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Item 1-Cover Page
Mariner Independent Advisor Network, LLC
also doing business as Mariner Advisor Network
Nall Corporate Centre II
5700 W. 112th Street, Suite 500
Overland Park, KS 66211
(650) 571-1934
Form ADV Part 2A
March 29, 2025
www.marineradvisornetwork.com
This Brochure provides information about the qualifications and business practices of Mariner
Independent Advisor Network, LLC, also doing business as Mariner Advisor Network (the
“Network,” the “Firm,” “Registrant,” “us,” “we,” or “our”) (CRD # 283824). If you have any
questions about the contents of this Brochure, please contact us at (650) 571-1934. The information
in this Brochure has not been approved or verified by the United States Securities and Exchange
Commission (“SEC”) or by any state securities authority. The Firm is a registered investment
adviser. Registration of an investment adviser does not imply a certain level of skill or training. The
oral and written communications of an Adviser provide you with information through which you
determine to hire or retain an Adviser.
information about
the Firm
is also available via
the SEC’s website at
Additional
www.adviserinfo.sec.gov.
Mariner Independent Advisor Network, LLC-Form ADV Part 2A
March 29, 2025
1
Item 2-Material Changes
This Item 2 discusses only specific material changes that were made to this Brochure since the last
annual update of our Brochure on March 31, 2024. It does not describe other modifications to this
Brochure, such as updates to dates and numbers, stylistic changes or clarifications.
•
Item 4 Advisory Business - Updated to reflect our current ownership structure as well as to
reflect the various services offered to our clients.
•
Item 5 Fees and Compensation - Updated to reflect certain billing processes and fees for
different strategies and services and to add disclosure regarding employee referrals and fees
for new products and services.
•
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss - Updated to included
additional strategies and risks.
•
Item 10 Other Financial Industry Activities and Affiliations - Updated to reflect changes to our
affiliations and services provided through our affiliates.
•
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading -
Updated with additional disclosure regarding participation or interest in client transactions.
•
Item 14 Client Referrals and Other Compensation - Updated to reflect changes associated with
the Firm’s Enterprise Partnership Alliance Program.
The Network encourages each client to read this Brochure carefully and to call us with any questions
you can or will have.
Pursuant to SEC Rules, we will ensure that you receive a summary of any material changes to this
and subsequent Brochures within 120 days of the close of our business’ fiscal year. We may provide
other ongoing disclosure information about material changes as necessary.
We will provide you with a new Brochure if requested based on changes or new information, at any
time, without charge. Currently, our Brochure may be
requested by contacting
compliance@marineradvisornetwork.com.
Mariner Independent Advisor Network, LLC-Form ADV Part 2A
March 29, 2025
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Item 3-Table of Contents
Item 1-Cover Page .................................................................................................................................. 1
Item 2-Material Changes ........................................................................................................................ 2
Item 3-Table of Contents ........................................................................................................................ 3
Item 4-Advisory Business ....................................................................................................................... 4
Item 5-Fees and Compensation ........................................................................................................... 23
Item 6-Performance Based Fees and Side-By-Side Management..................................................... 32
Item 7-Types of Clients ......................................................................................................................... 33
Item 8-Methods of Analysis, Sources of Information, Investment Strategies, and Risk of Loss ... 34
Item 9-Disciplinary Information ......................................................................................................... 47
Item 10-Other Financial Industry Activities and Affiliations .......................................................... 48
Item 11-Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading .................................................................................................................................................. 54
Item 12-Brokerage Practices ................................................................................................................ 57
Item 13-Review of Accounts ................................................................................................................. 65
Item 14-Client Referrals and Other Compensation .......................................................................... 66
Item 15-Custody .................................................................................................................................... 71
Item 16-Investment Discretion ............................................................................................................ 72
Item 17-Voting Client Securities ......................................................................................................... 73
Item 18-Financial Information ............................................................................................................. 74
Mariner Independent Advisor Network, LLC-Form ADV Part 2A
March 29, 2025
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Item 4-Advisory Business
Firm Description
Mariner Independent Advisor Network, LLC is registered with the SEC as a registered investment
adviser. We are a limited liability company formed in the State of California. Our firm has been in
business as an investment adviser since 2016.
Principal Owners
The Firm is 100% owned by Honor Bound Partners, LLC (“HBP”). HBP is wholly owned by
Mariner Platform Solutions, LLC (“MPS”). MPS is wholly owned by Mariner Advisor Network,
LLC (“MAN”). MAN is wholly owned by Mariner Wealth Advisors, LLC (referred to herein as
“Mariner”). In turn, Mariner is ultimately owned in principal by 1248 Holdings, LLC (“1248”) and
the Martin C. Bicknell Revocable Trust dated August 7, 1996, as amended and restated, each of
which are controlled by Martin Bicknell, the CEO and President of the Mariner, as well as entities
affiliated with Leonard Green & Partners, LLC (together with its affiliates, “LGP”) and NB
Alternative Advisors (together with its affiliates, “NBAA”), each of which operate separately from
the Mariner.
Services Offered
The Firm’s business model is based on a decentralized network of Investment Adviser
Representatives (“IARs”) doing business in disparate offices located in numerous states and cities.
Although all IARs are registered with, and subject to oversight by the Firm, they operate their
businesses independently. In addition, the majority of the IARs are also registered representatives
affiliated with LPL Financial (“LPL”), an independent broker-dealer and custodian. While the Firm
uses a brand DBA of Mariner Advisor Network, most IAR offices work under a separate “doing
business as” name (“DBA”) in their local community. IARs associated with the Firm can provide
IAR services to clients under a DBA name that is owned and registered by one or more IARs. As
such, in these circumstances, marketing materials provided to clients and prospective clients include
the DBA name and the logo associated with the DBA name. The Firm reviews and approves marketing
materials related to the IAR or investment advisory services offered and provided to clients.
The Firm supervises IARs in the performance of their IAR duties whether the services are performed
under their own name or a DBA name. If approved by the Firm and LPL and properly disclosed as
an outside business activity of the IAR, the Firm allows IARs to provide other products and services
through their DBA (such as insurance or Certified Public Accounting services) which are unrelated
to the Firm’s investment advisory business. These outside business activities are not associated with
or supervised by the Firm.
IARs have significant flexibility in providing individualized investment advice to clients. The Firm
assists the IARs with marketing, back-office functions and regulatory compliance responsibilities.
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March 29, 2025
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For a list of our DBAs, please refer to Schedule D in Section 1.B (Other Business Names) of Form
ADV Part 1, which can be found on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov.
The Firm will maintain the direct contractual relationship with each client and obtain, through such
agreements, the authority to engage independent third-party managers or other service providers, as
applicable, for services rendered through the platform in service of such client.
Investment Advisory Services
Through the Firm, IARs provide personal financial planning, reporting, consulting, and investment
advisory services to individuals, pension and profit-sharing plans, trusts, estates, charitable
organizations, corporations, and business entities. IARs employ a variety of investment strategies
when working with clients to construct a client’s portfolio. Investment management and advisory
services are generally offered for a fee based on assets under management or advisement as further
described in the agreement with the client. In certain cases, IARs provide financial planning,
reporting and/or consulting services for an additional fee, which can be based on a percentage of
assets or a flat or hourly rate.
Typically, when providing investment advisory services, we have full discretion to select securities
to buy and sell for a client’s account. However, from time-to-time clients impose reasonable
restrictions, limitations or other requirements with respect to their individual accounts. IARs work
with each client in order to tailor their accounts to address their specific goals, objectives and
constraints. IARs consider a range of factors that can impact the investment management process,
including risk tolerance, investment time horizon, current and future cash needs and such other
circumstances deemed relevant.
For clients of IARs utilizing model portfolios provided by the Firm, the Firm constructs investment
models using an appropriate mix of mutual funds or exchange traded funds, with asset allocation
determined based on the risk level of each respective model. The IAR works with the client to
understand the client’s objectives, goals, risk tolerance, constraints, and other relevant criteria, and
will select the appropriate model(s) based upon this review. The Firm is supported by the investment
resources of its affiliate, Mariner, LLC (“Mariner Wealth”). This includes access to equity, options,
structured notes, and fixed income strategies. Additionally, IARs have access to strategies and
models developed and managed by other third-party investment managers for use in client accounts.
Alternatively, certain IARs of the Firm who determine not to utilize the models developed by the
Firm will instead create a customized portfolio management program geared toward the client’s
specific investment goals, in a discretionary fashion. In this scenario, the IAR acts as the client’s
portfolio manager and is responsible for investment oversight and due diligence, allocation
decisions, rebalancing, and risk management, without the structure provided by the Firm’s
investment models. Utilizing information obtained regarding the client’s objectives, goals, risk
tolerance, constraints, and other relevant criteria, the IAR will determine the specific investments to
utilize in a client’s portfolio.
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March 29, 2025
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We also provide our clients with access to third-party managers (each a “third-party manager”), and
their investment products and services, including third-party managers in which the principal
owners of Mariner or an affiliate holds a direct or indirect ownership stake. This service provides
clients access to a wide range of investment opportunities and asset classes, including international
equities, emerging market equities, global fixed income, high-yield fixed income, private equity,
commodities, hedge funds, digital assets, structured notes and real assets. By combining third-party
managers with our in-house resources, we seek to optimize our customized portfolio management
capabilities for clients. Unless otherwise set forth in the third- party manager’s agreement, the third-
party manager shall have discretionary authority for the day-to-day management of the assets that
are allocated to it by the Firm or the client. The third- party manager shall continue in such capacity
until such arrangement is terminated or modified by the Firm. For certain accounts, the Firm utilizes
private funds (including through access to a platform which provides access to various alternative
investments), third-party providers of unified managed accounts, separately managed accounts and
model programs to access third- party money managers.
We also utilize the services of various broker-dealers/custodians through which we gain access to
asset allocation planning software, execution, clearing and custodial services in order to provide
comprehensive investment management of client assets (“Direct Asset Management Services”). The
software enables IARs to conduct and capture risk tolerances, complete investment analysis,
consolidate investment data, conduct portfolio optimization and access re-balancing tools. See Item
12, Brokerage Practices, for more information about our use of Soft Dollar benefits.
Clients have ready access to their IAR during normal business hours. IARs are not required to be
available for unscheduled visits by clients. However, IARs will periodically meet with clients and
generally are available to take client telephone calls regarding advisory-related matters.
In performing its services, the Firm and its IARs shall not be required to verify any information
received from the client or from the client’s other professional advisers, and we and our IARs are
expressly authorized to rely on such information. Moreover, each client is advised that it remains
his/her/its responsibility to promptly notify the Firm if there is ever any change in his/her/its
financial situation, investment objectives or risk tolerance, for the purpose of reviewing, evaluating
or revising Registrant’s previous recommendation and/or services.
Below is a description of custodians and related account platforms used to provide Direct
Asset Management Services.
LPL Managed Account and Asset Allocation Programs
The following LPL Financial (“LPL”) sponsored platforms are offered to our clients; (please note
that fees associated with these platforms are detailed in Item 5):
• Strategic Wealth Management (“SWM”) - The SWM platform is an open architecture, fee-
based investment platform. Through this platform, clients can consolidate multiple
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investments into one account and receive one statement. There is no minimum account size
required for utilizing the SWM platform. The platform is available in two forms, the
selection of which is mutually determined at the inception of the engagement:
o SWM – client pays both the advisory fee and all transaction costs.
o SWM II – client pays an advisory fee and transaction costs are included in a
single fee that covers both advisory fees and transaction costs, the latter of
which is paid by the adviser.
• Model Wealth Portfolios (“MWP”) – The MWP platform is a professionally managed
mutual fund and exchange-traded fund (“ETF”) asset allocation program. Our IARs will
initiate the steps necessary to open an MWP account and have discretion to select a model
portfolio designed by LPL’s Research Department or a third-party investment strategist,
consistent with the client’s stated investment objective. LPL’s Research Department or
third-party portfolio strategists are responsible for selecting the mutual funds or ETFs within
a model portfolio and for making changes to the mutual funds or ETFs selected. The client
will authorize LPL to act on a discretionary basis to purchase and sell mutual funds and ETFs
and to liquidate previously purchased securities. The client will also authorize LPL to effect
rebalancing for MWP accounts. MWP requires a minimum asset value for a program account
to be managed, and the minimums vary depending on the portfolio(s) selected and the
account’s allocation amongst portfolios. The lowest minimum for a portfolio is $25,000. In
certain instances, a lower minimum for a portfolio is permitted.
• Optimum Market Portfolios (“OMP”) - The OMP platform is a managed mutual fund asset
allocation platform. Clients invest in one or more model portfolios designed by LPL’s
Research Department, which consist of up to six mutual funds from the Optimum Family of
Funds.
• Personal Wealth Portfolios (“PWP”) - The PWP platform is a unified managed account
platform. Clients invest in one or more asset allocation portfolios designed by LPL’s
Research Department, which include a combination of mutual funds, ETFs, and investment
models (“Models”) provided to LPL by third party money managers (“PWP Advisors”).
• Manager Access Select (“MAS”) - The MAS platform provides clients with access to the
investment advisory services of third-party asset managers (“TPAMs”).
• Manager Access Network (“MAN”) – The MAN platform provides clients with access to
TPAMs to provide investment management services.
• Guided Wealth Portfolios (“GWP") - GWP offers clients the ability to participate in a
centrally managed, algorithm-based investment program, which is made available to users
and clients through a web-based, interactive account management portal (“Investor Portal”).
Investment recommendations to buy and sell ETFs and open-end mutual funds are generated
Mariner Independent Advisor Network, LLC-Form ADV Part 2A
March 29, 2025
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through proprietary, automated, computer algorithms (collectively, the “Algorithm”), based
upon model portfolios constructed by LPL and selected for the account as described below
(such model portfolio selected for the account, the “Model Portfolio”). Communications
concerning GWP are intended to occur primarily through electronic means (including but
not limited to, through email communications or through the Investor Portal), although our
IARs will be available to discuss investment strategies, objectives or the account in general
in person or via telephone.
A preview of the GWP program (the “Educational Tool”) is provided for a period of up to forty-
five (45) days to help users determine whether they would like to become advisory clients and
receive ongoing financial advice by enrolling in the advisory service (the “Managed Service”).
The Educational Tool and Managed Service is described in more detail below and in the GWP
Program Brochure which also includes important disclosures Users should review and
understand. Users of the Educational Tool are not considered to be advisory clients and do not
receive ongoing investment advice or supervision of their assets, and do not receive any trading
services.
A minimum account value of $5,000 is required to enroll in the Managed Service.
