have the
same price as a mutual fund purchased later that same day.
Digital Assets Risks
Digital assets are highly speculative and volatile investments that may become illiquid at any time. Digital assets
are loosely regulated. Clients could lose the entire value of their investment in digital assets and is only suitable
for Clients with a high risk tolerance.
Margin Borrowings
The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities
pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin
call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory
liquidation of the pledged securities to compensate for the decline in value.
Past performance is not a guarantee of future returns. Investing in securities and other investments
involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to
discuss these risks with the Advisor. Please see Item 8.B. – Risk of Loss in the Disclosure Brochure for
details on investment risks.
Proxy Voting
Marble Wealth does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements
directly from the Custodian. The Advisor will assist in answering questions relating to proxies. However, the
Client retains the sole responsibility for proxy decisions and voting.
Item 7 – Client Information Provided to Portfolio Managers
Marble Wealth is the sponsor and sole portfolio manager for the Program. The Advisor does not share Client
information with other portfolio managers because it is the sole portfolio manager for this Wrap Fee Program.
Please also see the Marble Wealth Privacy Policy (included after this Wrap Fee Program Brochure).
Item 8 – Client Contact with Portfolio Managers
Marble Wealth is a full-service investment management advisory firm. Clients always have direct access to the
Portfolio Managers at Marble Wealth.
Item 9 – Additional Information
A. Disciplinary Information and Other Financial Industry Activities and Affiliations
Marble Wealth does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements
directly from the Custodian. The Advisor will assist in answering questions relating to proxies. However, the
Client retains the sole responsibility for proxy decisions and voting.
Please see Item 9 of the Marble Wealth Disclosure Brochure as well as Item 3 of each Advisory Person’s
Brochure Supplement (included with this Wrap Fee Program Brochure) for additional information on how to
research the background of the Advisor and its Advisory Persons.
Other Financial Activities and Affiliations
Please see Item 10 – Other Financial Activities and Affiliation and Item 14 – Client Referrals and Other
Compensation of the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Program Brochure).
B. Code of Ethics, Review of Accounts, Client Referrals, and Financial Information
Marble Wealth has implemented a Code of Ethics that defines the Advisor’s fiduciary commitment to each Client.
This Code of Ethics applies to all persons subject to Marble Wealth’s compliance program (our “Supervised
Persons”). Complete details on the Marble Wealth Code of Ethics can be found under Item 11 – Code of Ethics,
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 23
Participation in Client Transactions and Personal Trading in the Disclosure Brochure (included with this Wrap
Fee Program Brochure).
Investments in
Review of Accounts
Client accounts are monitored on a regular and continuous basis by Advisory Persons of Marble Wealth under
the supervision of the Chief Compliance Officer (“CCO”). Details of the review policies and practices are
provided in Item 13 of the Form ADV Part 2A – Disclosure Brochure.
Other Compensation
Participation in Institutional Advisor Platform
As noted in item 12, Marble Wealth has established an institutional relationship with Fidelity and its affiliated
entities to assist the Advisor in managing Client account[s]. As part of the arrangement, Fidelity also makes
available to the Advisor, at no additional charge to the Advisor, certain research and brokerage services, including
research services obtained by Fidelity directly from independent research companies. The Advisor may also
receive additional services and support from Fidelity. As a result of receiving such services for no additional cost,
the Advisor may have an incentive to continue to use or expand the use of Fidelity's services. The Advisor
examined this potential conflict of interest when it chose to enter into the relationship with Fidelity and has
determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client obligations,
including its duty to seek best execution. Please see Item 12 above. The Advisor receives access to software and
related support without cost because the Advisor renders wealth management services to Clients that maintain
assets at Fidelity The software and related systems support may benefit the Advisor but not its Clients directly. In
fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients
should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest
since these benefits may influence the Advisor's recommendation of this Custodian over one that does not furnish
similar software, systems support, or services. In addition, Fidelity has provided the Advisor with financial support in
the launch of the Advisor and reimbursements for various third-party service providers.
