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Item 1-Firm Brochure
(Part 2A of Form ADV)
Marin Financial Advisors, LLC
80 E. Sir Francis Drake Blvd 1A
Larkspur, CA 94939
Tel: (415) 925-1212
Fax: (415) 707-6500
WWW.MARINFA.COM
October 10, 2025
this brochure, please
contact us
at:
(415) 925-1212, or by
email
information about
the Advisor
is available on
This brochure provides information about the qualifications and business practices of Marin
Financial Advisors, LLC hereinafter (“the Advisor”). If you have any questions about the contents
at:
of
compliance@wealthspire.com. The information in this brochure has not been approved or verified
by the United States Securities and Exchange Commission, or by any state securities authority.
Additional
the SEC’s website at
www.Advisorinfo.sec.gov
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Item – 2 Material Changes
Material Changes since the Last Update
Since the filing of our last annual updating amendment on March 27, 2025, we have made the
following material changes to our Brochure:
• Update to reflect that we have become a subsidiary of Wealthspire Advisors LLC
• Updates to Marin’s executives to reflect new ownership
• Added affiliate companies
Full Brochure Available
Whenever you would like to receive a complete copy of our Firm Brochure, please contact us by
telephone at: (415) 925-1212 or by email at: compliance@wealthspire.com.
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Item 3-Table of Contents
Item 1-Firm Brochure ........................................................................................................... - 1 -
Item – 2 Material Changes .................................................................................................... - 2 -
Item 3-Table of Contents ...................................................................................................... - 3 -
Item 4-Advisory Business ..................................................................................................... - 4 -
Types of Agreements ............................................................................................................ - 7 -
Asset Management ................................................................................................................ - 8 -
WRAP Program .................................................................................................................... - 8 -
Termination of Agreement .................................................................................................... - 8 -
Item 5-Fees and Compensation ............................................................................................. - 9 -
Item 6-Performance Fees .................................................................................................... - 10 -
Item 7-Types of Clients ...................................................................................................... - 11 -
Item 8-Methods of Analysis, Investment Strategies and Risk of Loss ............................... - 11 -
Item 9-Disciplinary Information ......................................................................................... - 12 -
Item 10-Other Financial Activities and Affiliations ........................................................... - 12 -
Item 11-Code of Ethics, Participation in Client Transactions and Personal Trading ......... - 13 -
Item 12-Brokerage Practices ............................................................................................... - 14 -
Item 13- Review of Accounts ............................................................................................. - 16 -
Item 14-Client Referrals and Other Compensation ............................................................ - 17 -
Item 15-Custody.................................................................................................................. - 17 -
Account Statements ............................................................................................................ - 17 -
Performance Reports ........................................................................................................... - 17 -
Item 16- Investment Discretion .......................................................................................... - 17 -
Item 17-Voting Client Securities ........................................................................................ - 18 -
Item 18-Financial Information ............................................................................................ - 18 -
Business Continuity Plan .................................................................................................... - 18 -
Information Security Program ............................................................................................ - 19 -
Privacy Practices ................................................................................................................. - 20 -
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Item 4-Advisory Business
Firm Description
Marin Financial Advisors, LLC, hereinafter (“the Advisor”) was founded in 2005 and is an SEC
registered investment advisor.
The Advisor provides personalized confidential financial planning and investment management to
individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, and small
businesses. In many cases, financial planning is part of the investment advisory services. Financial
planning generally advises clients regarding cash flow, college planning, retirement planning, tax
planning and estate planning and insurance.
Investment advice is provided, with the Advisor making the final decision on investment and
brokerage selection under a limited power of attorney. The client always maintains asset control
as their accounts are held by a qualified custodian. The Advisor does not take custody of or act
as a custodian of client assets.
Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the
client on an as-needed basis. Any conflicts of interest arising out of the Advisor, or its associated
persons are disclosed in this brochure.
Owners & Leadership
On October 1, 2025, the Advisor was acquired by Wealthspire Advisors LLC (“Wealthspire”), a
SEC-registered investment advisor wholly owned by NFP Corp. (previously known as National
Financial Partners Corp.) (“NFP”). Following the acquisition, the Advisor became a subsidiary of
Wealthspire. The Advisor intends to maintain a separate client brochure until such time as the
operations of Wealthspire and the Advisor are sufficiently integrated to merit a combined client
brochure.
Colin Drake is a Managing Director; Mike LaMena is the firm’s Chief Executive Officer; Eric
Sontag is the firm’s President and Chief Operating Officer; Michael Moriarty is the firm’s Chief
Investment Officer; Michael Del Priore is the firm’s Chief Compliance Officer; and Brian Powers
is the firm’s Chief Financial Officer.
Types of Advisory Services
The Advisor provides investment advice and management to individually managed accounts. The
Advisor holds a limited power of attorney to act on a discretionary basis with respect to these
accounts, however there are By All Accounts clients where the Advisor provides advice on a non-
discretionary basis. Client assets are deposited in a brokerage firm, usually Charles Schwab & Co.,
custodian account. Accounts are managed according to an Investment Policy Statement that is
developed between the Advisor and its clients. Most accounts are primarily comprised of mutual
funds, Exchange Traded Funds (“ETFs”) and some select securities although the Advisor generally
has the latitude to use a number of different security types to achieve client goals.