Features of the Educational Tool
Users of the Educational Tool (each, a “user”) agree to terms of use (“Terms of Use”) and
complete an investor profile. An investment objective (“Investment Objective”) and Model
Portfolio is assigned to each user based upon factors in the investor profile, including risk
tolerance and the number of years remaining until the age of retirement (such time being referred
to herein as the “Retirement Age”). (See description in “Features of the Managed Service”
below for information regarding the design of the Model Portfolios.) Based on the Investment
Objective and Model Portfolio, the Educational Tool generates sample analysis, advice and
investment recommendations (“Sample Recommendations”).
that can assist users
The Educational Tool provides Sample Recommendations
in
determining whether to utilize the Managed Service. Access to the Educational Tool is generally
limited to a period of forty-five (45) days. The Educational Tool is intended to be used for
educational and informational purposes only. The Educational Tool does not provide
comprehensive financial planning and is not intended to constitute legal, financial or tax advice.
There can be other relevant factors and financial considerations (e.g., debt load or financial
obligations) that are not considered in formulating any Sample Recommendations provided. The
Sample Recommendations made are meant solely as a sample of the types of recommendations
available through the Managed Service and users are solely responsible for making their own
investment decisions. The Educational Tool is only one of many tools that users can use as part
of a comprehensive investment analysis process. Users should not rely on the Educational Tool
as the sole basis for investment decisions.
Features of the Managed Service
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Investors participating in the Managed Service complete an account application (the “Account
Application”) and enter into an account agreement (the “Account Agreement”). As part of the
account opening process, such clients are responsible for providing complete and accurate
information regarding, among other things, their age, risk tolerance, and investment horizon
(collectively, “Client Profile”). Information in the Client Profile is relied upon in order to
provide services under the Program, including but not limited to, determination of suitability of
the Program for clients and an appropriate Investment Objective and Model Portfolio for clients.
The Model Portfolios have been designed and are maintained by LPL or, in the future, a third-
party investment strategist (as applicable, the “Portfolio Strategist”) and shall include a list of
securities holdings, relative weightings and a list of potential replacement securities for tax
harvesting purposes. The Model Portfolios cannot be accessed, changed or customized and only
one Model Portfolio is permitted per account.
Based upon a participating client’s risk tolerance as indicted in the Client Profile, the client is
assigned an investment allocation track (currently, allocation track options include Fixed
Income Tilt, Balance Tilt or Equity Tilt), the purpose of which is to slowly rotate the client’s
equity allocation to fixed income over time. LPL’s Research Department created these tracks
using academic research on optimal retirement allocations, the industry averages as calculated
by Morningstar for the target date fund universe, and input from certain third parties.
Within the applicable allocation track and based upon a participating client’s chosen Retirement
Age in the Client Profile, such client will be assigned a Model Portfolio and one of five of LPL’s
standard investment objectives (described below):
o Income with capital preservation. Designed as a longer-term accumulation account, this
investment objective is considered generally the most conservative. Emphasis is placed on
generation of current income with minimal risk of capital loss. Lowering the risk generally
means lowering the potential income and overall return.
o
Income with moderate growth. This investment objective emphasizes generation of current
income with a secondary focus on moderate capital growth.
o Growth with income. This investment objective emphasizes modest capital growth with
some focus on generation of current income.
o Growth. This investment objective emphasizes achieving high long-term growth and capital
appreciation. There is little focus on generation of current income.
o Aggressive growth. This investment objective emphasizes aggressive growth and maximum
capital appreciation, with no focus on generation of current income. This objective has a very
high level of risk and is for investors with a longer timer horizon.
Both the participating client and our IARs are required to review and approve the initial
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Investment Objective. As such client approaches the Retirement Age, the Algorithm will
automatically adjust the client’s asset allocation. Any change to the Investment Objective
directed by a client due to changes in the client’s risk tolerance and/or Retirement Age will
require written approval from the client and our IAR before implementation. Failure to approve
the change in Investment Objective can result in a client remaining in a Model Portfolio that is
no longer aligned with the applicable Client Profile. The Investment Objective selected for the
account is an overall objective for the entire account and can be inconsistent with a particular
holding and the account’s performance at any time and can be inconsistent with other asset
allocations suggested to client prior to client entering into the Account Agreement. Achievement
of the stated investment objective is a long-term goal for the account, and asset withdrawals can
impair the achievement of client’s investment objectives. A Client Profile that includes a
conservative risk tolerance over a long-term investment horizon can result in the selection of an
Investment Objective that is riskier than would be selected over a shorter-term investment
horizon. Clients should contact their IAR if they believe the Investment Objective does not
appropriately reflect the information in a Client Profile, such as a client’s risk tolerance.
By executing an Account Agreement, clients authorize the parties to the Account Agreement to
have discretion to buy and sell only ETFs and open-end mutual funds (collectively, “Program
Securities”) according to the Model Portfolio selected and, subject to certain limitations
described in the Account Agreement, hold or liquidate previously purchased non-model
securities that are transferred into the account (“Legacy Securities”). In order to be transferred
into an account, Legacy Securities must be open end mutual funds with which LPL has a full or
partial selling agreement, ETFs or individual U.S. listed stocks. Securities that are not Program
Securities included within the Model Portfolio will not be purchased for an account Legacy
Securities will be held or sold, generally, but not solely, with the goal of optimizing tax impacts
for accounts that are subject to tax. Additional Legacy Securities will not be purchased for the
account. Clients cannot impose restrictions on liquidating any Legacy Securities for any reason.
Clients should not transfer in Legacy Securities that they are not willing to have liquidated without
their prior approval.
In addition, uninvested cash can be invested in money market funds, the Multi-Bank Insured
Cash Account (“ICA”) or the Deposit Cash Account (“DCA”), as applicable, as described in the
Account Agreement. Dividends paid by the Program Securities in the account will be
contributed to the cash allocation and ultimately reinvested into the account based on the Model
Portfolio once the tolerance within cash allocation is surpassed.
Pursuant to the Account Agreement, client is authorizing the parties to the Account Agreement
to perform tax harvesting when deemed acceptable by the Algorithm. LPL, our IARs and clients
cannot alter trades made for tax harvesting purposes. In order to permit trading in a tax- efficient
manner, the Account Agreement also grants the authority to select specific tax lots when
liquidating securities within the account. Although the Algorithm attempts to achieve tax
efficiencies, by doing so, a client’s portfolio can or will not directly align with Model Portfolio.
As a result, a client can receive advice that differs from the advice received by accounts using
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the same Model Portfolio, and the client’s account can perform differently than other accounts
using the same Model Portfolio.
Trading in the account at any given time is also subject to certain conditions, including but not
limited to, conditions related to trade size, compliance tests, the target cash allocation and
allocation tolerances. LPL, IARs and clients can alter the rebalancing frequency.
Registrant believes that certain clients will benefit from GWP’s advisor-enhanced advisory
services, particularly due to the relatively low minimum account balance and the combination
of a digital advice solution with access to an advisor. Unlike direct- to-consumer robo platforms,
our IARs are responsible on an ongoing basis as investment advisors and fiduciaries for the
client relationship, including for recommending the Program for the client; providing ongoing
monitoring of the Program, the performance of the account, the services of LPL; determining
initial and ongoing suitability of the Program for the client; reviewing clients’ suggested portfolio
allocations; reviewing and approving any change in Investment Objective due to changes clients
make to their Client Profile; answering questions regarding the Program, assisting with
paperwork and administrative and operational details for the account; and being available to
clients to discuss investment strategies, changes in financial circumstances, objectives or the
account in general in person or via telephone. Our IARs can also recommend other suitable
investment programs if clients have savings goals or investment needs for which GWP is not
the optimal solution.
(SWM, MWP, OMP, PWP, MAS, MAN and GWP are collectively referred to as the “LPL
Platforms”).
Under the SWM, MWP, OMP, PWP, MAS, and GWP (subject to the limitations described above)
platforms, LPL and the Firm provide ongoing investment advice to Registrant’s clients in the
platform. Initially, an IAR will obtain necessary client financial data and assist the client in
determining the appropriate platform and asset allocation model(s) best suited for the client’s overall
investment objectives and guidelines.
Under the MAN platform, LPL serves as the client’s custodian and broker and the Firm provides
ongoing investment advisory services, including gathering necessary client financial data and
assisting the client in determining an appropriate TPAM with an investment strategy or strategies
suitable for and in line with each client’s investment guidelines.
Each client entering into an LPL Platform, with the exception of the MAN platform, will be
provided a written LPL disclosure brochure that outlines in detail the services provided and fees
charged, along with other important information about the selected platform. Clients should
thoroughly read the brochure upon receipt.
The LPL Platforms can or will not be suitable for, and therefore not offered to, all of our clients.
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Schwab Sponsored Programs
The following Charles Schwab & Co., Inc. (“CS&Co.”) sponsored programs are offered to our
clients; (please note that all fees associated with these platforms are detailed in Item 5):
• Managed Account Select (“SELECT”) – The SELECT program provides our clients with access
to the investment advisory services of TPAMs. The TPAMs and their investment strategies
offered are evaluated and monitored by Charles Schwab Investment Advisory, Inc. (“CSIA”),
an affiliate of CS&Co.
• Managed Account Access (“ACCESS”) – The ACCESS program also provides our clients with
access to investment advisory services of TPAMs. The investment strategies are not evaluated
by CS&Co., and there are no eligibility criteria for the TPAM.
• Managed Account Marketplace (“MARKETPLACE”) – With the MARKETPLACE program,
the IAR and the client can choose a TPAM from an extensive list that CS&Co. has compiled,
but neither CS&Co. nor CSIA screen, evaluate or monitor the TPAMs in the MARKETPLACE
program.
(SELECT, ACCESS, and MARKETPLACE are collectively referred to as the “Schwab Programs”).
Under each of the Schwab Programs, the TPAMs provide discretionary investment advisory
services and will manage clients’ assets in the programs in accordance with the investment strategies
chosen by the clients.
Also, CS&Co. serves as the client’s custodian and broker in the Schwab Programs and the Firm
provides ongoing investment advisory services, including gathering necessary client financial data
and assisting the client in determining an appropriate Schwab Program, including selection of
TPAMs, in accordance with the investment strategy or strategies suitable for and in line with each
client’s investment guidelines.
Each client entering into a Schwab Program will be provided with a written CS&Co. disclosure
brochure that outlines in detail the services provided and fees charged, along with other important
information about the selected Schwab Program. Clients should thoroughly read the brochure upon
receipt.
The Schwab Programs can or will not be suitable for, and therefore are not offered to, all of our
clients.
Schwab Technology Platforms
• Schwab Institutional (“SCHWAB INSTITUTIONAL”) – The SCHWAB INSTITUTIONAL
program is an open architecture, fee-based investment platform. Through this platform, clients
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can consolidate multiple investments into one account and receive one statement. There is no
minimum account size required for utilizing the SCHWAB INSTITUTIONAL program.
Fidelity Institutional Asset Management
Fidelity Institutional Asset Management (“FIAM”) works with financial advisors and advisory
firms, offering them resources to help investors plan and achieve their goals; it also works with
institutions and consultants to meet their varying and custom investment needs. FIAM is a gateway to
Fidelity’s diverse investment capabilities across equity, fixed income, high-income, and global asset
allocation. Our IARs use the Fidelity platform for their open architecture accounts to buy and sell
securities for our advisory clients.
Turnkey Asset Management Programs
At times, and when deemed appropriate for a particular client’s needs, the Network will utilize a
turnkey asset management program, also known as a “TAMP”. A TAMP allows IARs to outsource
the management of some or all of their clients' assets. With a TAMP, IARs gain access to managed
account services that allow them to offload time-consuming functions, such as research, portfolio
construction, rebalancing, performance reporting, and tax optimization and reporting, which allows
them to focus on clients' personal financial needs and concerns.
In each instance where the Firm deploys a TAMP in a client’s portfolio, we serve as the intermediary
to the TAMP providers to assist the client in determining an appropriate asset allocation strategy
based on discussions about the client’s risk tolerance and investment objectives. The Firm also
obtains important relevant and current information concerning the client's identity, occupation, and
financial circumstances, among many other things, as part of our advisory and fiduciary
responsibilities. Based on a client's individual circumstances and needs, we will assist the client in
determining which investment strategy is appropriate for that client. Factors considered in making
this determination include among other things account size, risk tolerance, and a client's investment
experience, which are all discussed during our initial consultation with the client.
IARs of the Firm will meet with the client (in person or via phone) at least annually. When
necessary, we will suggest changes in the client's investment strategy to reflect any changes in the
client's goals and attitudes. We will then implement changes to the investment strategy upon the
approval of the client. Recommendations made by the Firm are our own and are neither
recommended nor approved by the TAMP providers. Should there be any material change in the
client’s personal and/or financial situation, we should be notified immediately to determine whether
any review and/or revision of the client’s strategy are warranted.
The Firm’s fees include those fees associated with allocating client assets to the designated TAMP
program. Fees charged by the TAMP program will be in addition to the Firm’s fees charged to the
client by the IAR. TAMP firms also have different ways that they bill their fees, please refer to the
TAMP paperwork to understand when and how fees are billed.
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Currently, the TAMPs utilized by the Firm include AssetMark, Gemmer, and SEI among others,
although the Firm can utilize other TAMP programs when appropriate. At the time of engagement,
clients will complete account opening paperwork, TAMP related paperwork, and a risk tolerance
questionnaire, which will help the Firm in selecting an appropriate investment strategy for the client.
Depending on the relationship with the TAMP, the client will also complete the Firm’s standard
investment advisory agreement, if necessary.
Once the client has selected an investment strategy, the TAMP firm will manage the clients’ assets
on a discretionary basis according to the client’s investment strategy and asset allocation. The Firm
will monitor the client’s account activity and performance and, if we determine that a particular
TAMP provider is not providing sufficient management services to the client or is not managing the
client's portfolio in a manner consistent with the client's investment objectives, risk profile, and/or
time horizon, we will suggest that the client contract with a different TAMP provider or investment
platform.
AssetMark Platform
The Firm may offer advisory services to Clients by selecting the AssetMark Platform. For more
information regarding the AssetMark Platform, refer to AssetMark Platform Disclosure Brochure.
The minimum investment required on the AssetMark Platform depends upon the Investment
Solution chosen for a Client’s account and is generally $10,000 for Mutual Fund and $25,000 for
ETF Accounts, and from $25,000 to $1,000,000 for Privately Managed and Unified Managed
Accounts, depending on the investment strategy selected for the account. These minimums are
described in more detail in the Fees & Minimums Page in the AssetMark Platform Disclosure
Brochure. Accounts below the stated minimums may be accepted on an individual basis at the
discretion of AssetMark.
Sub-Advisory Agreement with SEI Investments Management Corporation
We have a Sub-Advisor Agreement with SEI Investments Management Corporation (“SIMC”), a
registered investment advisor affiliated with SEI Private Trust Company (“SPTC”). This agreement
allows us to allocate client assets for participation in SIMC’s Sub-Advised Program. We are
responsible to determine whether participation in the program is appropriate for our clients.
Under the program, SIMC provides discretionary investment management services to us and makes
available investment strategy models of SIMC, or investment managers appointed by SIMC. These
models seek to achieve particular investment goals and are not tailored to individual clients. We
may allocate client assets to one or more of SIMC’s models which match a client’s objectives. SIMC
then invests the allocated funds in accordance with the selected models as updated from time to time
by SIMC or investment managers appointed by SIMC. In most cases, SIMC will implement those
models and execute transactions; in others, the investment manager will do so.