Please se
Item 14 – Other Compensation in the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee
Program Brochure) for details on additional compensation that may be received by Marble Wealth or its
Advisory Persons. Each Advisory Person’s Brochure Supplement (also included with this Wrap Fee Program
Brochure) provides details on any outside business activities and the associated compensation.
Client Referrals from Solicitors
Marble Wealth does not engage paid solicitors for Client referrals.
Financial Information
Neither Marble Wealth, nor its management, have any adverse financial situations that would reasonably impair
the ability of Marble Wealth to meet all obligations to its Clients. Neither Marble Wealth, nor any of its Advisory
Persons, have been subject to a bankruptcy or financial compromise. Marble Wealth is not required to deliver a
balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or
more for services to be performed six months or more in the future.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 24
Form ADV Part 2B – Brochure Supplement
for
Matthew B. Murphy, CFP®
Partner, Chief Executive Officer
Effective: April 6, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Matthew B. Murphy, CFP® (CRD# 5503314) in addition to the information contained in the Marble Wealth LLC
(“Marble Wealth” or the “Advisor”, CRD# 335291) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the Marble Wealth Disclosure Brochure
or this Brochure Supplement, please contact us at (334) 679-4800.
Additional information about Mr. Murphy is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5503314.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 25
Item 2 – Educational Background and Business Experience
Matthew B. Murphy, CFP®, born in 1984, is dedicated to advising Clients of Marble Wealth as a Partner and the
Chief Executive Officer. Mr. Murphy earned a Bachelor’s Degree from Auburn University in 2006. Additional
information regarding Mr. Murphy’s employment history is included below.
Employment History:
Partner, Chief Executive Officer, Marble Wealth LLC
Investment Advisor Representative, Sanctuary Advisors, LLC
Registered Representative, Sanctuary Securities, Inc.
Financial Advisor, UBS Financial Services Inc.
05/2025 to Present
08/2022 to 05/2025
08/2022 to 05/2025
03/2008 to 08/2022
CERTIFIED FINANCIAL PLANNER® Professional
I am certified for financial planning services in the United States by Certified Financial Planner Board of
Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER®
Professional or a CFP® Professional, and I may use these and the other certification marks (the “CFP Board
Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning, Inc. has
licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state law or
regulation requires financial planners to hold the CFP® certification. You may find more information about the
CFP® certification at www.cfp.net.
CFP® Professionals have met CFP Board’s high standards for education, examination, experience, and ethics.
To become a CFP® Professional, an individual must fulfill the following requirements:
● Education – Earn a bachelor’s degree or higher from an accredited college or university and complete
CFP Board-approved coursework at a college or university through a CFP Board Registered Program.
The coursework covers the financial planning subject areas CFP Board has determined are necessary
for the competent and professional delivery of financial planning services, as well as a comprehensive
financial plan development capstone course. A candidate may satisfy some of the coursework
requirement through other qualifying credentials. CFP Board implemented the bachelor’s degree or
higher requirement in 2007 and the financial planning development capstone course requirement in
March 2012. Therefore, a CFP® Professional who first became certified before those dates may not have
earned a bachelor’s or higher degree or completed a financial planning development capstone course.
● Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to
assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the
context of real-life financial planning situations.
● Experience – Complete 6,000 hours of Professional experience related to the personal financial
planning process, or 4,000 hours of apprenticeship experience that meets additional requirements.
● Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP®
Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and
Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for
CFP® Professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements to
remain certified and maintain the right to continue to use the CFP Board.
Certification Marks:
● Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to
CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the
Client, at all times when providing financial advice and financial planning. CFP Board may sanction a
CFP® Professional who does not abide by this commitment, but CFP Board does not guarantee a CFP®
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 26
Professional’s service. A Client who seeks a similar commitment should obtain a written engagement
that includes a fiduciary obligation to the Client.
● Continuing Education – Complete 30 hours of continuing education every two years to maintain
competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with
developments in financial planning. Two of the hours must address the Code and Standards.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Murphy. Mr. Murphy has never
been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits,
arbitration claims or administrative proceedings against Mr. Murphy.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Murphy.