The Advisor also provides financial planning services in which associated persons of the Advisor
meet with clients to learn about their financial circumstances and identify their financial goals,
objectives, and risk tolerance. Based on these meetings, the Advisor makes appropriate financial
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planning recommendations. As part of a comprehensive financial plan, the Advisor will often
advise clients on matters of life, debt management, tax planning, estate planning, insurance review,
and other related topics, but does not provide accounting or legal advice. These services are
provided at the client’s request. The Advisor may offer to help client implement recommendations,
but client is under no obligation to accept any of the recommendations of the Advisor or purchase
securities or insurance products through the Advisor or its associated persons. When appropriate,
the Advisor may provide the client with recommendations of licensed insurance agents (some of
whom may be affiliated with parent company NFP) for the purchase of various types of insurance.
The Advisor does not accept or receive referral compensation from any of the firms to whom it
refers clients.
The Advisor uses a graduated compensation schedule for wealth advisory services and a fixed
price for financial planning-only services, however fees may be negotiated with the client on a
case-by case basis and the agreements may be terminated by either party with written notice. The
Advisor believes that its fees are competitive with fees charged by other investment Advisors for
comparable services, but these services may be available for lower fees than those that the Advisor
charges.
The Advisor engages in an investment Advisory business and manages more than one account.
Therefore, there may be conflicts of interest over the Advisor’s time devoted to managing any one
account and the allocation of investment opportunities among all accounts that it manages.
Advisors attempts to resolve all such conflicts in a manner that is generally fair to all of its clients.
Advisor may give advice and take action with respect to any of its clients that differs from the
advice that it gives or the timing or nature of the action that it takes with respect to another client
so long as it is Advisor’s policy, to the extent practicable, is to allocate investment opportunities
to its clients over time on a fair and equitable basis.
The Advisor shall provide research and analysis with regard to investment advice and fiduciary
due diligence services for the Client. The Advisor shall also provide research and analysis that
covers the investment products of several qualified and non-qualified retirement plan providers.
The goal of the investment due diligence process is to establish a logical, technical, and
comprehensive process that is consistently employed in the selection and ongoing monitoring of
funds for plan sponsors and individuals, accompanied by an investment policy statement (for plan
sponsors only), that defines the process utilized to recommend the investments to plan sponsors
and individuals.
For company retirement plan services, the Employer (Client of the Advisor) sponsors a qualified
(or nonqualified) Retirement Plan for the benefit of its employees. The Plan is a qualified or non-
qualified employee benefit plan intended to comply with all applicable federal laws and
regulations, including the Internal Revenue Code of 1986, as amended, and the Employee
Retirement Income Security Act of 1974 (ERISA), as amended, if applicable.
The Advisor may employ many different calculations, processes, and screening techniques to
arrive at specific recommended individual investments within the array of investments offered by
each investment provider that is being analyzed including but not limited to the following:
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•
Investment analysis by asset class (domestic equity, international equity, income,
hybrid/managed accounts), including market capitalization (small, medium, and large), and
investment objective (value, blend, and growth orientation)
• Performance relative to other investments in the same asset class
•
Investment performance relative to benchmark performance for the same asset class
• Style-based analysis to determine the impact of an investment being managed differently
than its stated investment objective (which is usually a combination of the stated market
capitalization category, and investment objective category)
• Common objective risk and return statistical measurements, such as Sharpe ratio, standard
deviation, alpha, and beta
• Common statistically relevant manager value measurements such as information ratio and
tracking error
In addition to providing investment advisory and financial planning services to individually
managed client accounts, the Adviser may, at times, bring clients (prospective investors) other
investment ideas (including but not limited to; private equity funds, limited partnerships, other
special purpose vehicles) that are outside of the scope of the client’s investment management
agreement. These outside investments are to be made by means of offering memoranda (or
similar), which the issuer will provide the prospective investors prior to investing and will contain
all material facts including additional risk factors relating to any such investment. These
prospective investors are advised to carefully review information in the offering memorandum and
consult with their own legal, accounting, tax and other advisors in order to independently assess
the merits of such an investment. While these outside investments are not formally part of the
client’s MFA managed assets, the Adviser fulfills its fiduciary obligation to the client by
conducting appropriate due diligence on each respective investment and disclosing all relevant
conflicts of interest. There is a potential for conflict as the Advisor or its representatives may have
an inherent interest in the success of the underlying investment. If/when a client decides to invest
in an opportunity that may relate to the interests of the advisor or its representatives, the firm will
make documented efforts to ensure any such outside investments are in-line with the fiduciary
duty of care & loyalty. More specifically, that Adviser: (a) ensures any such outside investment
is in the best interest of the client; (b) fulfills its obligation to subordinate its interest to that if the
client; and (c) has fully and fairly disclosed all material conflicts of interest that could impact the
relationship.
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's
Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing
the following acknowledgment to you.