SIMC charges us an investment management fee for participation in the program. We have
instructed SPTC to operationally facilitate the deduction of the investment management fees direct
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from our clients’ accounts held at SPTC.
Clients with assets allocated to the program are subject to certain risks, including the investment
manager implementing its model for its other accounts before implementing it for our clients. In
that case, securities may be traded by our clients at prices different than those obtained by the
manager’s other clients. The risk of price deviations is greater for large orders and thinly traded
securities. Additional performance of our client’s investments in a model may deviate from the
performance of other accounts in such models or those managed by SIMC or the investment
manager.
We may also invest client assets into model portfolios of mutual funds and exchanged-traded funds
created by SIMC. This includes the SEI Asset Allocation Models that consist of allocations to SEI
Funds and SEI ETFs and the Independent Funds Models Program which consists of model portfolios
of allocations to certain families of third-party mutual funds or ETFs.
Participant Account Management (Discretionary)
We use a third-party platform to facilitate management of held away assets such as defined
contribution plan participant accounts, with discretion. The platform allows us to avoid being
considered to have custody of client funds since we do not have direct access to client log-in
credentials to affect trades. We are not affiliated with the platform in any way and receive no
compensation from them for using their platform. A link will be provided to the client allowing
them to connect an account(s) to the platform and permit the Firm to view their account(s) and place
trade instructions on their behalf through the platform. Once client account(s) is connected to the
platform, we will review the current account allocations. When deemed necessary, we will rebalance
the account considering client investment goals and risk tolerance, and any change in allocations
will consider current economic and market trends. The goal is to improve account performance over
time, minimize loss during difficult markets, and manage internal fees that harm account
performance. Client account(s) will be reviewed periodically and allocation changes will be made
as deemed necessary.
Please refer to Items 5, 8 and 12 for further information regarding the LPL Platforms, the
Schwab Programs, Fidelity Programs and TAMP providers.
Consulting, Financial Planning and Tax Services
To the extent specifically requested by a client, IARs of the Firm will provide financial planning
and/or consulting services (including investment and non-investment related matters, such as estate
planning, insurance planning, education savings, tax consulting and preparation, etc.). The Firm
may charge an additional fee for such services depending on the level of service provided and other
considerations deemed relevant by IARs in their sole discretion. IARs of the Firm are also able to
provide financial planning and consulting services on a stand-alone basis. Prior to engaging the
Firm to provide these services and to the extent a client has not entered into an investment advisory
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agreement (also referred to as an investment management agreement) with the Firm, clients are
generally required to enter into a Financial Planning or Consulting Agreement with the Firm setting
forth the terms and conditions of the engagement (including termination), describing the scope of
the services to be provided, and the portion of the fee that is due from the client prior to the Firm
commencing services if applicable.
Please Note: While certain IARs and associates of the Firm are licensed attorneys, they do not
provide legal services to the Firm’s clients through the Firm and no attorney-client relationships
exist. IARs are required to report such activity as an Outside Business Activity and are supervised
accordingly.
Comprehensive Financial Planning
Generally, financial planning services are based on an analysis of the client’s current financial
circumstances, goals and objectives. This involves a process of information gathering by the IAR,
then preparation of a financial plan or other written report. Specifically, Comprehensive Financial
Planning will address each of the six key areas of financial planning:
• Financial Position
• Protection Planning
•
Investment Planning
• Corporate and Personal Income Tax Planning
• Retirement Planning
• Estate Planning
• Asset Separation (Divorce and Business)
• Project Management
Our written financial plans provided to clients or financial planning consultations rendered to clients
usually include general recommendations for a course of activity or specific actions to be taken by
the clients. For example, recommendations can be made that the clients begin or revise investment
programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter
retirement savings, or establish education or charitable giving programs.
For Comprehensive Financial Planning engagements, we provide our clients with a written
summary of their financial situation, observations, and recommendations. Financial plans or
consultations are typically completed within five (5) months of a client signing a contract with us,
provided that all the information and documents we request from the client are provided to us
promptly. Implementation of the recommendations will be at the discretion of the client. Clients are
free to implement investment recommendations through brokers unaffiliated with the Firm or its
IARs.
Subscription Based Financial Planning Services
The Firm has the ability to offer Financial Planning services on a subscription (flexible payment) fee
basis. Please see Item 5 below for a description of subscription based financial planning.
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Hourly Consulting Services
General hourly consulting services are provided for a variety of purposes including, but not limited
to:
• Annual Update to Financial Plan
• Asset Allocation Recommendations
• Portfolio Management Recommendations
•
Individual Issue Consulting
• Third-Party Review (2nd opinion)
For hourly consulting engagements, we usually do not provide our clients with a written summary of
our observations and recommendations as the process is less formal than our financial planning
services. Implementation of any recommendations or next steps to be taken will be at the discretion
of the client.
Tax Compliance, Planning, Preparation and Consulting
To the extent specifically requested by a client, IARs are able to provide coordinated tax
compliance, planning, preparation and consulting services (collectively referred to as “tax services”)
to investment advisory clients as an integrated part of our investment advisory services, including
through referrals to Mariner Wealth tax team. Certain IARs also provide tax services on a stand-
alone basis, pursuant to a separate tax engagement agreement, to individuals, businesses and
family offices. Although the Firm is a registered investment adviser under the Investment Advisers
Act of 1940 (“Advisers Act”), the Firm is not serving in a fiduciary capacity in its provision of
stand-alone tax services and will not provide ongoing investment advisory services with respect to
stand-alone tax clients’ assets or accounts. For clients who receive separate tax services , IARs may
recommend the Firm be retained as their investment adviser pursuant to a separate investment
advisory agreement; however, such clients are under no obligation to do so. IARs may also
recommend the services of other, non-affiliated professionals to provide tax services. Our clients are
under no obligation to engage the services of any such recommended professional. It is solely up to
our clients as to whether they accept or reject any recommendation made by an IAR.
Please Note: Our clients agree that, if any dispute arises between our client and any other
professional recommended by an IAR and/or the Firm, they will seek recourse exclusively from and
against the engaged qualified professional.
Please Also Note: While certain investment adviser representatives of the Firm are licensed CPAs or
EAs, they are not responsible for providing tax services unless the client’s Agreement specifically
sets forth that such tax services will be provided. The Firm typically charges an additional or
separate fee for tax services.
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Retirement Plan Consulting Services (i.e., 401(k) Plans)
Retirement Plan Consulting services are provided in compliance with the applicable state law(s)
regulating pension consulting services. This applies to client accounts that are pension or other
employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of
1974, as amended (“ERISA. Retirement Plan Consulting Services are provided pursuant to a
separate written Retirement Plan Consulting Agreement (“RPCA”), that is entered into between the
Firm and the Client, Sponsor and/or Responsible Plan Fiduciary. If the client accounts are part of a
Plan, and we accept appointments to provide our services to such accounts, we acknowledge our
fiduciary role within the meaning of Section 3(21) of ERISA, but only with respect to the provision
of services described in the Services section of the RPCA. When providing Retirement Plan
Consulting Services, we will solely be making recommendations to the Client, Plan sponsor and/or
Retirement Plan Fiduciary (RPF). Under a RPCA, IARs provide a number of different services, as
described below:
IARs serve as a fiduciary for the Plan, as such term is defined in Section 3(21) of ERISA. IARs serve
as a limited scope fiduciary, also known as a Limited Scope Section (3)(21) fiduciary. As such, IARs
perform some or all of the following services:
o recommend investment options for the Plan to offer to its participants;
o periodically review the Plan’s investment options;
o assist Plan fiduciaries in creating and/or updating the Plan’s written Investment
Policy Statement (“IPS”);
o provide general investment educational seminars to Plan participants; and
o work with other Plan service providers.
IARs shall not however, have discretion over: (i) the establishment of the Plan’s IPS, (ii) the
selection, monitoring, removal and replacement of the Plan’s investment options, or (iii) the creation
and management of model portfolios to be offered to participants as investment options in the Plan.
The Plan retains the sole responsibility for determining whether to implement any recommendations
made by the IAR and is not required to implement any such recommendations or conduct business
through IAR.
For all Retirement Plan Consulting Services, clients will be required to provide information to the
IAR in the form of written responses to questionnaires, documentation, or in face-to-face or
telephone discussions. IARs will rely upon the information provided by Client, Plan sponsor or
Responsible Plan Fiduciary. Clients are advised that it remains their responsibility to promptly
advise the IAR of any changes to this information.
IARs shall provide Retirement Plan Consulting Services only with respect to the selection and
retention of the Plan’s assets and shall not: (i) serve as a Plan custodian; (ii) provide advice or
recommendations with respect to the Plan’s choice of a third party administrator, record-keeper or
other service provider; or (iii) assume the duties of a trustee of the Plan or administrator (as such
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term is defined in Section 3(16) of ERISA); or (iv) provide any other services to participants,
including without limitation, quarterly investment performance measurement reports, participant
communications, notices, benefit statements or other information not specifically related to the use
of the investment options offered under the Plan. IARs have no authority or responsibility to provide
services with respect to voting proxies for securities held by the Plan or take other action related to
the exercise of shareholder rights regarding such securities, including prospectus delivery. IARs do
not provide legal or tax advice to the client, RPF and/or the Plan (or any Plan participant or
beneficiary), and clients must seek the advice of its own legal and/or tax adviser, as to all matters that
might arise relating to the Plan, including, without limitation, the operations and administration of
the Plan and the compliance of the Plan with applicable law. IARs are not responsible or liable for
the recommendation of or services rendered by any other provider as a result of such services or the
other provider’s compliance with applicable laws, including, without limitation, ERISA and the
Internal Revenue Code, as amended with respect to such services.
In certain cases, if deemed appropriate for a client, IARs will refer Plans to utilize the services of the
Firm’s affiliate, Mariner Institutional, for management.
Our Fiduciary Acknowledgement
When we provide investment advice to you regarding your retirement plan account or IRA, we are
fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act
(“ERISA”) and/or Section 4975 of the Internal Revenue Code (the “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:
• 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
• Give you basic information about conflicts of interest
For purposes of this special rule, covered “plans” include 401(k), 403(b), profit sharing, pension
and all other plans that are subject to ERISA, together with tax-qualified retirement plans under the
Code (even if not subject to ERISA) such as Solo 401(k) and “Keogh” plans. “IRAs” subject to the
special rule include both traditional and Roth IRAs, individual retirement annuities, health savings
accounts, Archer medical savings accounts and Coverdell education savings accounts
Portfolio Consulting and Model Portfolios
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IARs of the Firm can utilize Portfolio Consulting (“PC”) services, which is a separate offering
consisting of portfolio design, investment consulting, trade execution, and portfolio re- balancing
services. The PC Team can access client accounts through an advisor’s existing custodian as well as
provide sub-advisory services through a separate custodial relationship. In addition, the PC team
has established a relationship to provide these services through Orion Technologies via their
“Communities” platform. PC services are provided through the Firm and the relationship and services
with the IAR is governed by a separate written Portfolio Consulting Agreement with the Firm. See
Item 5 for additional information about fees charged to IARs in conjunction with the utilization of
PC services. IARs of the Firm are under no obligation to utilize PC services. Clients whose IARs
utilize PC services are not charged a separate fee for such services. IARs pay for the services of PC
themselves as a business expense.
Closed-end Funds, Exchange Traded Funds (ETFs) and Mutual Fund Portfolios
IARs of the Firm provide advice to client accounts, that include as part of the overall client
allocation, portfolios of closed-end funds, ETFs and mutual funds.
Managed Accounts – Equity Portfolios and Fixed Income Portfolios
We also offer our clients a variety of equity and fixed income strategies. These strategies offer
clients access to equity and fixed income securities. The Firm generally imposes account minimums
of $100,000 when offering managed accounts to clients, which may be adjusted depending on the
level of service provided to the client, the investment strategy employed by the account and other
considerations deemed relevant by the Firm in its sole discretion. The equity strategies vary by
mandate, all with a focus on capital appreciation as a primary objective. Philosophies include
dividend-based strategies, GARP (growth at a reasonable price), value, growth, direct indexing and
socially conscious. The Firm will select individual securities based upon fundamental analysis
performed by our research investment professionals. We rely primarily on publicly available
information in our analysis, supplemented by third-party research and analytical tools. With respect
to our fixed income strategies, our primary objective is capital preservation. Secondary objectives
include providing a steady, tax-efficient revenue stream and the potential for capital appreciation.
Our fixed income strategies are formed through a combined top-down and bottom-up perspective.
From the top-down, we develop our economic outlook and interest rate strategy using
macroeconomic and market data and trends. We will alter our duration, sector, and yield curve
exposure targets based on this outlook.
Options Strategies
We also offer our clients a variety of options strategies, including through a sub-advisory
relationship with Mariner Wealth. These strategies are generally designed to provide clients with
income that is uncorrelated to the performance of their underlying investments held as collateral.
Alternatively, the options strategies may be used to enhance the returns of an underlying
concentrated position or to protect the downside of an equity or an index.
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Structured Notes Strategies
We offer our clients structured notes strategies, including through a sub-advisory relationship with
Mariner Wealth. These strategies are generally designed to provide clients with an alternative
risk/reward payoff compared to owning the same asset directly. The structured notes objectives are
to offer capital appreciation to equity indices and varying levels of downside protection to the index.
They may also be used to provide income or principal protection.
Variable Prepaid Forwards
We offer our clients variable prepaid forward strategies. This strategy seeks to combine the
benefits of an equity collar with immediate cash proceeds, which can be used for investment or
diversification purposes
Alternative Strategies
Our alternative and private fund strategies focus on generating absolute, risk-adjusted returns that
are intended to have lower correlation to the broad equity market. As a result, clients must
affirmatively subscribe for any such investment.
The Firm has contracted with CAIS Capital, LLC and Capital Integration Systems LLC (collectively
“CAIS”) and has granted wealth advisors access to the CAIS alternative investment platforms. CAIS
and its affiliates conduct the initial and on-going due diligence (investment and operational) on
private equity and hedge fund offerings available on their platform. The Firm utilizes and includes
the due diligence provided by CAIS related to the offerings available on the platform in its approval
process. Only Firm-approved alternative investments are available on the CAIS platform. Please
note that with privately held alternatives valuations can lag a month or more and are received from
the issuer’s or offerings’ third-party administrator. We use this data to calculate your advisory fee
(as detailed below in Item 5 Fees and Compensation). Please refer to Item 5 Fees and Compensation
for additional information on fee calculation.
IARs who are affiliated with LPL also have access to LPL’s Alts Connect platform. LPL Alts
Connect is a centralized, digitized system that streamlines the purchasing process and provides tools
such as prequalification, e-signature capabilities and the ability to send sales kits directly to clients.