However, we do encourage you to independently view the background of Mr. Murphy on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
5503314.
Item 4 – Other Business Activities
Mr. Murphy is dedicated to the investment advisory activities of Marble Wealth’s Clients. Mr. Murphy does not
have any other business activities.
Item 5 – Additional Compensation
Mr. Murphy is dedicated to the investment advisory activities of Marble Wealth’s Clients. Mr. Murphy does not
receive any additional forms of compensation.
Item 6 – Supervision
Mr. Murphy serves as a Partner and the Chief Executive Officer of Marble Wealth and is supervised by Lauren
Farrior, the Chief Compliance Officer. Ms. Farrior can be reached at (334) 679-4800.
Marble Wealth has implemented a Code of Ethics, an internal compliance document that guides each
Supervised Person in meeting their fiduciary obligations to Clients of Marble Wealth. Further, Marble Wealth is
subject to regulatory oversight by various agencies. These agencies require registration by Marble Wealth and its
Supervised Persons. As a registered entity, Marble Wealth is subject to examinations by regulators, which may
be announced or unannounced. Marble Wealth is required to periodically update the information provided to
these agencies and to provide various reports regarding the business activities and assets of the Advisor.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 27
Form ADV Part 2B – Brochure Supplement
for
Rebecca H. Baker, CFP®, CPA, CEPA®
Partner, Chief Operating Officer
Effective: April 6, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Rebecca H. Baker, CFP®, CPA, CEPA® (CRD# 6337829) in addition to the information contained in the Marble
Wealth LLC (“Marble Wealth” or the “Advisor”, CRD# 335291) Disclosure Brochure. If you have not received a
copy of the Disclosure Brochure or if you have any questions about the contents of the Marble Wealth Disclosure
Brochure or this Brochure Supplement, please contact us at (334) 679-4800.
Additional information about Ms. Baker is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 6337829.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 28
Item 2 – Educational Background and Business Experience
Rebecca H. Baker, CFP®, CPA, CEPA®, born in 1981, is dedicated to advising Clients of Marble Wealth as a
Partner and the Chief Operating Officer. Ms. Baker earned an MBA from Auburn University at Montgomery in
2005. Ms. Baker also earned a Bachelor of Science in Commerce & Business Administration and Accounting
from University of Alabama in 2004. Additional information regarding Ms. Baker’s employment history is included
below.
Employment History:
Partner and Chief Operating Officer, Marble Wealth LLC
Registered Representative, Sanctuary Securities, Inc.
Investment Advisor Representative, Sanctuary Advisors, LLC
Financial Advisor, UBS Financial Services Inc.
Financial Advisor, Morgan Stanley
05/2025 to Present
08/2022 to Present
08/2022 to 05/2025
04/2016 to 08/2022
07/2014 to 04/2016
CERTIFIED FINANCIAL PLANNER® Professional
I am certified for financial planning services in the United States by Certified Financial Planner Board of
Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER®
Professional or a CFP® Professional, and I may use these and the other certification marks (the “CFP Board
Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning, Inc. has
licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state law or
regulation requires financial planners to hold the CFP® certification. You may find more information about the
CFP® certification at www.cfp.net.
CFP® Professionals have met CFP Board’s high standards for education, examination, experience, and ethics.
To become a CFP® Professional, an individual must fulfill the following requirements:
● Education – Earn a bachelor’s degree or higher from an accredited college or university and complete
CFP Board-approved coursework at a college or university through a CFP Board Registered Program.
The coursework covers the financial planning subject areas CFP Board has determined are necessary
for the competent and professional delivery of financial planning services, as well as a comprehensive
financial plan development capstone course. A candidate may satisfy some of the coursework
requirement through other qualifying credentials. CFP Board implemented the bachelor’s degree or
higher requirement in 2007 and the financial planning development capstone course requirement in
March 2012. Therefore, a CFP® Professional who first became certified before those dates may not have
earned a bachelor’s or higher degree or completed a financial planning development capstone course.
● Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to
assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the
context of real-life financial planning situations.
● Experience – Complete 6,000 hours of Professional experience related to the personal financial
planning process, or 4,000 hours of apprenticeship experience that meets additional requirements.
● Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP®
Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and
Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for
CFP® Professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements to
remain certified and maintain the right to continue to use the CFP Board.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 29
Certification Marks:
● Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to
CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the
Client, at all times when providing financial advice and financial planning. CFP Board may sanction a
CFP® Professional who does not abide by this commitment, but CFP Board does not guarantee a CFP®
Professional’s service. A Client who seeks a similar commitment should obtain a written engagement
that includes a fiduciary obligation to the Client.
● Continuing Education – Complete 30 hours of continuing education every two years to maintain
competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with
developments in financial planning. Two of the hours must address the Code and Standards.
Certified Public Accountant™ (“CPA”)
CPAs are licensed and regulated by their state boards of accountancy. While state laws and regulations vary, the
education, experience and testing requirements for licensure as a CPA generally include minimum
college education (typically 150 credit hours with at least a baccalaureate degree and a concentration in
accounting), minimum experience levels (most states require at least one year of experience providing services
that involve the use of accounting, attest, compilation, management advisory, financial advisory, tax or consulting
skills, all of which must be achieved under the supervision of or verification by a CPA), and successful passage
of the Uniform CPA Examination. In order to maintain a CPA license, states generally require the completion of
40 hours of continuing professional education (CPE) each year (or 80 hours over a two-year period or 120 hours
over a three-year period). Additionally, all American Institute of Certified Public Accountants™ (AICPA®) members
are required to follow a rigorous Code of Professional Conduct which requires that they act with integrity,
objectivity, due care, competence, fully disclose any conflicts of interest (and obtain client consent if a conflict
exists), maintain client confidentiality, disclose to the client any commission or referral fees, and serve the public
interest when providing financial services. The vast majority of state boards of accountancy have adopted the
AICPA’s® Code of Professional Conduct within their state accountancy laws or have created their own.
Certified Exit Planning Advisor™ (“CEPA®”)
The Certified Exit Planning Advisor™ and CEPA® are professional certifications marks granted by The Exit
Planning Institute®. It is recognized as the designation that business owners look for when looking for a trusted
advisor. CEPA® applicants must meet strict requirements, including a minimum of a bachelor’s degree from an
accredited U.S. college or university (or the equivalent from a foreign university); completion of the 5-day CEPA®
program taught by a faculty of experts; and passing the CEPA® exam consisting of 150 multiple-choice
questions. Applicants must also have five years of experience dealing with the owners of privately-held
businesses in some advisory capacity. All applicants for the CEPA® program must sign an attestation agreeing to
abide by the Code of Ethics and Professional Standards™ of the Exit Planning Institute.
CEPA® advisors must complete ongoing continuing professional education and ethics requirements to maintain
their certification, with recertification every three years and completing 40 hours of continuing education. More
information on the CEPA® designation can be found on the Exit Planning website: www.exit-planning-
institute.org
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Ms. Baker. Ms. Baker has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Ms. Baker.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Ms. Baker.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 30
However, we do encourage you to independently view the background of Ms. Baker on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD#
6337829.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Ms. Baker is also a licensed insurance professional. Implementations of insurance recommendations are
separate and apart from Ms. Baker’s role with Marble Wealth. As an insurance professional, Ms. Baker will
receive customary commissions and other related revenues from the various insurance companies whose
products are sold. Ms. Baker is not required to offer the products of any particular insurance company.
Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict
of interest in recommending certain products of the insurance companies. Clients are under no obligation to
implement any recommendations made by Ms. Baker or the Advisor. Ms. Baker spends approximately less than
10% of her time per month in this capacity.