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement
Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing
retirement accounts. The way we make money creates some conflicts with your interests, so we
operate under a special rule that requires us to act in your best interest and not put our interest
ahead of yours. Under this special rule's provisions, we must:
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• Meet a professional standard of care when making investment recommendations (give
prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give
loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
•
Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
As of December 31, 2024, the Advisor manages approximately $483,576,320 in assets for
approximately 518 accounts on a discretionary basis and $4,097,118 in assets for approximately
6 accounts on a non-discretionary basis.
Tailored Relationships
The goals and objectives for each client are documented in our client relationship management
system. Investment policy statements are created that reflect the stated goals and objective. Clients
may impose restrictions on investing in certain securities or types of securities.
Assignment of Investment Management Agreements
Agreements may not be assigned without the client’s consent.
Types of Agreements
The following agreements define the typical client relationships.
Financial Planning Agreement
The financial plan may include, but is not limited to: a net worth statement; a cash flow statement;
a review of investment accounts, including reviewing asset allocation and providing repositioning
recommendations; strategic tax planning; a review of retirement accounts and plans including
recommendations; a review of insurance policies and recommendations for changes, if necessary;
one or more retirement scenarios; estate planning review and recommendations; and education
planning with funding recommendations.
The financial planning service provided does not require that the client use or purchase the
investment Advisory services offered by the Advisor or any of the insurance products or other
products and services offered by the associated persons of the Advisor. There is an inherent
conflict of interest for the Advisor whenever a financial plan recommends the use of professional
investment management services or the purchase of insurance products or other financial products
or services. The Advisor or its associated persons may receive compensation for financial planning
and the provision of investment management services and/or the sale of insurance and other
products and services. The Advisor does not make any representation that these products and
services are offered at the lowest available cost and the client may be able to obtain the same
products or services at a lower cost from other providers. However, the client is under no
obligation to accept any of the recommendations of the Advisor or use the services of the Advisor
in particular.
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Investment Management Agreement
Realistic and measurable goals are set and objectives to reach those goals are defined. As goals
and objectives change over time, suggestions are made and implemented on an ongoing basis. The
Advisor periodically reviews a client’s financial situation and portfolio through regular contact
with the client, which often includes an annual meeting with the client. The Advisor makes use of
portfolio rebalancing software to maintain client allocations according to the Investment Policy
Statement in effect.
The scope of work and fee for an Advisory Service Agreement is provided to the client in writing
prior to the start of the relationship. The agreement sets forth the services to be provided, the fees
for the service and the agreement may be terminated by either party in writing at any time. Fees
may vary based on client needs and advisory services provided by the Advisor.
Asset Management
Investments in client portfolios may include mutual funds (shares), equities (stocks), corporate
debt securities, commercial paper, certificates of deposit, municipal securities, investment
company securities (variable life insurance, variable annuities, and U. S. government securities,
options contracts, and interests in partnerships.
Assets are invested primarily in no-load or low-load mutual funds and exchange-traded funds,
usually through brokers or fund companies. Fund companies may charge each fund shareholder
an investment management fee that is disclosed in the fund prospectus. Brokers may charge a
transaction fee for the purchase of some funds.
Stocks and bonds may be purchased or sold through a brokerage account when appropriate
whereby the brokerage firm charges a fee for stock and bond trades. The Advisor does not receive
any compensation from fund companies or brokerages.
Initial public offerings (IPOs) are not available through the Advisor.
WRAP Program
The Advisor does not sponsor or provide investment management services to a wrap program.
Termination of Agreement
A Client may terminate any of the aforementioned agreements at any time by notifying the Advisor
in writing. Clients shall be charged pro rata for services provided through to the date of termination.
If the client made an advance payment, The Advisor would refund any unearned portion of the
advance payment.
The Advisor may terminate any of the aforementioned agreements at any time by notifying the
client in writing. If the client made an advance payment, the Advisor would refund any unearned
portion of the advance payment.
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The Advisor reserves the right to terminate any financial planning engagement where a client has
willfully concealed or has refused to provide pertinent information about financial situations when
necessary and appropriate, in the Advisor’s judgment, to providing proper financial advice. Any
unused portion of fees collected in advance will be refunded.
Item 5-Fees and Compensation
Investment Management
The Advisor bases its fees on a percentage of assets under management, hourly charges, and fixed
fees. The length of service to the client is at the client’s discretion. Upon termination, fees will be
billed on a pro rata basis for the portion of the quarter completed. The portfolio value at the
completion of the prior full billing quarter is used as the basis for the fee computation, adjusted for
the number of days during the billing quarter prior to termination. The investment management
fees are negotiable at the sole discretion of the Advisor and may exceed the minimum annual
percentage due to additional advisory services provided.