The platform complements an expanding product set that includes an array of prominent funds
giving advisors more optionality to build diversified, non-correlated portfolios. LPL expanded its
long-standing relationship with iCapital to offer a suite of alternative investment products to LPL’s
network of advisors and affiliated firms. This collaboration includes a tailored selection of iCapital’s
funds to LPL’s curated menu alongside their diligence.
Annuities
Clients may grant the Firm discretion to: (a) select investment strategy allocations for clients’
existing or new annuity products; and (b) allocate among the investment strategy allocations
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available from the specific annuity sponsor (collectively (a) and (b) are referred to as the “Annuity
Allocation Services”). In performing Annuity Allocation Services, the Firm will only consider the
options available within the specific annuity purchased by the client. If an annuity was purchased
with retirement account assets, client agrees that the Firm did not exercise discretionary control with
respect to the purchase of the annuity. Any changes in client’s annuity investments (re-allocations
among investment strategy allocations) are subject to the terms and conditions imposed by the
applicable annuity sponsor. The assets invested in any annuity product for which the Firm is
providing Annuity Allocation Services are included in the total assets on which the Firm’s advisory
fee is calculated. The Firm’s advisory fee is separate from, and in addition to, the management fees
and expenses charged on a continuing basis by the annuity sponsor, insurance company, and/or
associated investment manager. Annuities have inherent risks, will fluctuate in value, incur losses
based on the performance of selected investments or investment strategy allocations, are suitable
only as long-term investments, and should not be viewed as short-term trading vehicles. Clients
should carefully review the prospectus and other offering documents for more information on
annuities.
Certain insurance companies provide advisory annuities whereby the insurance company will
deduct the advisory fee directly from the client’s annuity. Any advisory fee disbursement will
impact any applicable living benefit feature and will reduce the cash surrender value of their annuity
contract and the net death benefit payable under the contract. It is also important to verify if the
insurance company has been granted a Private Letter Tax Ruling from the Internal Revenue Service
that allows advisory fee disbursements on fixed index annuity, variable annuity and registered
index-linked non-qualified contracts to not be considered distributions for federal income tax
purposes, provided they do not exceed an amount equal to an annual rate of 1.5% of the contract’s
value. Advisory fee disbursements from nonqualified multi-year guaranteed contracts are
considered distributions and may be taxable to the client who owns the contract. Generally, advisory
fee disbursements are partial withdrawals under the terms of the contract, and the amount of the
advisory fee disbursement is included in the calculation of the free partial withdrawal amount
permitted each year without surrender charges, however clients should refer to their annuity contract
for specific details.
Other Businesses and Investment Programs
The Firm and our affiliates also offer to our clients a variety of services, including estate and trust
services, and risk management. The Firm earns fees for the services provided by it, and its affiliates
will likewise earn fees directly for services they provide. Please see Item 10 for more information
on the services provided by our affiliates.
Assets Under Management
Our assets under management totaled $8,486,309,662 as of December 31, 2024. All assets are
managed on a discretionary basis.
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Item 5-Fees and Compensation
General Fee Information
Fees are due, payable, and deducted from your account by the custodian in advance (unless
otherwise stated in the client agreement due to a TAMP relationship or unique custodial platform)
and are based upon the market value of the client’s account assets as of the close of business on the
last day of the previous calendar quarter as valued by the applicable custodian or another
independent third-party, as set forth on the most recent statement made available to us, or as
otherwise dictated by the client’s Agreement. The Agreement also addresses the application of fees
with respect to accrued interest. The Agreement and/or the separate agreement with any financial
institution(s) authorizes us to invoice the custodian for the advisory fee. The Agreement further
authorizes the custodian to deduct the amount stated in the fee statement from one or more of the
client’s accounts in accordance with applicable custody rules. The custodian does not validate or
check our fee or its calculation on the assets on which the fee is based. The custodian will deduct
the fee from the account(s) or, if the client has more than one related account(s), from the account
designated by the Firm and/or the client to pay our fees, as applicable. The custodians with which
our clients maintain accounts have agreed to send statements to each client, at least quarterly,
indicating all amounts disbursed from the account(s), including the amount of advisory fees paid
directly to us. We urge clients to carefully review such account statements for accuracy.
Fees for the initial quarter are adjusted pro rata based upon the number of calendar days in the
calendar quarter that the Investment Advisory Agreement goes into effect. Fee schedules are set forth
by the platform provider and agreed and monitored by the Firm; however, our IARs have the ability
to negotiate fees, in their sole discretion with the client, so long as such fees fall within the ranges
approved by the Firm and are reasonable in nature, based on factors such as the complexity of the
client’s situation, scope of services provided and expertise of the IAR.
The advisory relationship can be terminated by the client or by third parties to the contract in
accordance with the provisions of the Investment Advisory Agreement and Platform/TAMP
paperwork. The client receives a pro rata refund of any prepaid unearned advisory fees. Any unpaid
fees become immediately due and payable. Clients receive an account statement from their
custodian at least quarterly. The statement includes the amount of any fees paid directly to the Firm.
Clients should note that the same or similar services to those described above can be available
elsewhere at a lower cost to the client.
The Firm may employ a third-party manager to manage a portion of your account, including third-
party managers affiliated with the Firm. The fees payable to a third-party manager will be set forth
in a written agreement and shall be in addition to the advisory fee payable under your Agreement.
If the Firm retains the third-party manager as a “sub-adviser” to your account, depending on the
agreement between the Firm and the sub-advisor the Firm will typically either pay the sub-advisory
fee from your advisory fee payable to the Firm or the sub-advisor will deduct its fee from your
account directly, but for certain sub-advisers there may be a separate written agreement between
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you and the sub-adviser to pay an additional amount directly to the sub-adviser.
Transaction Based Fee and Asset Based Fee Options
The Firm offers two forms of pricing/fee options that vary on how transactions within investment
portfolios are paid for. The details for Transaction Based Fee Option (“TBFO”) and Asset Based
Fee Option (“ABFO”) are outlined in the sections below.
1) Transaction Based Fee Option (TBFO)
The Firm offers two different forms of TBFO which are available on any custodial platform that the
Firm offers. Under one of the forms of the TBFO, clients pay separate transaction charges and/or
commissions at the time of each transaction in addition to investment advisory fees. As a fee-based
investment adviser, the Firm generally avoids investment vehicles that charge the client a
commission for their sale or purchase. However, if a commission is charged, this cost will be passed
on to the client. Most brokers and custodians charge transaction fees to effect trades for a client’s
account. These fees are levied by the broker or custodian to cover their costs for completing the
transaction. The Firm does not share or participate in any such transaction fees, commissions, or
12b-1 fees, if applicable. 12b-1 fees are marketing and distribution fees on a mutual fund. The 12b-
1 fee is considered to be an operational expense and, as such, is included in a mutual fund’s expense
ratio.
In the other form of the TBFO, the IAR can agree to pay transaction charges and/or commissions
pursuant to a written agreement between the client and IAR. Transaction fees vary by broker and/or
custodian and can vary by IAR. Please ask your IAR for details on transaction fees and/or
commissions specific to your account. The IAR can charge a higher overall advisory fee in order to
offset their cost for the transaction charges involved in the management of the portfolio.
Dependent upon the custodian and investment platform selected, advisory fees charged by the IAR
range from 0.4% to 2.55% (when a client is paying for transaction charges in addition to advisory
fees) and from 0.4 % to 2.75% (when a client pays for the advisory fee only and the IAR pays for all
transaction charges).
Please see below for details relating to additional transaction fees, brokerage costs and custodial
platform fees assessed by the broker-dealer or custodian. Dependent upon the custodian and
investment platform selected, unless otherwise noted, for platforms that use third-party managers,
generally, advisory fees assessed by Registrant/IAR do not include the manager’s fee, nor do they
include brokerage commissions and other trading costs of transactions (such as mark-ups and mark-
downs); mutual fund 12b-1 fees; sub-transfer agent, networking and omnibus processing fees;
transfer taxes, fund management fees and administrative servicing fees; certain deferred sales
charges on previously purchased mutual funds and other transaction charges and service fees, IRA
and Qualified Retirement Plan fees; administrative servicing fees for trust accounts; and other taxes
and platform charges required by law or imposed by exchanges or regulatory bodies. Fees for these
platforms are found in the sponsor’s or manager’s Form ADV Part 2A, which will be delivered to
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the client prior to the commencement of investing in the platform. Fees for similarly situated
accounts will differ due to negotiation of the advisory fee with the IAR, size of the account,
complexity of the client’s servicing needs, long-term or family relationship with the IAR and
services requested and time commitment.
Further information regarding fees and charges assessed by any mutual funds, variable annuities
and exchange traded funds which are passed down to a client are further outlined in the sponsor’s or
manager’s Form ADV, and in that mutual fund’s or annuity’s prospectus, which is available upon
request by contacting your IAR.
Important information related to the fees for all available investment platforms are described in
additional detail below.
TBFO Asset Allocation Program Fees
LPL Financial (“LPL”) sponsored platforms:
Strategic Wealth Management (“SWM”) - The SWM platform is an open architecture, fee-based
investment platform. Through this platform, clients can consolidate multiple investments into one
account and receive one statement. There is no minimum account size required for utilizing the
SWM platform. The platform is available in two forms, the selection of which is mutually
determined at the inception of the engagement:
• SWM – clients pay both the advisory fee and all transaction costs.
• SWM II – transaction costs are included in a single fee that covers both advisory fees
and transaction costs, the latter of which is paid by the adviser.
Charles Schwab & Co., Inc. (“CS&Co.”) Technology Platforms:
Schwab Institutional (“SCHWAB INSTITUTIONAL”) – The Schwab Institutional program is an
open architecture, fee-based investment platform. Through this platform, clients can consolidate multiple
investments into one account and receive one statement. There is no minimum account size required for
utilizing the Schwab Institutional program.
Fidelity Institutional Asset Management (“FIAM”)
The Fidelity Institutional Asset Management (“FIAM”) program is an open architecture, fee-
based investment platform. Through this platform, clients can consolidate multiple investments
into one account and receive one statement. There is no minimum account size required for
utilizing the FIAM program.
2) Asset Based Fee Option
If a client chooses the Asset Based Fee Option (“ABFO”), the client’s account will be charged a
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single periodic fee for advisory services, transaction charges, brokerage and related services based on
the value of assets in a client’s account. Those fees are in lieu of regular transaction-based charges
and do not vary based on the number or size of trades in a client’s account. The appropriateness of
the ABFO can depend on a number of factors, including, among other things, client investment
objectives and financial situation, frequency of withdrawals from the accounts, the IAR’s
investment strategies and trading patterns including the frequency of trading and the number and
size of the transactions. Clients should consider that depending upon the level of the fee charges,
the amount of portfolio activity in their accounts, the value of services that are provided, and other
factors, the ABFO fee (defined below) can exceed the aggregate cost of services if they were to be
provided separately. A transaction-based pricing arrangement can be more cost effective for
accounts that do not experience frequent trading activity or client withdrawals, which would
increase the number of transactions.
Under the ABFO, advisory fees are paid by the client, while trading costs of transactions are paid
by the client’s IAR. In an ABFO arrangement, the Firm and/or the IAR can or will have negotiated
with a custodian for a flat basis point or flat fee to cover all of the transaction charges.
Important information related to the fees for all available investment platforms are described in
additional detail below.
ABFO Asset Allocation and Managed Account Program Fees
The following LPL Financial (“LPL”) sponsored platforms are offered to our clients and can or will
have an ABFO model:
LPL Financial (“LPL”) sponsored platforms:
The total platform fees charged under the MWP, OMP, PWP, MAS, SMS, and GWP platforms
(described above) are fully outlined in the LPL disclosure brochure and the platform agreement entered
into between LPL, the client, and the Firm. The platform fee is charged to the client as part of
the Firm’s advisory fee. LPL will receive the portion of the advisory fee that represents the
amount of the platform fee. The advisory fee received by the Firm and its IARs is based on a
negotiated percentage of the maximum platform fee and varies depending on the extent of
services being provided.
The account fee charged to the client for each LPL advisory program is subject to the
following maximum account fees:
SWM Platform
MWP Platform
OMP Platform
PWP Platform
MAS Platform
MAN Platform
2.75% (advisor fee)
2.60% (LPL program fee, strategist fee, and an advisor fee)
2.50% (LPL program fee and an advisor fee)
2.50% (LPL fee, separate account manager fees, and an advisor fee)
2.50% (LPL program fee, manager fee, and an advisor fee)
2.75% advisor fee (program fee, portfolio manager fee are additional)
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GWP Platform
1.35% (LPL program fee and an advisor fee)
The platform fees for the MWP, OMP, PWP, MAS, and GWP platforms are negotiable and
calculated by LPL at the beginning of each quarter based on the value of the client’s assets
invested in the platform as of the close of business on the last day of the preceding quarter. LPL
will deduct the full platform fee from the client’s platform account as authorized by the client in
the platform agreement, unless other arrangements have been agreed to in writing, and will pay
the Firm its advisory fee. LPL’s refund policy is fully outlined in the LPL disclosure brochure
for each platform, which is provided to platform clients and should be fully reviewed upon
receipt.
For the MAN platform, LPL will deduct and pay the Firm’s advisory fee from the client’s platform
account as authorized by the client in the Investment Advisory Agreement, unless other
arrangements have been agreed to in writing.
Schwab Sponsored Platforms:
The total program fees charged under the SELECT, ACCESS, and MARKETPLACE programs
are fully outlined in the CS&Co. disclosure brochure and the program agreement entered into
between CS&Co., the client, and the Firm. These program fees are in addition to the investment
advisory fees charged by the Firm, which are outlined above.
The program fees for the SELECT, ACCESS, and MARKETPLACE programs are negotiable at
CS&Co.’s discretion and are calculated and deducted by CS&Co. from the client’s program
account in the month following the month for which the fees were incurred. CS&Co.’s refund
policy is fully outlined in the CS&Co. disclosure brochure, which is provided to program clients
and should be fully reviewed upon receipt.
LPL’s Separate Assessment of Oversight Fees for the Firm
Clients should also understand that LPL is responsible under FINRA rules for supervising certain
business activities of the Firm and its dually registered persons (“Dually Registered Persons”) that
are conducted through broker-dealers and custodians other than LPL. LPL charges a fee for its
oversight of activities conducted through these other broker-dealers and custodians. This
arrangement presents a conflict of interest because the Firm has a financial incentive to recommend
that you maintain your account with LPL rather than with another platform custodian to avoid
incurring the oversight fee.
In addition, all clients, whether engaging the Firm under the ABFO or TBFO, will incur additional
charges as detailed in the paragraphs above.
For additional information on our financial affiliations please refer to Item 10 of this Brochure.
Please Note: LPL is affiliated with Private Trust Company, N.A., a trust company licensed in all 50
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states under a national bank charter (“PTC”). To the extent that a client elects to utilize LPL as their
custodian, LPL will direct the client’s IRA assets to be held at PTC. As such, clients can incur an
Annual IRA maintenance fee charged by PTC. Any Annual IRA maintenance fees incurred by the
client shall be separate and in addition to the Firm’s investment advisory fee.