Broker-Dealer Affiliation
Ms. Baker is also a registered representative of Sanctuary Securities, Inc. (“Sanctuary”). Sanctuary is a
registered broker-dealer (CRD# 205), member FINRA, SIPC. In Ms. Baker’s separate capacity as a registered
representative, Ms. Baker will receive commissions for the implementation of recommendations for
commissionable transactions. Clients are not obligated to implement any recommendation provided by Ms.
Baker. Neither the Advisor nor Ms. Baker will earn ongoing investment advisory fees in connection with any
products or services implemented in Ms. Baker’s separate capacity as a registered representative. Ms. Baker
spends approximately 10% of her time per month in her role as a registered representative of Sanctuary.
Item 5 – Additional Compensation
Ms. Baker has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Ms. Baker serves as a Partner and the Chief Operating Officer and is supervised by Lauren Farrior, the Chief
Compliance Officer. Ms. Farrior can be reached at (334) 679-4800. Marble Wealth has implemented a Code of
Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary
obligations to Clients of Marble Wealth. Further, Marble Wealth is subject to regulatory oversight by various
agencies. These agencies require registration by Marble Wealth and its Supervised Persons. As a registered
entity, Marble Wealth is subject to examinations by regulators, which may be announced or unannounced.
Marble Wealth is required to periodically update the information provided to these agencies and to provide
various reports regarding the business activities and assets of the Advisor.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 31
Form ADV Part 2B – Brochure Supplement
for
Adam M. Rogers, CFA®
Partner, Chief Investment Officer
Effective: April 6, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Adam M. Rogers, CFA® (CRD# 7615821) in addition to the information contained in the Marble Wealth LLC
(“Marble Wealth” or the “Advisor”, CRD# 335291) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the Marble Wealth Disclosure Brochure
or this Brochure Supplement, please contact us at (334) 679-4800.
Additional information about Mr. Rogers is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 7615821.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 32
Item 2 – Educational Background and Business Experience
Adam M. Rogers, CFA®, born in 1981, is dedicated to advising Clients of Marble Wealth as a Partner and the
Chief Investment Officer, Partner. Mr. Rogers earned an MA in Finance from the University of Alabama in 2005.
Mr. Rogers also earned a BA in Finance from the University of Alabama in 2003.
Employment History:
Partner, Chief Investment Officer, Partner, Marble Wealth LLC
Investment Advisor Representative, Sanctuary Advisors, LLC
Portfolio Manager, Retirement Systems of Alabama
05/2025 to Present
08/2022 to 05/2025
07/2005 to 08/2022
Chartered Financial Analyst™ (“CFA®”)
The Chartered Financial Analyst™ (“CFA®”) charter is a professional designation established in 1962 and
awarded by CFA® Institute. To earn the CFA® charter, candidates must pass three sequential, six-hour
examinations over two to four years. The three levels of the CFA® Program test a wide range of investment
topics, including ethical and professional standards, fixed-income analysis, alternative and derivative
investments, and portfolio management and wealth planning. Also, CFA® charter holders must have at least four
years of acceptable professional experience in the investment decision-making process and must commit to
abide by, and annually reaffirm their adherence to the CFA® Institute Code of Ethics and Standards of
Professional Conduct. CFA® is a trademark owned by CFA® Institute.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Rogers. Mr. Rogers has never
been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits,
arbitration claims or administrative proceedings against Mr. Rogers. Securities laws require an advisor to
disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory,
civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or
omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or
dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events
to disclose regarding Mr. Rogers. However, we do encourage you to independently view the background of
Mr. Rogers on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with
his full name or his Individual CRD# 7615821.
Item 4 – Other Business Activities
Mr. Rogers is dedicated to the investment advisory activities of Marble Wealth’s Clients. Mr. Rogers does not
have any other business activities.
Item 5 – Additional Compensation
Mr. Rogers is dedicated to the investment advisory activities of Marble Wealth’s Clients. Mr. Rogers does not
receive any additional forms of compensation.