Clients are charged an annual management fee based on account size according to the following
schedule:
Account Value To
$1,000,000
$2,000,000
$5,000,000
$10,000,000
Minimum Annualized Investment Management Fees
Account Value From
$0
$1,000,001
$2,000,001
$5,000,001
Over $10,000,001
Annual Percentage Fee
1.00%
0.75%
0.50%
0.40%
Negotiable
The Advisor provides advice to company 401(k) plans at the following fee schedule:
Plan Size
From
$0
$1,000,001
$5,000,001
$10,000,001
$20,000,001
$50,000,001
To
$1,000,000
$5,000,000
$10,000,000
$20,000,000
$50,000,000
$100,000,000
MFA Fee
0.90%
0.70%
0.60%
0.50%
0.40%
0.30%
The investment management fees for advice on 401(k) plans are negotiable at the sole discretion
of the Advisor. The Advisor may and has agreed to a fixed fee rather than a fee based on assets
under management for this service. The client for this service is generally billed in arrears,
however at its discretion the Advisor may agree to other billing arrangements. Should a 401(k)
plan terminate, any fees taken in advance will be reimbursed pro rata for the time period that
services are provided.
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Financial Planning
The Advisor may charge an additional hourly fee for complex financial planning advice that goes
beyond that which is typically included in the investment management fee. The hourly rate, which
is negotiable at the sole discretion of the Advisor, is determined by the extent and complexity of
the plan. Alternatively, the client and The Advisor can agree upon a fixed rate for the plan. In the
case of a fixed rate, The Advisor will charge an up-front retainer of at least $1,500 or up to half of
the fixed rate fee whichever is greater, with the balance due upon the plan’s completion. Planning
fees generally range from $3,000 or more for the first six months with the fee being determined by
the extent and complexity of the plan. Fees for financial planning are negotiable for larger
accounts, multiple accounts or at the discretion of The Advisor. Financial planning agreements
may be terminated upon written notice by the client or the Advisor. Fees paid in advance for
financial planning are not refundable if the agreed upon work has been completed. If the client
terminates the agreement before The Advisor’s work is completed, fees will be refunded pro-rata
based upon how much of the work has been completed.
Item 6-Performance Fees
Performance Fees
Fees are not based on a share of the capital gains or capital appreciation of managed securities.
However, the Advisor may employ certain types of investments that do charge a performance fee
in which the Advisor does not participate. For these investments, refer to their offering or private
placement memorandum for an explanation and amounts of the performance fees.
Fee Billing
Investment management fees for wealth management clients are billed quarterly, in arrears,
meaning that we invoice you after the three-month billing period has ended. Payment in full is
expected upon invoice presentation. Fees are deducted from the client account to facilitate billing
as authorized by the investment management agreement. Arrangements may be made for advance
or invoice billing at the sole discretion of Advisor.
Other Fees
The Advisor may include mutual funds, variable annuity products, ETFs, and other managed
products or partnerships in clients’ portfolios. Clients may be charged for the services by the
providers/managers of these products in addition to the management fee paid to the Advisor. The
Advisor, from time to time, may select or recommend to separately managed clients the purchase
of proprietary investment products. The fees and expenses charged by the product providers are
separate and distinct from the management fee charged by the Advisor. These fees and expenses
are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering
memorandums of a partnership. These fees will generally include a management fee, other fund
expenses and a possible distribution fee. No-load or load waived mutual funds may be used in
client portfolios so there would be no initial or deferred sales charges; however, if a fund that
imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client
could invest in a mutual fund or variable annuity or investment partnership directly, without the
services of the Advisor. Accordingly, the client should review both the fees charged by the funds
and the applicable program fee charged by the Advisor to fully understand the total amount of fees
to be paid by the client and to thereby evaluate the Advisory services being provided. If it is
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determined that a client portfolio shall contain corporate debt or other types of over-the-counter
securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the
other side of the transaction that is built into the purchase price of the security.
Item 7-Types of Clients
Description
The Advisor generally provides investment advice to individuals, pension and profit-sharing plans,
trusts, estates, or charitable organizations, and corporations or business entities. Client
relationships vary in scope and length of service.
Account Minimums
The Advisor generally requires a minimum account size of $1,000,000 of assets under
management. The Advisor has the sole discretion to waive the account minimum.
Item 8-Methods of Analysis, Investment Strategies and
Risk of Loss
Methods of Analysis and Investment Strategies
Portfolio construction is based on research originally done by Dimensional Fund Advisors of
Austin, TX. The investment strategy is based on “three factor analysis” commonly referred to as
Fama-French three factor analysis (named after the academics who did the original research) and
is generally tilted toward small cap and value stocks (as well as toward highly profitable stocks).
Advisors also invest in companies domiciled outside the US through mutual funds and ETFs.
Advisors primarily rely upon the financial press for information and has no source of inside
information. Advisor subscribes to academic research, fund company research and to various
publications and information services such as Morningstar, Financial Planning Magazine,
Financial Advisor, Investment News and others. Advisor also attends various meetings and
conferences throughout the year to keep current on issues such as investments, tax and retirement
plans. While the Advisor takes a long-term investment approach, accounts are set up to allow
short-term liquidity. Leverage (margin borrowing) is not employed as an investment strategy but
is often added to accounts as a feature to enable some convenience for client cash flow, expenses
and tax management issues.
Investment Strategies
Portfolio strategies may include long-term purchases, short-term purchases, margin transactions,
and option writing. The primary investment strategy used in client accounts is a strategic asset.
Portfolios are globally diversified to control the risk associated with traditional markets.