Consulting and Financial Planning Services
Consulting and Financial Planning Services are charged through a fixed fee, hourly, or subscription
fee arrangement as agreed upon between the client and the IAR. Fees are negotiable and vary
depending upon the complexity of the client’s situation and services to be provided.
Fixed fees typically range from $2,500 to $50,000 depending on the complexity of the project and
services. Note: In the event the total annual fixed fee is less than $1,000, one half (1/2) of the fee
can or will be collected up front, with the remaining one half (1/2) being collected at the
presentation of plan.
Hourly rates range from $100 - $400 per hour, depending on the experience and qualifications of the
IAR. An estimate for total hours is determined at the start of the Consulting and Financial Planning
Services relationship.
Subscription fees, also known as flexible payment program fees, allow an advisor to spread the
billing of their consulting and financial planning fees out over a longer term for convenience to a
client/family. The fees can be billed monthly, quarterly, and bi-annually. Our firm uses a technology
payment program through AdvicePay. We use this system to track payments, provide transparency,
and allow cancellation of payments by a client. Clients who engage in financial planning and
consulting services will be provided a separate agreement to outline the scope of engagement and
disclose all aspects of the services provided to include billing and obligations of the advisor.
Fees for Consulting and Financial Planning Services are subject to negotiation and, in the
discretion of the Firm, will differ from the above schedule due to size of total estate,
complexity, additional services needed, and time commitment.
For clients receiving Consulting and Financial Planning Services who are also investment advisory
clients of the Firm, all or a portion of such client’s Consulting and Financial Planning Services fees
can be waived, at the discretion of the IAR. Please note that comparable financial planning services
can be available elsewhere for a lower cost to the client.
Private Funds
Clients may invest in affiliated and unaffiliated private funds and other privately offered investment
vehicles. Clients will be subject to management fees and/or other fees in addition to the Firm’s
advisory fee, if applicable. The fees and expenses of each vehicle are fully described in the offering
materials. A conflict of interest exists when the Firm causes clients to invest in investment products
advised by its affiliates where the Firm or the affiliate receives additional fees. The Firm has sought
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to mitigate this conflict as detailed below under “Conflicts of Interest.”
Investors in such privately offered vehicles must meet specific suitability and investor eligibility
requirements in order to invest and specific opportunities may require higher levels of investment.
Options Strategy Fees
For our options strategies, the advisory fee is based upon either the notional value or market value
of assets under management on the last day of the previous quarter (including margin release, net
unrealized appreciation or depreciation of investments of cash, cash equivalents and accrued
interest) depending on the strategy and Agreement in place. The fee relating to the options strategy
is set forth in a separate fee addendum and may range up to 1.50% of assets under management,
charged per annum. All fee arrangements for our options strategies are subject to negotiation.
Variable Prepaid Forwards Fees
For our variable prepaid forward strategies, the standard advisory fee is charged to the managed
account(s) and a strategy fee generally equal to 0.30% of assets is charged to the collateral account,
per annum. All fee arrangements for our variable prepaid forwards strategies are subject to
negotiation.
Educational Events
IARs can host educational events (“Events”) on various financial topics, at no charge to clients. that
encourage clients to seek investment advisory services. From time to time, the Firm’s personnel,
including its owners, can participate in such Events.
Internal Mutual Fund & Variable Annuity Expenses
Generally, mutual fund and variable annuity companies impose internal fees and expenses to
manage their investment companies. Such fees are in addition to any custodial or platform costs and
advisory fees associated with the Firm’s services described above. Complete details of such internal
expenses are specified and disclosed in each mutual fund and variable annuity company’s prospectus.
Clients are strongly advised to review the prospectus(es) prior to investing in such securities.
If deemed appropriate for a client, our IARs recommend clients utilize fee-based variable annuities,
including through a third-party provider of a platform of insurance consultation services. Fee-based
variable annuities are not assessed transaction fees since the reallocation of transactions are placed
directly with the variable annuity sponsor.
However, variable annuity companies generally impose mortality and expense charges of
approximately 0.45% - 1.5% annually on the overall assets. Variable annuity companies often also
have additional riders or features on the contract as well which add additional costs. Please read
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and understand the total fees for your contract. Clients are encouraged to review the variable annuity
prospectus prior to investing.
Clients can purchase shares of mutual funds directly from the mutual fund issuer, its principal
underwriter or a distributor without paying for the services of the Firm. Certain mutual funds are
offered to the public without a sales charge. In the case of mutual funds offered with a sales charge, the
prevailing sales charge (as described in the mutual fund prospectus) can be more or less than the
applicable advisory fee and is in addition to such fee. However, if clients were to purchase shares
directly, then clients would not receive any investment advice from the Firm, including the IAR’s
assistance in developing an investment strategy, selecting securities, monitoring performance of the
account, and making changes as necessary.
Clearing & Custodial Arrangements
LPL, Schwab, SEI, Fidelity and Pershing can execute trades, settle securities transactions, and custody
client assets on behalf of our clients using Direct Asset Management Services. For further details
concerning these arrangements, clients should refer to the Investment Advisory Agreement and/or
other related disclosure documents relative to the type of account they select.
Due to the unique nature of fee-based variable annuities, they must be maintained directly with the
variable annuity sponsor. Neither the IAR nor the Firm creates or forwards client account statements
or confirmations relating to variable annuities. This responsibility remains exclusively with the
variable annuity sponsor. All subaccount reallocations are directed to and executed at the variable
annuity sponsor.
Conflicts of Interest
When allocating investment opportunities among our investment programs, products and clients, the Firm
has an incentive to favor the investment programs, products and clients that generate the most revenue for
Mariner. For example, when recommending the use of a third-party manager, the Firm has an incentive
to recommend a manager which charges a separate fee instead of paying the manager out of the Firm’s
fee.
As further detailed in Item 10, Mariner and its principal voting owners, MWA, 1248, LGP and NBAA,
own or have interests in various other investment-related service providers and investment managers and
other financial entities. As such, we have an indirect financial incentive to recommend other financial
services and products provided by such entities and their respective affiliates because revenues earned by
them from such services and products ultimately flow to the principal voting owners of Mariner. We seek
to manage this conflict by disclosing it to clients and not sharing any revenue from affiliated private funds
and other investment-related services and products with the wealth advisors who recommend client
investments. Further, such services, products and funds are recommended to clients by IARs with
considerations of various factors, including but not limited to, the client’s investment objective and
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financial circumstances. For additional discussion of the conflicts of interest presented by Mariner’s use
of affiliated services and products, Please see Item 10 – Other Financial Industry Activities and
Affiliations.
Compensation of Employees for Sale of Securities or Other Products
As permitted by applicable law, we compensate certain employees for business development activities,
including the attraction or retention of client assets. It is expected that IARs will be entitled to receive
and share in the advisory fees payable to the Firm by a client.
As noted above, Mariner and its affiliates offer a variety of services and products to our clients beyond investment
advisory services. Certain representatives of Mariner are entitled to receive compensation from affiliates for
referring clients for services and products provided by the affiliate.
Certain representatives of the Firm are licensed insurance agents and are compensated for the sale of insurance-
related products. To the extent such insurance products have commissions payable to the IAR, this presents a
conflict of interest for the IAR to recommend such products for additional compensation.
For additional discussion of the conflicts of interest presented by the Firm’s use of affiliated services and products,
please see Item 10 – Other Financial Industry Activities and Affiliations.
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Item 6-Performance Based Fees and Side-By-Side Management
Performance-Based Fees
We do not charge any performance-based compensation (fees based on a share of capital gains on
or capital appreciation of the assets of a client). If deemed appropriate for a particular client, our
recommended investments include investment products that charge performance-based fees,
including investment products managed by affiliates of the Firm.
Side-by-Side Management
In some cases, IARs of the Firm manage clients in the same or similar strategies. This may give
rise to potential conflicts of interest if the clients have, among other things, different objectives or
fees. For example, potential conflicts may arise in the following areas: client orders do not get fully
executed; trades may get executed for an account that may adversely impact the value of securities
held by a client; there will be cases where certain clients receive an allocation of an investment
opportunity when other accounts may not; and/or trading and securities selected for a particular
client may cause differences in the performance of different accounts or funds that have similar
strategies.
From time to time, IARs of the Firm may recommend that certain of the Firm clients invest in limited
investment opportunities. The allocation of these investments across client portfolios is generally
not executed on a pro rata basis as a number of factors will determine whether the limited offering is
appropriate or suitable for a client. Accordingly, such opportunities may be allocated based on
another approach, including random selection, selection based on account size or another
methodology. Factors which may impact the allocation, including but are not limited to: account
size, liquidity, investor qualification and risk tolerance. We note that limited investment
opportunities may not be appropriate for smaller accounts, depending on factors such as minimum
investment size, account size, risk, and diversification requirements, and accordingly may not be
allocated such investments. Certain limited investment opportunities are available only to clients of
certain IARs of the Firm.
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Item 7-Types of Clients
There are minimum account size requirements for Direct Asset Management Services as well as
Consulting and Financial Planning Services offered through the Firm and the individual IARs that
are affiliated with the Firm. In addition, there can be minimum account size requirements
established by the particular investment platforms of the Custodians used by the IARs. The Firm,
office, or the custodian can waive these minimum account size requirements.
Our IARs provide personal advisory services to individuals, high net worth individuals, pension and
profit-sharing plans, including plans subject to the ERISA, trusts, estates, charitable organizations,
and corporations, as well as other business entities.
If a client’s account is a pension or other employee benefit plan governed by ERISA, the Firm can
be a 3(21) fiduciary to the plan. In providing our investment advisory services, the sole standard of
care imposed upon us is to act with the care, skill, prudence and diligence under the circumstances
then prevailing that a prudent person acting in a like capacity and familiar with such matters would
use in the conduct of an enterprise of a like character and with like aims.
We will provide certain required disclosures to the “Responsible Plan Fiduciary” (as such term is
defined in ERISA) in accordance with Section 408(b)(2), regarding the services we provide and the
direct and indirect compensation we receive by such clients. Generally, these disclosures are
contained in this Brochure or the RCPA and are designed to enable the ERISA plan’s fiduciary to:
(1) determine the reasonableness of all compensation received by us; (2) identify any potential
conflicts of interest; and (3) satisfy reporting and disclosure requirements to plan participants.
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Item 8-Methods of Analysis, Sources of Information, Investment Strategies, and Risk of Loss
Our IARs providing Direct Asset Management Services work independently from one another and
employ varying philosophies, strategies, and tools in their investment analysis and due diligence
processes. Any one of our IARs could utilize the following methods of analysis and strategies:
• Fundamental
• Technical
• Quantitative
• Qualitative
Our IARs provide advice and recommendations on equity securities, warrants, options, certificates
of deposit, limited partnerships, futures contracts, variable life insurance, fee-based variable
annuities, mutual funds, ETFs, municipal securities, U.S. government securities, structured notes
and debt instruments.
Our IARs apply generally accepted investment theories so that investment choices for clients align
with the client’s investment needs and objectives and are made with the objective to reasonably
diversify client assets to help minimize the risk of large losses and to provide the potential for varying
degrees of long-term appreciation and capital preservation. Our IARs generally use a mix of equity
and fixed income exposures to achieve the desired investment objective. IARs will diversify,
reallocate and rebalance the investments and associated risk levels over time in accordance with
generally accepted investment theories and consistent with the client’s investment objective. IARs
can make recommendations for changes to the underlying investments and/or the asset allocation
percentages of any model portfolios as well.
IARs providing Direct Asset Management Services have access to online portfolio software tools
that assist in analyzing client portfolios. Such software is based upon Modern Portfolio Theory
(“MPT”). MPT attempts to balance a portfolio’s risk and return level based on a particular client’s
risk tolerance and investment objectives. Various research tools are used in conjunction with asset
allocation software to provide clients with access to risk tolerance assessments, efficient frontier
plotting, fund profiling and performance data, as well as portfolio optimization and re-balancing
tools.
In addition, our IARs can use, without limitation, any of the following methods of analysis and
sources of information: charting, fundamental technical and cyclical analysis; financial newspapers
and magazines; research materials prepared by others; timing services; corporate rating services
such as Morningstar, annual reports, prospectuses and press releases.
In the implementation of their analyses, IARs use some or all of the following strategies at any given
time:
• Long-Term Purchases – securities purchased with the expectation that the value of those
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securities will grow over a relatively long period of time, generally greater than one year.
• Short-Term Purchases – securities purchased with the expectation that they will be sold within
a relatively short period of time, generally less than one year, to take advantage of the securities’
short-term price fluctuations. Short-term gains in taxable accounts are subject to federal income
tax at higher rates than long-term gains. This difference in tax treatment is a disadvantage of
short-term trades for taxable clients.
• Trading – Representatives can use short-term trades (in general, selling securities within 30 days
of purchasing the same securities) when managing account(s). An IAR can sell a security soon
after purchasing it on occasions when they determine that there is a reasonable basis for the sale,
and it is suitable given a client’s stated investment objectives and tolerance for risk. Short-term
gains in taxable accounts are subject to federal income tax at higher rates than long-term gains,
while losses realized on securities held 30 days or less are generally not tax deductible. These
differences in tax treatment are disadvantages of short-term trades for taxable clients. There is
also risk in that high velocity trading creates substantial transaction costs that in aggregate could
negatively impact account performance.
• Short Sales – securities transactions in which an investor sells securities he or she borrowed in
anticipation of a price decline. The investor is then required to return an equal number of shares
at some point in the future. A short seller will profit if the stock goes down in price. The risk
associated with a short sale is the potential of unlimited loss should the underlying value of the
short position increase in value instead of the anticipated decline. Another risk is buy-in risk.
Once borrowed, the shares are subject to buy-in at any time, which could force the client to
cover the short position at a disadvantageous time or price. Short sales require the use of margin,
which can increase cost and risk. Additional costs include interest on the value of borrowed
securities. Risks also include additional margin calls in response to market fluctuations or at the
discretion of the custodian.
• Margin Transactions – a securities transaction in which an investor borrows money to purchase
a security, in which case the security serves as collateral on the loan. This allows the client to
purchase more stock than they would otherwise be able to, based on the account’s available
cash, and would allow the IAR to purchase stock without selling other holdings, which is
therefore a higher risk strategy. Securities purchased on margin are subject to liquidation,
additional margin calls, and interest on the funds borrowed. Should the value of the securities
decline, clients can be forced to deposit additional margin with limited notice, or to liquidate
their securities at substantial losses.
• Option Purchases and Option Writing – Purchasing a long option gives the buyer the right, but
not the obligation, to buy or sell a particular security at a specified price before the expiration
date of the option. When an investor writes (or sells) an option, he or she is obligated to deliver
to the buyer of the option a specified number of shares (or the calculated money difference) if
the buyer exercises the option. The Firm does not generally permit uncovered option writing in
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advisory accounts. The seller receives a premium in exchange for writing the option. Options are
wasting assets and expire at pre-determined dates. Commission charges for options transactions
can be higher than the charges assessed for other assets, such as individual equities.