Item 6 – Supervision
Mr. Rogers serves as a Partner and the Chief Investment Officer of Marble Wealth and is supervised by Lauren
Farrior, the Chief Compliance Officer. Ms. Farrior can be reached at (334) 679-4800. Marble Wealth has
implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting
their fiduciary obligations to Clients of Marble Wealth. Further, Marble Wealth is subject to regulatory oversight by
various agencies. These agencies require registration by Marble Wealth and its Supervised Persons. As a
registered entity, Marble Wealth is subject to examinations by regulators, which may be announced or
unannounced. Marble Wealth is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 33
Form ADV Part 2B – Brochure Supplement
for
Dustin G. Hatfield
Wealth Advisor
Effective: April 6, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Dustin G. Hatfield (CRD# 7062329) in addition to the information contained in the Marble Wealth LLC (“Marble
Wealth” or the “Advisor”, CRD# 335291) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the Marble Wealth Disclosure Brochure or this
Brochure Supplement, please contact us at (334) 679-4800.
Additional information about Mr. Hatfield is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 7062329.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 34
Item 2 – Educational Background and Business Experience
Dustin G. Hatfield, born in 1994, is dedicated to advising Clients of Marble Wealth as a Wealth Advisor. Mr.
Hatfield earned a B.S. in Economics from Auburn University of Montgomery in 2018. Additional information
regarding Mr. Hatfield’s employment history is included below.
Employment History:
Wealth Advisor, Marble Wealth LLC
Investment Advisor Representative, Sanctuary Advisors, LLC
Registered Representative, Sanctuary Securities, LLC
Financial Advisor, UBS Financial Services, Inc.
05/2025 to Present
08/2022 to 05/2025
08/2022 to 05/2025
05/2019 to 08/2022
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Hatfield. Mr. Hatfield has never
been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits,
arbitration claims or administrative proceedings against Mr. Hatfield.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Hatfield.
However, we do encourage you to independently view the background of Mr. Hatfield on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
7062329.
Item 4 – Other Business Activities
Mr. Hatfield is dedicated to the investment advisory activities of Marble Wealth’s Clients. Mr. Hatfield does not
have any other business activities.
Item 5 – Additional Compensation
Mr. Hatfield has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Hatfield serves as a Wealth Advisor of Marble Wealth and is supervised by Lauren Farrior, the Chief
Compliance Officer. Ms. Farrior can be reached at (334) 679-4800.
Marble Wealth has implemented a Code of Ethics, an internal compliance document that guides each
Supervised Person in meeting their fiduciary obligations to Clients of Marble Wealth. Further, Marble Wealth is
subject to regulatory oversight by various agencies. These agencies require registration by Marble Wealth and its
Supervised Persons. As a registered entity, Marble Wealth is subject to examinations by regulators, which may
be announced or unannounced. Marble Wealth is required to periodically update the information provided to
these agencies and to provide various reports regarding the business activities and assets of the Advisor.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 35
Form ADV Part 2B – Brochure Supplement
for
Emily L. Farrior
Director of Operations and Chief Compliance Officer
Effective: April 6, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Emily L. Farrior (CRD# 5600784) in addition to the information contained in the Marble Wealth LLC (“Marble
Wealth” or the “Advisor”, CRD# 335291) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the Marble Wealth Disclosure Brochure or this
Brochure Supplement, please contact us at (334) 679-4800.
Additional information about Ms. Farrior is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 5600784.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 36
Item 2 – Educational Background and Business Experience
Emily L. Farrior, born in 1985, serves as the Director of Operations and the Chief Compliance Officer of Marble
Wealth. Ms. Farrior earned a BA in Public Administration from Auburn University in 2008. Additional information
regarding Ms. Farrior’s employment history is included below.
Employment History:
Director of Operations and Chief Compliance Officer, Marble Wealth LLC
Director of Operations, Sanctuary Advisors LLC
Registerd Representative, Sanctuary Securities, Inc.
Financial Advisor, Raymond James Financial Services Advisors, Inc.