The investment strategy for a specific client is based upon the objectives stated by the client during
consultations. The client may change these objectives at any time. Each client is asked to execute
an Investment Policy Statement that documents their objectives and their desired investment
strategy. The Advisor’s strategies do not involve frequent trading.
Market, Security and Regulatory Risks
All investment programs have certain risks that are borne by the investor. Our investment
approach constantly keeps the risk of loss in mind. Investors face the following investment risks:
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Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For
example, when interest rates rise, yields on existing bonds become less attractive, causing their
market values to decline.
Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and
intangible events and conditions. This type of risk is caused by external factors independent of a
security’s particular underlying circumstances. For example, political, economic and social
conditions may trigger market events.
Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a
dollar next year, because purchasing power is eroding at the rate of inflation.
Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against
the currency of the investment’s originating country. This is also referred to as exchange rate risk.
Reinvestment Risk: This is the risk that future proceeds from investments may have to be
reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed
income securities.
Business Risk: These risks are associated with a particular industry or a particular company within
an industry. For example, oil-drilling companies depend on finding oil and then refining it, a
lengthy process, before they can generate a profit. They carry a higher risk of profitability than
an electric company, which generates its income from a steady stream of customers who buy
electricity no matter what the economic environment is like.
Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally,
assets are more liquid if many traders are interested in a standardized product. For example,
Treasury Bills are highly liquid, while real estate properties are not.
Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of
profitability, because the company must meet the terms of its obligations in good times and bad.
During periods of financial stress, the inability to meet loan obligations may result in bankruptcy
and/or a declining market value.
Item 9-Disciplinary Information
Legal and Disciplinary
The firm and its employees have not been involved in legal or disciplinary events related to past
or present investment clients.
Item 10-Other Financial Activities and Affiliations
Other Financial Industry Activities and Affiliations
The Advisor is not registered as a securities broker-dealer, nor is involved in any other business other than
providing investment advice to its clients.
On October 1, 2025, the Advisor was acquired by Wealthspire, a SEC-registered investment advisor wholly
owned by NFP. Following the acquisition, the Advisor became a subsidiary of Wealthspire. The Advisor
intends to maintain a separate client brochure until such time as the operations of Wealthspire and the
Advisor are sufficiently integrated to merit a combined client brochure.
The Advisor is indirectly owned by NFP, a provider of benefits, insurance and wealth management services.
NFP also owns other registered investment advisers, broker-dealers, insurance agencies and other product
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and service providers. The Advisor is under no obligation to sell any products or recommend any services
to our clients as a result of NFP’s ownership. With the exception of the recent acquisition by Wealthspire,
the referral relationship with NFP Retirement, Inc., and occasionally referring clients to insurance agents
affiliated with NFP, the Advisor does not conduct any business with any other NFP-affiliated entities (“NFP
Affiliates”). Please Note: A full list of NFP Affiliates is available upon request. The Advisor’s parent
company, Wealthspire, has also entered into a referral agreements with NFP Retirement, Inc., Fiducient
Advisors LLC, and Kestra Advisory Services, LLC (“Kestra”). Certain NFP Affiliate employees offer
advisory services through Kestra.
Item 11-Code of Ethics, Participation in Client
Transactions and Personal Trading
Code of Ethics
The Advisor has adopted a Code of Ethics which establishes standards of conduct for the Advisor’s
supervised persons. The Code of Ethics includes general requirements that such supervised persons
comply with their fiduciary obligations to clients and applicable securities laws, and specific
requirements relating to, among other things, personal trading, insider trading, conflicts of interest
and confidentiality of client information. It requires supervised persons to report their personal
securities transactions and holdings quarterly to the Advisor’s Compliance Officer and requires
the Compliance Officer to review those reports. It also requires supervised persons to report any
violations of the Code of Ethics promptly to the Advisor’s Compliance Officer. Each supervised
person by the Advisor receives a copy of the Code of Ethics and any amendments to it and must
acknowledge in writing having received the materials. Annually, each supervised person must
certify that he or she complied with the Code of Ethics during that year. Clients and prospective
clients may obtain a copy of the Advisor’s Code of Ethics by contacting the Compliance Officer
of the Advisor. Under the Advisor’s Code of Ethics, the Advisor and its managers, members,
officers and employees may invest personally in securities of the same classes as are purchased
for clients and may own securities of the issuers whose securities are subsequently purchased for
clients.
If an issue is purchased or sold for clients and any of the Advisor, managers, members, officers
and employees on the same day purchase or sell the same security, either the clients and the
Advisor, managers, members, officers or employees shall receive or pay the same price or the
clients shall receive a more favorable price. The Advisor and its managers, members, officers and
employees may also buy or sell specific securities for their own accounts based on personal
investment considerations, which the Advisor does not deem appropriate to buy or sell for clients.
Clients and prospective clients may obtain a copy of the Advisor’s Code of Ethics by contacting
Advisor. The employees of The Advisor have committed to a Code of Ethics. The firm will
provide a copy of the Code of Ethics to any client or prospective client upon request.