Please note: Investing in securities involves risk of loss that clients should be prepared to bear.
While the value of your investments could increase and your account(s) thereby enjoy a gain, it is
also possible that the value of your investments could decrease and your account(s) thereby suffer
a loss, including a complete loss. It is important that you understand the risks associated with
investing in the securities markets, that you be appropriately diversified in your investments, and that
you ask us any questions you have.
Although we seek to manage your account assets in a manner consistent with your stated investment
objectives and risk tolerances, we do not represent or guarantee that our services or methods of
analysis can or will predict future results, successfully identify market tops or bottoms, or insulate
clients from losses due to market corrections or declines. We cannot offer any guarantees that your
financial goals and objectives will be met. Past performance is in no way an indication or guarantee
of future performance.
Prior to entering into an Investment Advisory Agreement with us, a client should carefully consider:
(1) committing to management only those assets that the client believes will not be needed for
current purposes and that can be invested on a long-term basis, usually a minimum of three to five
years, (2) that volatility from investing in the stock and bond markets can occur, and
(3) that over time the client’s assets can fluctuate and at any time be worth more or less than the
amount invested.
Described below are some particular risks associated with some types of investments we can
recommend. Risk is inseparable from return. Every investment involves some degree of risk, and
both the degree of risk and the type of risk varies depending on the investment. For example, the
risk of loss to principal can be very close to zero in the case of a US Treasury security, or very high
for something such as a concentrated exposure to one specific foreign security. On the other hand,
purchasing power risk for a US Treasury security can be higher than the purchasing power risk of a
higher-yield corporate bond or an equity. An understanding of risk in different forms can help clients
to understand the opportunities, trade-offs and costs involved with different investment approaches.
The principal risk of any investment is that despite any comprehensive analysis, the security or
instrument will not perform as expected. This can be due to, among other things:
• Alternative Investment Risk: There are a number of different risks involved with alternative
investments, including some or all of those listed below. The risks vary depending on the type
of alternative investment, with the main risks generally being illiquidity, higher and multi
layered fee structures, complex investments, less transparency, tax issues; and lack of
diversification of investments.
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• Geopolitical Risks – Unexpected political, regulatory and diplomatic events within the United
States and abroad, such as the U.S.-China “trade war,” may affect investor and consumer
confidence and may adversely impact financial markets and the broader economy, perhaps
suddenly and to a significant degree. The current political climate and the renewal or escalation
of a trade wars between United States and other countries may have an adverse effect on both
the U.S. and such other countries’ economies, including as the result of one country’s imposition
of tariffs on the other country’s products. In addition, sanctions or other investment restrictions
could preclude the clients from investing in certain non-U.S. issuers or cause the clients to sell
investments at disadvantageous times. Events such as these and their impact on clients and their
investments are difficult to predict and further tariffs may be imposed or other escalating actions
may be taken in the future.
For example, the United States recently imposed additional tariffs on imports from certain
countries. These additional tariffs, as well as a government’s adoption of “buy national” policies
or retaliation by another government against such tariffs or policies may have introduced
significant uncertainty into the market. At this time, it remains unclear what additional actions,
if any, will be taken by the United States or other governments with respect to international trade
agreements, the imposition of additional tariffs on goods imported into the United States, tax
policy related to international commerce, increased export control, sanctions and investment
restrictions, or other trade matters. Other effects of these changes, including impacts on the price
of raw materials, and responsive or retaliatory actions from governments could also have
significant impacts on markets.
• Federal Workforce Reductions and Budget Cuts – The current administration has commenced
efforts to implement significant changes to the size and scope of the federal government and
reform its operations to achieve stated goals that include reducing the federal budget deficit and
national debt, improving the efficiency of government operations, and promoting innovation
and economic growth. To date, these efforts have been carried out through a mix of executive
actions aimed at eliminating or modifying federal agency and federal program funding, reducing
the size of the federal workforce, reducing or altering the scope of activities conducted by, and
possibly eliminating, various federal agencies and bureaus, and encouraging the use of artificial
intelligence and other advanced technologies within the public and private sectors. These
changes, if implemented and taken as a whole, may have varied effects on the economy that are
difficult to predict. For instance, the delivery of government services and the distribution of
federal program funds and benefits may be disrupted or, in some cases, eliminated as a result of
funding cuts or recasting of federal agency mandates. Further, a substantial reduction of the
federal workforce could adversely affect regional and local economies, both directly and
indirectly, in geographies with significant concentrations of federal employees and contractors.
It is possible that such comprehensive changes to the federal government may be materially
adverse to the regional and local economies and financial markets more broadly.
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•
Interest-Rate Risk – Fluctuations in interest rates can cause investment prices to fluctuate. For
example, when interest rates rise, yields on existing bonds become less attractive, causing their
market values to decline.
• Risks Related to Conflicts of Interest – Various conflicts of interest are discussed throughout
this document. Please review this information carefully and contact us if you have any questions.
• Data Sources Risks – The Firm uses external software applications to analyze performance
attribution and to assist in investment decision making or investment research. As a result, if
information that the Firm receives from a third-party data source is incorrect, the Firm may not
achieve the desired results. Although the Firm has found the third-party data sources to be
generally reliable, the Firm typically receives these services “as is” and cannot guarantee that
the data received from these sources is accurate.
• Equity Risk: Investments in equity securities generally involve a high degree of risk. Prices are
volatile and market movements are difficult to predict. These price movements can result
from factors affecting individual companies or industries. Price changes can be temporary or
last for extended periods. In addition to, or in spite of, the impact of movements in the overall
stock market, the value of investments can decline if the particular investments within the
portfolio do not perform well in the market. Prices of growth stocks can be more sensitive to
changes in current or expected earnings than prices of other stocks. Prices of stocks can fall or
fail to appreciate regardless of movements in securities markets. A higher turnover rate, or
increased trading can result in higher transactions costs and higher taxes in taxable accounts and
can also affect the strategies’ overall performance.
• Market Risk: The price of a stock, bond, mutual fund or other security can drop in reaction to
tangible and intangible economic and market conditions, such as interest rates, availability of
credit, inflation rates, commodity prices, economic uncertainty, changes in laws, trade barriers,
currency fluctuations and controls, and national and international political circumstances. These
factors can affect the levels of volatility of securities prices and the liquidity of investments in
client portfolios. Such volatility or illiquidity could impair profitability or result in losses.
• Management Risk: the strategies utilized by the Firm, as well as portfolio managers of mutual
funds and ETFs, can or will not be successful in some market conditions.
• 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.
• Fixed Income Risks: investments in fixed income securities represent numerous risks such as
credit, interest rate, reinvestment, and prepayment risk, all of which affect their price/value.
These risks represent the potential for a large amount of price volatility. In general, securities
with longer maturities are more sensitive to price changes. Additionally, the prices of high-yield,
fixed income securities fluctuate more than high-quality debt issues. Prices are especially
Mariner Independent Advisor Network, LLC-Form ADV Part 2A
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sensitive to developments affecting the company’s business and to changes in the ratings
assigned by rating agencies. Prices are often closely linked with the company’s stock prices.
High-yield securities can experience sudden and sharp price swings due to changes in economic
conditions, stock market activity, large sales by major investors, default, or other factors. In the
event of a default, the investment can suffer a partial or total loss.
• Business Risk: These risks are associated with a particular industry or a particular company within
an industry. Generally, business risk is that a company will go bankrupt or perform below
expectations. Every company carries the business risk that it will produce insufficient cash flow in
order to maintain operations. Business risk can come from a variety of sources, some systemic
and others un-systemic. That is, every company has the business risk that the broader economy
will perform poorly and therefore that sales will be poor, and also the risk that the market simply
will not like its products.
• Market Liquidity Risk: Liquidity is the ability to readily convert an investment into cash.
Generally, assets are more liquid if there is an active market for the asset. For example, Treasury
Bills are highly liquid, while real estate properties are not. The value of securities held in client
accounts that are traded on exchanges and the risks associated with holding these positions vary
in response to events that affect asset markets in general. Market disruptions such as those that
occurred in 1987, in September 2001, and more recently the “Flash Crash” in May 2010 (the
biggest one-day point decline, 998.5 points, on an intraday basis in Dow Jones Industrial average
history) could lead to violent price swings in securities held within client portfolios and could
result in substantial losses.
• Increased Regulations: Events during the past several years and adverse financial results have
focused attention upon the necessity to maintain adequate risk controls and compliance
procedures. These events have led to increased governmental and self- regulatory authority
scrutiny of the financial industry. Various national governments have also expressed concern
regarding disruptive effects of speculative trading and the need to regulate the markets in
general. Any regulations that restrict the ability to employ, or broker-dealers and counterparties
to extend credit or restrict trading activities could adversely impact profit potential.
• Leverage 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 can result in bankruptcy
and/or a declining market value.
• Short Sales, Leverage and Derivatives Risk: Short sales, leverage and derivatives all represent
substantial risks given their inherent heightened risk of loss. Leverage and derivatives imply
borrowing capital. When such borrowing is deployed, losses can escalate quickly should
investment suffer even small losses. Short sales involve a finite opportunity for appreciation,
but a theoretically unlimited risk of loss. Short positions can also be subject to a “short squeeze”
that could lead to accelerating losses for those short that particular security.
Mariner Independent Advisor Network, LLC-Form ADV Part 2A
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• Counterparty Risk: the risk that the other party in a transaction will not fulfill its contractual
obligations.
• Expenses Risk: When investing in mutual funds and exchange traded funds, master limited
partnerships, and REITs, and other pooled investments, the investor will incur a proportionate
share of the expenses of the investment (including operating costs and investment management
fees), in addition to the advisory fees and other expenses charged to the investor’s assets invested
in the pooled investment.
• Small Capitalization Companies: a portion of assets can be invested in smaller and less
established companies. Both debt and equity securities of such issuers tend to be more volatile
than larger, more established companies. Such volatility could adversely impact client
portfolios.
• Large Company Risk: The stocks of large capitalization companies can perform differently from
other segments of the equity market or from the equity market as a whole. Large capitalization
companies can be less flexible in evolving markets or unable to implement change as quickly
as smaller capitalization companies.
• Credit Risk: the market’s perception of a bond issuer’s ability to pay interest and repay principal.
• Convertible Arbitrage Risk: If interest rates on the convertible security rise, its value usually falls.
• Tax Risk: The Firm in some cases can or will not manage client accounts with tax consequences
in mind. Some strategies, including transactions in options and futures contracts, can be subject
to special tax rules, which can have adverse consequences for the account holder.
• Non-US Investments: Client funds can be invested in securities (e.g., debt, equity, currencies,
derivatives, etc.) of issuers domiciled outside the United States. Such investments expose a
portfolio to a number of risks that can or will not exist in the domestic market alone. Such risks
include, among other things, trade balances and imbalances and related economic policies,
currency exchange rate fluctuations, imposition of exchange control regulation, withholding
taxes, limitations on the removal of funds or other assets, possible nationalization of assets or
industries, political difficulties, and political instability in foreign nations.
• Extraordinary Events: global terrorist activity and United States involvement in armed conflict
can negatively affect general economic prospects, including sales, profits, and production, and
can lead to depressed securities prices and problems relating to infrastructure and trading
facilities.
• Potential Concentration: Client portfolios can have highly concentrated positions in issuers
engaged in one or a few industries. This increases the risk of loss relative to the market as a
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whole.
• Pledging Assets: Certain custodians utilized by the Firm have partnered with certain banks to
help facilitate clients’ access to collateralized non-purpose lines of credit; however, clients are
not required to use these banks, and can work directly with other banks (“nonpartner banks”) to
negotiate loan terms or obtain other financing arrangements. Clients who choose to use non-
partner banks should notify their IARs of the amount of the line of credit. In these collateralized
lending arrangements, clients borrow from the bank and pay interest to the bank. In some cases,
an IAR may recommend that a client seeking to access funds (for purposes other than purchasing
securities) hold his securities investments and instead utilize a non- purpose line of credit
collateralized by the assets in his advisory account. Unless an IAR specifically recommends that
a client hold his securities investments and instead utilize a collateralized line of credit to access
funds, the decision regarding whether to arrange for a collateralized loan and the decision to
draw down on such a loan are not covered by a client’s advisory relationship with LPL or his IAR.
While an IAR may assist the client with facilitating a line of credit, clients are responsible for
independently evaluating the terms of the loan and deciding whether the loan meets their needs.
Clients also should be aware that pledging assets in an account to secure a loan involves
additional risks. The bank holding the loan has the authority to liquidate all or part of the
securities at any time without your prior notice in order to maintain required maintenance levels,
or to call the loan at any time. As a practical matter, this may cause you to sell assets and realize
losses in a declining market. Moreover, an IAR’s ability to make investment decisions or
recommendations for the account may be restricted by collateral requirements imposed by the
bank. These restrictions or a forced liquidation may interfere with your long-term investment
goals and/or result in adverse tax consequences. Further, you should note that the returns on
accounts or on pledged assets may not cover the cost of loan interest and advisory fees. Clients
should be aware that collateralized loan programs are one way, among many, for clients to raise
necessary cash. Before pledging assets in an account, clients should carefully review the loan
agreements, loan applications and any forms required by the bank and any other forms and
disclosures provided by the custodian. For additional information, please review the link to an
SEC bulletin on Securities-Backed Lines of Credit (SBLOC).
Lastly, please know that there is a conflict of interest for an advisor to recommend an SBLOC
since they will continue to receive advisory compensation while the SBLOC is in place in the
account. Please feel free to discuss this conflict of interest with your advisor and review your
options for accessing capital.
• Collateralized Debt Obligations, Collateralized Loan Obligations: IARs may invest client
accounts in collateralized debt obligations (“CDO”), collateralized loan obligations (“CLO”)
and other related instruments. The portfolio may consist of CLO equity, multi-sector CDO
equity, trust preferred CDO equity and CLO mezzanine debt. Such securities are subject to
credit, liquidity and interest rate risks. The equity and other tranches purchased by a client may
be unrated or non-investment grade, which means that a greater possibility that adverse changes
in the financial condition of an issuer or in general economic conditions or both may impair the
Mariner Independent Advisor Network, LLC-Form ADV Part 2A
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ability of the related issuer or obligor to make payments of principal or interest. Such
investments may be speculative. In addition, as a holder of equity, there are limited remedies
available upon the default of the CLO or CDO.