Investment Operations Coordinator, Arlington Family Offices
Underwriting/Muni Sales, Stifel/Merchant Capital LLC
05/2025 to Present
04/2023 to 05/2025
04/2023 to 05/2025
03/2017 to 05/2021
05/2016 to 08/2017
11/2013 to 05/2016
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Ms. Farrior. Ms. Farrior has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Ms. Farrior.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Ms. Farrior.
However, we do encourage you to independently view the background of Ms. Farrior on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD#
5600784.
Item 4 – Other Business Activities
Ms. Farrior is dedicated to the investment advisory activities of Marble Wealth’s Clients. Ms. Farrior does not
have any other business activities.
Item 5 – Additional Compensation
Ms. Farrior has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Ms. Farrior serves as the Director of Operations and Chief Compliance Officer of Marble Wealth and is
supervised by Rebecca Baker, the Chief Operating Officer. Ms. Baker can be reached at (334) 679-4800.
Marble Wealth has implemented a Code of Ethics, an internal compliance document that guides each
Supervised Person in meeting their fiduciary obligations to Clients of Marble Wealth. Further, Marble Wealth is
subject to regulatory oversight by various agencies. These agencies require registration by Marble Wealth and its
Supervised Persons. As a registered entity, Marble Wealth is subject to examinations by regulators, which may
be announced or unannounced. Marble Wealth is required to periodically update the information provided to
these agencies and to provide various reports regarding the business activities and assets of the Advisor.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 37
Privacy Policy
Effective: April 6, 2026
Our Commitment to You
Marble Wealth LLC (“Marble Wealth or the “Advisor”) is committed to safeguarding the use of personal
information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as
described here in our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your
private information, and we do everything that we can to maintain that trust. Marble Wealth (also referred to as
"we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements
controls to ensure that such information is used for proper business purposes in connection with the
management or servicing of our relationship with you.
Marble Wealth does not sell your non-public personal information to anyone. Nor do we provide such information
to others except for discrete and reasonable business purposes in connection with the servicing and
management of our relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set
forth in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing
your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose
how we collect, share, and protect your personal information.
What information do we collect from you?
Driver’s license number
Date of birth
Social security or taxpayer identification number Assets and liabilities
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Other advisory agreements and legal documents
Transactional information with us or others
Account applications and forms
Investment questionnaires and suitability
documents
Other information needed to service account
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 38
How do we protect your information?
To safeguard your personal information from unauthorized access and use, we maintain physical, procedural,
and electronic security measures. These include such safeguards as secure passwords, encrypted file storage,
and a secure office environment. Our technology vendors provide security and access control over personal
information and have policies over the transmission of data. Our associates are trained on their responsibilities to
protect Client’s personal information.
We require third parties that assist in providing our services to you to protect the personal information they
receive from us.
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information.
Basis For Sharing
Do we share?
Can you limit?
Yes
No
No
Not Shared
Yes
Yes
No
Not Shared
Servicing our Clients
We may share non-public personal information with non-affiliated third
parties (such as administrators, brokers, custodians, regulators, credit
agencies, other financial institutions) as necessary for us to provide
agreed upon services to you, consistent with applicable law, including but
not limited to: processing transactions; general account maintenance;
responding to regulators or legal investigations; and credit reporting.
Marketing Purposes
Marble Wealth does not disclose, and does not intend to disclose,
personal information with non-affiliated third parties to offer you services.
Certain laws may give us the right to share your personal information with
financial institutions where you are a customer and where Marble Wealth
or the client has a formal agreement with the financial institution. We will
only share information for purposes of servicing your accounts, not
for marketing purposes.
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent(s) or
representative(s).
Information About Former Clients
Marble Wealth does not disclose and does not intend to disclose, non-
public personal information to non-affiliated third parties with respect to
persons who are no longer our Clients.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the
previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public
personal information other than as described in this notice unless we first notify you and provide you with an
opportunity to prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by
contacting us at (334) 679-4800.
Marble Wealth LLC
4137 Carmichael Road, Suite 210, Montgomery, AL 36106
Phone: (334) 679-4800 | Website: https://marblewealth.com
Page 39