Participation or Interest in Client Transactions
Under the Advisor’s Code of Ethics, the Advisor and its managers, members, officers and
employees may invest personally in securities of the same classes as are purchased for clients and
may own securities of the issuers whose securities are subsequently purchased for clients. If an
issue is purchased or sold for clients and any of the Advisor, managers, members, officers and
employees on the same day purchase or sell the same security, either the clients and the Advisor,
managers, members, officers or employees shall receive or pay the same price or the clients shall
receive a more favorable price. The Advisor and its managers, members, officers and employees
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may also buy or sell specific securities for their own accounts based on personal investment
considerations which the Advisor does not deem appropriate to buy or sell for clients.
Personal Trading
The Chief Compliance Officer of the Advisor is Michael Del Priore. The Wealthspire Compliance
Team monitors all employee trades. The personal trading reviews ensure that the personal trading
of employees does not affect the markets and that clients of the firm receive preferential treatment.
Item 12-Brokerage Practices
Brokerage Selection and Soft Dollars
For our clients’ accounts that Schwab maintains, Schwab generally does not charge you
separately for custody services but is compensated by charging you commissions or other fees
on trades that it executes or that settle into your Schwab account. Certain trades (e.g., mutual
funds or ETFs) do not incur Schwab commissions or transaction fees. Schwab is also
compensated by earning interest on the uninvested cash in your account in Schwab’s Cash
Features Program. For some accounts, Schwab charges you a percentage of the dollar amount
of assets in the account in lieu of commissions. In addition to commissions and asset-based fees,
Schwab would charge you a flat dollar amount as a “prime broker” or “trade away” fee for each
trade that, if applicable, a TPAM executes for our clients at a different broker- dealer, but where
securities bought or the funds from securities sold are deposited (settled) into your Schwab
account. These fees would be in addition the commissions or other compensation you pay the
executing broker-dealer. Because of this, in order to minimize your trading costs, we seek and
encourage you and your IAR to execute trading costs through the Schwab (or other custodians
that you may utilize as part of our service). Trading away can sacrifice best execution and incur
additional costs from the other firm, as well as fees from our custodians to transfer in those
positions.
Products and Services Available to Us From Schwab
Schwab Adviser ServicesTM serves independent investment advisory firms like us. They
provide our clients with access to their institutional brokerage services (trading, custody,
reporting and related services), many of which are not available to Schwab retail customers.
However, certain retail investors may be able to get institutional brokerage services from
Schwab without going through us. Schwab also makes available various support services. Some
of those services help us manage and grow our business. Schwab’s support services are
generally available on an unsolicited business (we do not have to request them) and at no cost
to us. The following material provides a more detailed description of Schwab support services.
Services that benefit you.
Schwab institutional brokerage services include access to a broad range of investment products,
execution of securities transactions and custody of client assets. The investment products made
available through Schwab include some of which you might not otherwise have access to or
that would require a significantly higher minimum initial investment by our clients. Schwab’s
services described in this paragraph generally benefit you and your account.
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Services that do not directly benefit you.
Schwab also makes available to use other products and services that benefit us but do not
directly benefit you and or your account. These products and services assist us in managing
and administering our clients’ accounts and operating our firm. They include investment
research, both Schwab’s own and that of 3rd parties. We use this research to service all or a
substantial number of our clients’ accounts, including accounts not maintained in Schwab. In
addition to investment research, Schwab also makes available software and other technology
that:
• Provide access to client account data (such as duplicate trade confirmations and
account statements)
• Facilitate trade execution and allocate aggregated trade orders for multiple client
accounts
• Provide pricing and other market data
• Facilitate payment of our fees from other clients’ accounts
• Assist with back-office functions, recordkeeping, and client reporting
We do not open accounts for you, although we may assist you in doing so. To the extent that
your account is maintained at Schwab, and most trades may occur through Schwab or such other
designated custodian, such custodians have the ability to use other brokers to execute trades
for your account.
Your Brokerage and Custody Costs
For our client’s accounts that Schwab maintains, Schwab generally does not charge you
separately for custody services but is compensated by charging you commissions or other fees
on trades that it executes or that settle into your Schwab account. Certain trades (for example,
mutual funds and ETDs) do not incur Schwab commissions or transaction fees. Schwab is also
compensated by earning interest on the uninvested cash in your account in Schwab’s Cash
Features Program. For some accounts, Schwab charges you a percentage of the dollar amount
of the assets in the account in lieu of commissions.
Services that generally benefit only us.
Schwab also offers other service intended to help us manage and further develop our business
enterprise. They services include:
• Educational conference and events;
• Consulting on technology and business needs;
• Consulting on legal and compliance-related needs;
• Publications and conferences on practice management and business succession;
• Access to employee benefits providers, human capital consultants and insurance
providers; and
• Marketing consulting and support.
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We intend to use the benefit to covers some of the costs of its annual sales and due diligence
conference for our investment advisory personnel and supervised persons. This is being
included as a conflict of interest. It serves as an incentive to use Schwab over other custodians.
Schwab provides some of these services itself. In other cases, it will arrange for 3rd party
vendors to provide the services to us. Schwab also discounts or waives its fees for some of these
services or pays all or part of the 3rd party fees. Schwab may also provide us with other benefits,
such as occasional business entertainment for our personnel.