• Structured Notes: IARs may invest clients’ accounts in structured notes. These are complex
instruments consisting of a bond component and an imbedded derivative. Structured notes that
provide for the repayment of principal at maturity are subject to the credit risk of the issuing
financial institution. Structured notes that do not offer this protection may cause a client to lose
some, or all, of its principal. Depending on the nature of the linked asset or index, the market
risk of the structured note may include changes in equity or commodity prices, changes in
interest rates or foreign exchange rates, or market volatility. After issuance, structured notes
may not be re-sold on a daily basis and thus may be difficult to value given their complexity. A
client’s ability to trade or sell structured notes in a secondary market is often very limited and
clients should, therefore, be prepared to hold a structured note to its maturity date, or risk selling
the note at a discount to its value at the time of sale. Structured notes may have complicated
payoff structures that can make it difficult for clients to accurately assess their value, risk and
potential for growth through the term of the structured note. Determining the performance of
each note can be complex and this calculation can vary significantly from note to note depending
on the structure. Notes can be structured in a wide variety of ways. Structured notes expose
investors to credit risk: if the structured note issuer defaults on these obligations, investors may
lose some, or all, of the principal amount they invested in the structured notes as well as any
other payments that may be due on the structured notes. If a structured note has a “call
provision” and the issuer “calls” the structured note, investors may not be able to reinvest their
money at the same rate of return provided by the structured note that the issuer redeemed.
• Variable Prepaid Forwards: We offer variable prepaid forward (VPF) strategies to our clients.
A VPF is an agreement to sell a variable number of shares at a specified future date (typically
one to three years) in exchange for the upfront cash payment. The cash payment is generally
between 70% and 90% of the stock’s current market value and is determined based on factors
such as the stock position, size, interest rates, volatility, duration, and structure. To execute a
variable prepaid forward, the investor executes an equity collar, choosing the maturity date,
floor price, and cap price. The investor receives cash immediately equal to the floor price per
share, less the financing costs, less the cost of the equity collar (if any). The investor continues
to hold the underlying stock during its life, retaining voting rights and dividends.
A variable prepaid forward contact risks include but are not limited to: Complexity and Legal
Risk - Negotiating and structuring a VPF contract requires legal and financial expertise. Poorly
structured contracts may lead to unintended tax implications or liquidity constraints so
professional legal advice is essential. Market/Derivative Risk - Since the transaction sets a cap
on potential gains, investors may miss out on higher returns if their stock price rises significantly
beyond the contracted threshold. Regulatory and Tax Risk - VPF contracts must be monitored
to ensure compliance with IRS tax regulations. Misuse or structuring contracts improperly could
lead to tax penalties and legal consequences. VPFs also must comply with SEC insider-trading
Mariner Independent Advisor Network, LLC-Form ADV Part 2A
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restrictions and disclosures. Professional tax and legal advice are essential to navigate these
complexities. Liquidity Risk - While VPFs provide liquidity upfront, the investor must deliver
shares or cash at maturity. Financing Risk - The difference between the current market value of
the stock and the cash advance received represents the fixed financing cost, which can be
substantial. Suitability Risk - VPFs are not appropriate for less sophisticated investors and those
with a net worth of less than $5 million. Counterparty Risk - These contracts involve
counterparties such as investment banks or financial institutions. If the counterparty fails to meet
its obligations, the investor could face significant financial losses.
• Master Limited Partnerships (“MLPs”): MLP investing includes risks such as equity and
commodity-like volatility. Also, distribution payouts sometimes include the return of principal
and, in these instances, references to these payouts as “dividends” or “yields” may be inaccurate
and may overstate the profitability/success of the MLP. Additionally, there are potentially
complex and adverse tax consequences associated with investing in MLPs. This is largely
dependent on how the MLPs are structured and the vehicle used to invest in the MLPs.
• Managed Futures: Managed futures strategies typically utilize derivatives, such as futures,
options, structured notes and swap agreements, which provide exposure to the price movements
of a commodity (i.e., oil, grain, livestock) or a financial instrument (i.e., currency, index). The
use of derivatives can be highly volatile, illiquid and difficult to manage. Derivatives involve
greater risks than the underlying obligations because in addition to general market risks, they
are subject to illiquidity risk, counterparty risk, credit risk, pricing risk and leveraging risk. A
highly liquid secondary market may not exist for certain derivatives utilized by this strategy,
and there can be no assurances that one will develop.
• Digital Assets: IARs may invest client accounts in virtual currencies, crypto-currencies, and
digital coins and tokens (“Digital Assets”). The investment characteristics of Digital Assets
generally differ from those of traditional currencies, commodities or securities. Importantly,
Digital Assets are not backed by a central bank or a national, supra-national or quasi-national
organization, any hard assets, human capital, or other form of credit. Rather, Digital Assets are
market-based: a Digital Asset’s value is determined by (and fluctuates often, according to)
supply and demand factors, the number of merchants that accept it, and/or the value that various
market participants place on it through their mutual agreement, barter or transactions.
• Price Volatility of Digital Assets: A principal risk in trading Digital Assets is the rapid
fluctuation of market price. High price volatility undermines Digital Assets’ role as a medium
of exchange as consumers or retailers are much less likely to accept them as a form of payment.
The value of client portfolios relates in part to the value of the Digital Assets held in the client
portfolio and fluctuations in the price of Digital Assets could adversely affect the value of a
client’s portfolio. There is no guarantee that a client will be able to achieve a better than average
market price for Digital Assets or will purchase Digital Assets at the most favorable price
available. The price of Digital Assets achieved by a client may be affected generally by a wide
variety of complex and difficult to predict factors such as Digital Asset supply and demand;
Mariner Independent Advisor Network, LLC-Form ADV Part 2A
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rewards and transaction fees for the recording of transactions on the blockchain; availability and
access to Digital Asset service providers (such as payment processors), exchanges, miners or
other Digital Asset users and market participants; perceived or actual Digital Asset network or
Digital Asset security vulnerability; inflation levels; fiscal policy; interest rates; and political,
natural and economic events.
• Digital Asset Service Providers: Several companies and financial institutions provide services
related to the buying, selling, payment processing and storing of virtual currency (i.e., banks,
accountants, exchanges, digital wallet providers, and payment processors). However, there is no
assurance that the virtual currency market, or the service providers necessary to accommodate
it, will continue to support Digital Assets, continue in existence or grow. Further, there is no
assurance that the availability of and access to virtual currency service providers will not be
negatively affected by government regulation or supply and demand of Digital Assets.
Accordingly, companies or financial institutions that currently support virtual currency may not
do so in the future.
• Custody of Digital Assets: Under the Advisers Act, SEC registered investment advisers are
required to hold securities with “qualified custodians,” among other requirements. Certain
Digital Assets may be deemed to be securities. Currently, many of the companies providing
Digital Assets custodial services fall outside of the SEC’s definition of “qualified custodian”,
and many long-standing, prominent qualified custodians do not provide custodial services for
Digital Assets or otherwise provide such services only with respect to a limited number of
actively traded Digital Assets. Accordingly, clients may use non-qualified custodians to hold all
or a portion of their Digital Assets.
• Government Oversight of Digital Assets: The regulatory schemes—both foreign and
domestic—possibly affecting Digital Assets or a Digital Asset network may not be fully
developed and subject to change. It is possible that any jurisdiction may, in the near or distant
future, adopt laws, regulations, policies or rules directly or indirectly affecting a Digital Asset
network, generally, or restricting the right to acquire, own, hold, sell, convert, trade, or use
Digital Assets, or to exchange Digital Assets for either fiat currency or other virtual currency. It
is also possible that government authorities may take direct or indirect investigative or
prosecutorial action related to, among other things, the use, ownership or transfer of Digital
Assets, resulting in a change to its value or to the development of a Digital Asset network.
Our clients also can elect to open margin accounts. Clients should be aware that there are a number of
additional risks that all investors need to consider in deciding to trade securities on margin. The risks
associated with margin include, but are not limited to, the following:
• Clients can lose more funds than they deposit in the margin account. A decline in the value of
securities that are purchased on margin can require the client to provide additional funds to the
firm that has made the loan to avoid the forced sale of those securities or other securities in
the account.
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• The lending firm can or will be able to force the sale of securities in a margin account. If the
equity in margin account falls below the maintenance requirements under the law—or the
lending firm’s higher "house" requirements—the firm can or will be able to sell the securities
in the margin account to cover the margin deficiency. Clients using margin can also be
responsible for any short fall in the account after such a sale.
In a cash account, your risk is limited to the amount of money that you have invested. In a margin
account, your risk includes the amount of money invested plus the amount that has been loaned to
you.
Other Risks:
• Cybersecurity: The Firm’s information and technology systems may be vulnerable to damage
or interruption from computer viruses, network failures, computer and telecommunication
failures, infiltration by unauthorized persons and security breaches, usage errors by its
professionals, power outages and catastrophic events such as fires, tornadoes, floods, hurricanes
and earthquakes. Although the Firm has implemented various measures to protect the
confidentiality of its internal data and to manage risks relating to these types of events, if these
systems are compromised, become inoperable for extended periods of time or cease to function
properly, the Firm will likely have to make a significant investment to fix or replace them. The
failure of these systems and/or of disaster recovery plans for any reason could cause significant
interruptions in the Firm’s operations and result in a failure to maintain the security,
confidentiality or privacy of sensitive data, including personal information relating to clients.
Such a failure could harm the Firm’s reputation or subject it or its affiliates to legal claims and
otherwise affect their business and financial performance. The Firm will seek to notify affected
clients of any known cybersecurity incident that will likely pose substantial risk of exposing
confidential personal data about such clients to unintended parties. Further, certain IARs of the
Firm may utilize their own information and technology systems and, while IARs will generally
be required to implement cybersecurity measures, the Firm will not control the measures
implemented in order to protect the confidentiality of data and manage risks.
• Regulation Risk: Regulation and laws affecting the Firm change from time to time. The Firm
cannot predict the effects, if any, of future regulatory and legal changes on our business or the
services provided.
• Market Risk: Either the market as a whole, or the value of an individual company, goes down,
resulting in a decrease in the value of client investments. Global markets are interconnected, and
events like hurricanes, floods, earthquakes, forest fires and similar natural disturbances, war,
terrorism or threats of terrorism, civil disorder, public health crises, and similar “Act of God”
events have led, and may in the future lead, to increased short-term market volatility and may
have adverse long-term and wide-spread effects on world economies and markets generally.
Clients may have exposure to countries and markets impacted by such events, which could result
Mariner Independent Advisor Network, LLC-Form ADV Part 2A
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in material losses.
It is important that investors take time to learn about the risks involved in trading securities on
margin, and investors should consult IARs regarding any questions or concerns they have with their
margin accounts.
All investments involve risks that can result in loss including loss of principal, a reduction in
earnings (including interest, dividends and other distributions), and the loss of future earnings. The
summary above is qualified in its entirety by the risk factors set forth in the applicable offering
materials for the applicable product.
Mariner Independent Advisor Network, LLC-Form ADV Part 2A
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Item 9-Disciplinary Information
The Firm is required to disclose all material facts regarding any legal or disciplinary events that would be
material to your evaluation of the Firm, or the integrity of our management. The Firm reviews advisory
personnel records on a periodic basis to ensure that no disciplinary events have been reported. The Firm
has no material legal or disciplinary events in response to this item. The Firm maintains ADV Part 2B for
its advisors, which are provided to each client, and detail each individual team member’s professional
credentialing, and other pertinent information about the advisor.
Mariner Independent Advisor Network, LLC-Form ADV Part 2A
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Item 10-Other Financial Industry Activities and Affiliations
We have relationships that are material to our advisory business or to our clients with related persons
that provide a variety of financial services and products, as detailed below. When appropriate for a
client, we use and/or recommend services and products offered by Mariner, its principal voting
owners, each of their respective affiliates and/or parties in which Mariner or its affiliates have a
financial interest.
With respect to the services and products (including private funds) described herein offered by the
Firm’s principal voting owners and their affiliates, namely Mariner, 1248, LGP and NBAA, there
exists a conflict of interest in our recommending such services or products to the Firm’s clients as
all or a portion of the revenues earned by such parties ultimately flow to Mariner’s principal voting
owners and/or their affiliates. Except as noted herein, the affiliated services, products and private
funds charge fees in addition to the fees charged by the Firm. As such, the Firm has an indirect
financial incentive to recommend other services/products provided and/or private funds managed
by such parties.
Specifically, Martin Bicknell, the CEO and President of Mariner, has significant ownership stakes
in Mariner and 1248, which in turn directly and indirectly hold financial interests in various other
investment advisers and other financial entities, as detailed below. Where the Firm recommends
services or products provided by Mariner, 1248 or its affiliates, the Firm will provide such
recommendations to applicable clients on a fully disclosed basis, as applicable.
In addition, as discussed herein, Mariner is owned in significant part by entities affiliated with LGP
and NBAA. Each of LGP and NBAA are large, global financial services firms, offering a wide
range of financial products and services. Further, as part of their standard business operations, LGP
and NBAA will periodically, directly or indirectly, own or control other financial services
companies. Due to the global nature of the products and services offered by LGP and NBAA
directly, and each of their portfolio companies indirectly, the Firm may allocate or recommend to
clients the products and/or services offered by LGP, NBAA or their portfolio companies from time
to time. Any such decision will be based on client-specific considerations, needs and circumstances,
and incidental to any indirect financial interest on the part of LGP and/or NBAA. Additional
information relating to the products and services of LGP and NBAA is publicly available on their
respective Form ADVs, as filed with the SEC.
The Firm seeks to manage the conflicts of interest discussed above by disclosing them to clients and
not sharing revenue from affiliated services, products and private funds with the IARs who
recommend client investments, except as specifically disclosed to the applicable client. Further, the
affiliated services, products and private funds are recommended to clients by IARs with
consideration of various factors, including but not limited to, the client’s investment objective and
financial circumstances. The Firm has procedures in place to monitor the conflicts of interest
presented by these relationships.
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Other Investment Advisers
The Firm is affiliated with and indirectly owned by Mariner Platform Solutions, LLC (CRD No.
305418), an SEC registered investment adviser, which also provides a platform solution for
independent investment advisors.
The Firm is affiliated, and under common control, with Mariner, LLC dba Mariner Wealth (CRD
No. 140195), an SEC registered investment adviser, which provides investment advisory and/or
related services to its clients.
The Firm is affiliated, and under common control, with Mariner Wealth Advisors-IC, LLC (CRD
No. 289886), an SEC registered investment adviser, which provides referral services to Mariner
Wealth by introducing prospective clients to Mariner Wealth who may have an interest in utilizing
Mariner Wealth’s investment advisory and/or related services.
The Firm is affiliated, and under common control, with Mariner Wealth Advisors-PR LLC (CRD
No. 329377), an SEC registered investment adviser.
The Firm is affiliated, and under common control, with Baystate Wealth Management (CRD No.
151664), an SEC registered investment adviser.
The Firm is affiliated, and under common control, with Mariner Institutional, LLC ( CRD No
111964), a SEC registered investment adviser.
The Firm is affiliated, and under common control with the following investment advisers as a result
of 1248’s significant ownership stake through its subsidiary holding company, Montage
Investments, LLC.
• 1248 Partners, LLC (CRD No. 325304), a SEC registered investment adviser;
• Flyover Capital Partners, LLC (CRD No. 173709), an SEC registered investment
adviser; and
• Ubiquity Management, LP (CRD No. 311168), an exempt reporting investment adviser.