Our interest in Schwab’s services, as well as the service of other Custodians.
The availability of these services from Schwab benefits us because we do not have to produce or
purchase them. We don’t have to pay for Schwab’s ancillary services. Schwab has also agreed to
pay for certain technology, research, marketing, and compliance consulting products and services
on our behalf. The fact that we receive these benefits from Schwab is an incentive for us to
recommend/request the use of Schwab rather than making such a decision based exclusively
on your interest in receiving the best value in custody services and the most favorable execution
of your transactions. This is a conflict of interest. We believe, however, that taken in the aggregate,
whichever custodian we use, our selection of the custodians, whether Schwab or otherwise, as
custodian and broker is driven by the Best Interest of our clients. Our selection is primarily
supported by the scope, quality, and price of custodian’s services and not service that benefits only
us.
Order Aggregation
The nature of the clients and/or trading activity on behalf of client accounts are such that trade
aggregation does not garner any client benefit (in regard to mutual fund or exchange traded funds
for example).
Directing Brokerage for Client Referrals
The Advisor and its associated persons do not receive client referrals from broker dealers or third
parties as consideration for selecting or recommending brokers for client accounts.
Item 13- Review of Accounts
Periodic Reviews
Accounts are monitored on a daily basis utilizing rebalancing software. Additionally, Advisor
attempts to meet annually with clients. They consider the client's current security positions and
the likelihood that the performance of each security will contribute to the investment objectives of
the client.
Review Triggers
While accounts are monitored on a daily basis through the rebalancing software, the Advisors will
meet with clients more frequently as personal circumstances or market conditions dictate. Other
conditions that may trigger a review are changes in the tax laws, new investment information, and
changes in a client's financial or personal situation.
Regular Reports
Individually managed accounts receive monthly reports from the custodian and quarterly reports
from the Advisor. Advisor reviews are typically distributed in the first 30 days following the end
of the calendar quarter. As an alternative, Advisor reviews may be conducted in person at the
Advisor's office. Reviews include a listing of all values of assets managed by the Advisor plus
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performance reviews of each asset. The reviews may also include graphs showing the allocation
of assets by type in the client portfolio.
Item 14-Client Referrals and Other Compensation
Incoming Client Referrals
The Advisor from time to time may receive client referrals which may come from current clients,
estate planning attorneys, accountants, employees, personal friends of employees and other similar
sources. The firm does not compensate referring parties for these referrals.
Referrals to Third Parties
The Advisor does not accept referral fees or any form of remuneration from other professionals
when a prospect or client is referred to them.
Item 15-Custody
Custody Policy
The Advisor does not accept or permit the Firm or its associated persons to obtain custody of client
assets including cash, securities, acting as trustee, or providing bill paying service, have password
access to control account activity or any other form of controlling client assets. All checks or wire
transfer to fund client accounts are required to be made out to/sent to the account custodian.
Account Statements
All assets are held by qualified custodians and the custodians provide account statements not less
than quarterly to clients at their address of record. Clients should carefully review such statements
for any discrepancies or inaccuracies.
Performance Reports
Pursuant to recent amendments to Rule 206(4) under the Investment Advisors Act of 1940, the
Securities and Exchange Commission now requires Advisors to urge clients to compare the
information set forth in their statement from the Advisor with the statements received directly from
the custodian to ensure accuracy of all account transactions.
Item 16- Investment Discretion
Discretionary Authority for Trading
The Advisor accepts new accounts usually only when it is given full investment discretion. The
firm's discretionary authority regarding investments may however be subject to certain
limitations. These limitations are recognized as the restrictions and prohibitions placed by
the Client on transactions in certain types of business or industries. All such restrictions are to be
agreed upon in writing at the account's inception. Under certain circumstances, the Advisor
provides advice on By All Accounts clients and does not have discretion whereby the Advisor
must obtain authorization to trade on behalf of those clients.
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Item 17-Voting Client Securities
Proxy Votes
The Advisor will not vote nor advise clients how to vote proxies for securities held in client
accounts. The client clearly keeps the authority and responsibility for the voting of these proxies.
The Advisor does not give any advice or take any action with respect to the voting of these proxies.
For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974
(“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of
any proxies for securities held in plan accounts. The Advisor promptly passes along any proxy
voting information to the clients or their representatives. However, where required by regulation
or law in regard to an ERISA account the Advisor will vote proxies and retain records of how
voted and supporting documentation on the vote. Any account subject to having proxies voted by
the Advisor may request a copy of the voting records from Michael Del Priore, the Chief
Compliance Officer.
Item 18-Financial Information
Financial condition
The Advisor does not have any financial impairment that will preclude the firm from meeting
contractual commitments to clients and the Advisor meets all net capital requirements that it may
be subject to. The Advisor has not been the subject of a bankruptcy petition in the last 10 years.
The Advisor is not required to provide a balance sheet as it does not serve as a custodian for client
funds or securities and does not require prepayment of fees of more than $1,200 per client, and six
months or more in advance.
Business Continuity Plan
General
The Advisor has a Business Continuity Plan in place that provides detailed steps to mitigate and
recover from the loss of office space, communications, services or key people.
Disasters
The Business Continuity Plan covers natural disasters such as earthquakes, hurricanes, tornados,
and flooding. The Plan covers man-made disasters such as loss of electrical power, loss of water
pressure, fire, bomb threat, nuclear emergency, chemical event, biological event, T-1
communications-line outage, Internet outage, railway accident and aircraft accident. Electronic
files are backed up daily and archived offsite.
Alternate Offices
Alternate offices are identified to support ongoing operations in the event the main office is
unavailable. It is our intention to contact all clients within five days of a disaster that dictates
moving our office to an alternate location.
Summary of Business Continuity Plan
A summary of the business continuity plan is available upon request to the Advisor’s Chief
Compliance Officer.
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Information Security Program
Information Security
The Advisor maintains an information security program to reduce the risk that your personal and
confidential information may be breached.
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Privacy Practices
Our Privacy Policy
Our Commitment to You
Marin Financial Advisors 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. Marin
Financial Advisors (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.
Marin Financial Advisors 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 do 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?
Social security or taxpayer identification number
Name, address and phone number[s]
E-mail address(es)
Account information (including other institutions)
Assets and liabilities
Income and expenses
Investment activity
Investment experience and goals
Other similar data
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
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Account applications and forms
Investment questionnaires and suitability documents
Other information needed to service accounts
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
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
Marin Financial Advisors does not disclose, and does not intend to
disclose, personal information with non-afffiliated 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 Marin Financial Advisors 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].
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No
Not Shared
Information About Former Clients
Marin Financial Advisors 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.
State-specific Regulations
California
In response to a California law, to be conservative, we assume accounts with
California addresses do not want us to disclose personal information about you to non-
affiliated third parties, except as permitted by California law. We also limit the
sharing of personal information about you with our affiliates to ensure compliance
with California privacy laws.
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 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 (415) 925-1212 or via email us at compliance@wealthspire.com.
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Firm Brochure
(Part 2B of Form ADV)
Marin Financial Advisors, LLC
80 E. Sir Francis Drake Blvd 1A
Larkspur, CA 94939
Tel: (415) 925-1212
Fax: (415) 707-6500
WWW.MARINFA.COM
OCTOBER 2025
This brochure provides information about principals and Advisor representatives of Marin
Financial Advisors, LLC and this brochure supplements the Marin Financial Advisors, LLC
brochure. You should have received a copy of that brochure. Please contact Michael Del Priore
at (415) 925-1212, or by email at: compliance@wealthspire.com if you did not receive Marin
Financial Advisors, LLC brochure or if you have any questions about the contents of this
supplement. The information in this brochure has not been approved or verified by the United
States Securities and Exchange Commission, or by any state securities authority.
Additional information about principals and Advisor representatives of Marin Financial Advisors,
LLC is available on the SEC’s website at www.Advisorinfo.sec.gov.
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Colin B. Drake, CFP
Year of birth: 1969
Item 2-Educational Background:
Marin Financial Advisors, LLC requires that associated persons have a bachelor's degree and
further coursework demonstrating knowledge of financial planning and tax planning.
• Mr. Drake attended Middlebury College, graduating in 1991, earning a Bachelor of Arts
degree in Psychology.
• As of 2000, Mr. Drake holds the Certified Financial Planner (CFP®) certification. The
certification is a voluntary certification; no federal or state law or regulation requires
financial planners to hold CFP® certification. It is recognized in the United States and a
number of other countries for its (1) high standard of professional education; (2) stringent
code of conduct and standards of practice; and (3) ethical requirements that govern
professional engagements with clients.
• Mr. Drake has held the designation of Registered Life Planner (RLP®) since 2009. RLP®
is a professional designation administered by the Kinder Institute of Life Planning. In order
to obtain the RLP® designation, a candidate must take several courses related to life
planning and money maturity, followed by a mentor-run six-month case study of a real-life
planning case.
Employment:
• Marin Financial Advisors, LLC, Principal, 2018 to Present
• Drake Wealth Management, LLC, Principal 2012 to February 2018
Items 3 & 7-Disciplinary Information: As it relates to past, current or prospective clients, Mr.
Drake has not been involved in legal or disciplinary events, has not been involved in arbitrations,
has not been subject to self-regulatory organization or administrative proceedings and has not
filed or planning to file a bankruptcy petition.
Item 4-Other Business Activities: Mr. Drake is not actively engaged in any other investment-
related businesses or occupations. He is not actively engaged in any non-investment-related
business or occupation for compensation.
Item 5-Additional Compensation: In the course of business Mr. Drake does not receive
economic benefit from non-clients for providing advisory services. Mr. Drake does not receive
financial benefit from outside business activities.
Item 6-Supervision: Michael Del Priore is the Chief Compliance Officer for Marin Financial
Advisors, LLC and is responsible for supervision of Mr. Drake’s investment advisory activities
to ensure compliance with regulatory and internal procedures. His contact information is available
on the cover page of this brochure.
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