These investment advisers, along with Mariner Wealth, serve as the investment manager or
investment adviser to private funds, (please see the Form ADV of each advisor for specific
information). IARs of the Firm further recommend that certain clients invest in affiliated private
funds should the IAR determine such investments are in the client’s best interest and in accordance
with the client’s investment objectives.
the
investment objectives and strategies, minimum
Relevant information, terms and conditions relative to the aforementioned affiliated private funds,
including
investments, qualification
requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth
in the offering documents (which typically include confidential private offering memorandum,
Mariner Independent Advisor Network, LLC-Form ADV Part 2A
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Limited Partnership Agreement/Limited Liability Company Agreement, or Subscription
Agreement), which each investor is required to receive and/or execute prior to being accepted as an
investor.
Through the ownership structures discussed above, Mariner’s affiliates have a passive, direct or
indirect, minority financial interest in the following investment advisers.
• Eaglebrook Advisors, Inc (CRD No. 304438), a SEC registered investment adviser;
• Altruist, LLC (CRD No. 299398), a SEC registered investment adviser;
• Lifeworks Advisors, LLC (CRD No. 288255), a SEC registered investment adviser; and
• Dynasty Wealth Management, LLC (CRD No. 153377), SEC registered investment adviser.
• 503 Capital Partners, LLC (CRD No. 327580) a SEC registered investment adviser; and
• Alpine Fox Capital, LLC (CRD No. 324348), an exempt reporting adviser.
These investment advisers provide advisory services to a variety of clients, across various different
formats, including through separately managed accounts, model portfolios and facilitating access to
online marketplaces (please see the Form ADV of each adviser for specific information). The Firm
recommends or allocates client capital to these investment advisers should a client’s adviser
determine such investments are in the client’s best interest and in accordance with the client’s
investment objectives.
Broker-Dealer
We are affiliated, and under common ownership, with MSEC (CRD No. 154327), a broker-dealer
registered with the SEC and various state jurisdictions, member of the Financial Industry Regulatory
Authority (FINRA), Securities Investment Protection Corporation (SIPC), and Municipal Securities
Rulemaking Board (MSRB). At the time of this filing, we do not have any IARs registered with
MSEC.
As described in further detail in Item 12 of this Brochure, members of the Firm’s management team
and our IARs have outside business activities as registered representatives of LPL, for which they
receive additional compensation. These outside business activities and additional compensation
create conflicts of interest. For example, from time to time, our IARs recommend or invest on behalf
of clients in investment products sold through LPL and by doing so receive usual and customary
commissions and/or other compensation. This presents a conflict of interest to the extent that the
IAR recommends that a client invest in a security which results in a commission being paid to
him/her. The receipt of commissions provides an incentive to recommend investment products based
on commissions received rather than on a particular client’s need. Clients should be aware that they
can purchase investment products recommended by Registrant through other non-affiliated broker-
dealers.
We are affiliated, and under common control, with Securities, LLC (CRD No. 140869) (“W G”), a
capital acquisition broker registered with the SEC and various state jurisdictions, member of FINRA
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and SIPC. To the extent applicable, we may refer clients in need of institutional investment banking
services to our affiliate Woodbridge International, LLC, the direct owner of W G Securities, LLC.
To the extent an investment banking engagement requires use of a broker dealer, the transaction
will typically be executed through W G. The Firm’s affiliation with W G and Woodbridge
International, LLC creates a financial incentive for the Firm to recommend the services of W G and
Woodbridge International, LLC over unaffiliated parties. In addition, certain eligible personnel of
the Firm are generally entitled to a referral fee from W G and/or Woodbridge International, LLC,
as applicable, for the referral of investment banking clients and/or opportunities.
Tax Consulting
We are under common control with and in certain situations refer clients to Mariner Wealth
which, in addition to advisory services, provides tax consulting, compliance and bookkeeping
services to clients. To the extent that a client requires bookkeeping and/or tax preparation services,
we recommend the services of Mariner Wealth, which shall be rendered independent of the Firm
pursuant to a separate agreement between the client and Mariner Wealth. However, certain of our
IARs may receive a portion of the fee paid to Mariner Wealth.
Trust Company
We are under common control with Mariner Trust Company, LLC. Mariner Trust Company, LLC, is
a state-chartered public trust company organized under the laws of South Dakota and serves to
provide its customers with administrative trust services and other related services. The entity is
subject to the regulatory oversight of the South Dakota Department of Labor and Regulation. The
Firm is deemed to have custody of any client account where Mariner Trust Company, LLC serves
as trustee or co-trustee.
Investment Banking Firm
We are under common control with Woodbridge International LLC (“Woodbridge”) which provides
investment banking services. To the extent that a client requires these services, we recommend
Woodbridge, all of which services shall be rendered independent of the Firm pursuant to a separate
agreement between the client and Woodbridge. The Firm receives compensation for referrals to
Woodbridge in addition to the indirect financial incentive to refer clients due to common ownership.
In addition, certain eligible personnel of the Firm are generally entitled to a referral fee from
Woodbridge for the referral of investment banking clients and/or opportunities.
Insurance Companies or Agencies
We are under common control with Mariner Insurance Resources, LLC, an insurance agency.
Clients are reminded that they may purchase insurance products recommended by the Firm through
other non-affiliated agencies.
Several of our IARs are also licensed insurance agents of various independent insurance companies.
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In the course of providing investment advisory services, these individuals can recommend that
clients purchase products or policies underwritten by certain insurance carriers. Please note that a
conflict of interest exists to the extent that certain recommendations result in a commission being
paid to these individuals by the insurance company should a client purchase that company’s
insurance products or policies. The amount paid is the normal commission paid for services
rendered as an insurance agent. Clients should be aware that they are under no obligation to purchase
insurance products or policies recommended by the Firm or any of its IARs, and can purchase
insurance products or policies from non-affiliated insurance agents.
Financial Planning Wellness Platform
We are under common control with Mariner Financial Wellness, LLC, which provides a Financial
Wellness Platform to companies. Through the Financial Wellness Platform, employees of these
companies are able to access Financial Wellness Coaching provided by advisors registered with
Marnier Wealth.
Specialty Tax Services
The Firm is affiliated and under common control with Mariner Specialty Tax Services, LLC, which
provides specialty tax services to certain clients. In addition to the indirect financial incentive to
refer clients due to common ownership, certain investment adviser representatives of the Firm may
receive a portion of the fee paid to Mariner Specialty Tax Services, LLC.
Legal Services Solution
Through the ownership structures discussed above, Mariner’s affiliates have a passive, direct or
indirect minority financial interest in Vanilla, a software solution that provides certain legal
services. To the extent that a client requires these services, we recommend Vanilla, all of which
services shall be rendered independent of Mariner Wealth pursuant to a separate agreement between
the client and Vanilla.
Other Affiliates
Through our ownership by HBP, we are affiliated with Honor Bound Consulting Services, LLC
(“HBC”) and Honor Bound Network, LLC (“HBN”). HBN is a California limited liability
company that primarily serves to hold the assets and income of an office of supervisory jurisdiction
with LPL Financial. In this capacity, HBN is responsible for overseeing the activities of registered
representatives assigned to the branch. In many instances, these same registered representatives serve
as IARs of the Firm.
LPL
Several of our IARs are also dually registered with LPL Financial’s RIA firm in order to provide
consulting for ERISA plans. Our IAR’s leverage some of the systems that LPL has built to provide
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fee-based advice to ERISA based 401k plans. Our IAR’s may charge through an assets under
management fee or a flat fee.
The recommendation by IARs that a client purchase a securities and/or insurance commission
product presents a conflict of interest as the receipt of commissions provides an incentive to
recommend investment or insurance products based on commissions received, rather than on a
particular client’s need. No client is under any obligation to purchase any commission products
from IARs. Clients are reminded that they can purchase investment or insurance products
recommended by IARs through other non-affiliated broker dealers or insurance agents.
The conflicts surrounding these outside business activities are disclosed to clients at the time of
entering into an Investment Advisory Agreement with the Firm, primarily through the delivery of
this Brochure and the Supplemental Brochures (ADV Part 2Bs). Additionally, the Firm has
implemented certain policies, procedures and internal controls to help mitigate these conflicts,
including having procedures to monitor the outside business activities of the IARs. Importantly, as
part of our fiduciary duty to clients, the Firm and its IARs endeavor at all times to put the interests of
the clients first, and recommendations and investments will only be made to the extent that they are
reasonably believed to be suitable and in the best interests of the client.
Additionally, as a result of the Firm’s relationship with LPL, LPL will have access to certain
confidential information (e.g., financial information, investment objectives, transactions and
holdings) about the Firm’s clients, even if the client does not establish any account through LPL.
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Item 11-Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
Overview of Code of Ethics and Personal Trading
We have adopted a code of ethics that sets forth the standards of conduct expected of our supervised
persons and requires compliance with applicable securities laws (“Code of Ethics”). In accordance
with Section 204A of the Advisers Act, the Code of Ethics contains written policies reasonably
designed to prevent the unlawful use of material non-public information by us or any of our
supervised persons. The Code of Ethics also requires that certain of our personnel (“access persons”)
report their personal securities holdings and transactions and obtain pre-approval of transactions in
certain securities deemed reportable under the Code of Ethics, including equities, options, initial
public offerings, limited offerings and virtual coins or tokens in initial coin offerings.
A conflict of interest exists to the extent the Firm and/or its IARs and/or other related persons invest
in the same securities that are recommended to clients. In order to address this conflict of interest,
the Firm has implemented certain policies and procedures in its Code of Ethics, as further described
herein. If an access person is aware that the Firm or an IAR within the Firm is purchasing/selling
any security on behalf of a client, the access person may not themselves effect a transaction in that
security until the transaction is completed for all clients. This does not include transactions for
accounts that are executed as part of a block trade within a managed strategy or for accounts over
which the access person has no direct or indirect influence or control. These requirements are not
applicable to:
• Direct obligations of the Government of the United States
• Money market instruments including, bankers’ acceptances, bank certificates of deposit,
commercial paper, repurchase agreements and other high quality short-term debt instruments
(High quality short-term debt instrument is defined as any instrument having a maturity at
issuance of fewer than 366 days and which is rated in one of the highest two rating categories
by a nationally recognized statistical rating organization, or which is unrated but is of
comparable quality.)
• Shares issued by money market funds
• Shares issued by open-end mutual funds (other than exchange traded funds) Shares issued by
unit investment trusts that are invested exclusively in one or more unaffiliated open-end mutual
funds (other than exchanged traded funds)
No supervised person may trade, either personally or on behalf of others, (including client accounts),
while in the possession of material, nonpublic information, nor may any supervised person of the
Firm communicate material, nonpublic information to others in violation of the law.
We maintain restrictions on receiving and giving of gifts and entertainment to and from clients and
others that the Firm does business with. This is in an effort to curb potential conflicts of interest he
may create. We also monitor outside business activities of our IARs to review situations that would
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compete with the interests the Firm.
Our clients or prospective clients may request a copy of our Code of Ethics by contacting us at (650)
571-1934 or compliance@marineradvisornetwork.com.
Participation or Interest in Client Transactions
If we determine that it is appropriate based on the client’s investment objectives and investor status,
we recommend to clients, or buy or sell for client accounts, securities in which our related persons
have a financial interest. This includes, but is not limited to, instances in which Mariner Wealth or
an affiliate act as the general partner in a partnership or a managing member of a limited liability
company in which we recommend client(s) invest. This also includes products and services offered
by other financial entities in which a principal voting owner of the Firm – MWA, 1248 LGP and/or
NBAA have a direct or indirect ownership interest. These types of transactions present a conflict of
interest in that the Firm has an indirect financial incentive as revenues earned by the related person
ultimately flow to the principal voting owners of Mariner. See Item 10 for additional disclosure
regarding this conflict, including the policies and procedures the Firm has implemented in order to
address the conflict.
To address these potential conflicts and protect and promote the interests of clients, we employ the
following policies and procedures:
• If we enter into a transaction on behalf of our clients that presents either a material or nonmaterial
conflict of interest, the conflict should be prominently disclosed to the client prior to the
consummation of such transaction.
• Associates must comply with our policy on the handling and use of material inside information.
Associates are reminded that they may not purchase or sell, or recommend the purchase or sale, of
a security for any account while they are in possession of material inside information. In addition,
associates may not disclose confidential information except to other associates who “need to know”
that information to carry out their duties to clients.
• Access persons must report securities transactions in any related account.
• Client trades will be aggregated with related accounts of access persons under the following
conditions:
• Trades for clients are treated equally with those for related accounts of access persons;
• Each participant in the trade will receive the average execution price and commissions; and
• Securities will be allocated in a fair and equitable manner pursuant to the Firm’ policies
and procedures
In addition, we have adopted trading practices designed to address potential conflicts of interest.
There can be no assurance, however, that all conflicts have been addressed in all situations. Further,
during periods of unusual market conditions, the Firm may deviate from its normal trade allocation
practices.
From time to time, IARs of the Firm may recommend that certain clients invest in limited
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investment opportunities. The allocation of these investments across client portfolios is generally
not executed on a pro rata basis as a number of factors will determine whether the limited offering
is appropriate or suitable for a client. Accordingly, such opportunities may be allocated based on
another approach, including random selection, selection based on account size or another
methodology. Factors which may impact the allocation include but are not limited to: account size,
liquidity, investor qualification and risk tolerance. We note that limited investment opportunities
may not be appropriate for smaller accounts, depending on factors such as minimum investment
size, account size, risk, and diversification requirements, and accordingly may not be allocated such
investments.
The Firm generally does not engage in cross-trading of client accounts, nor does it engage in any
principal or agency cross securities transactions for client accounts. Any exceptions to the general
prohibition against cross trades or principal trades must be approved in advance by a member of the
Compliance Team. Principal transactions are generally defined as transactions where an adviser,
acting as principal for its own account or the account of an affiliated broker-dealer, buys from or
sells any security to any advisory client. A principal transaction may also be deemed to have
occurred if a security is crossed between an affiliated hedge fund and another client account. If the
Firm should at any time determine that a principal trade is in a client’s best interest, then prior to
the settlement of any such principal transaction, the Compliance Team is responsible for obtaining
any affected client’s informed written consent to the transaction. An agency cross transaction is
generally defined as a transaction where a person acts as an investment adviser in relation to a
transaction in which the investment adviser, or any person controlled by or under common control
with the investment adviser, acts as broker for both the advisory client and for another person on
the other side of the transaction. Agency cross transactions may arise where an adviser is dually
registered as a broker-dealer or has an affiliated broker-dealer.
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Item 12-Brokerage Practices
The Custodians and Brokers We Use
We do not maintain custody of your assets that we manage, although we may be deemed to have
custody of your assets if you give us authority to withdraw assets from your account (see Item 15—
Custody, below). Your assets must be maintained in an account at a “qualified custodian,” generally
a broker-dealer or bank. We generally recommend that our clients use LPL Financial (“LPL”),
Charles Schwab & Co., Inc. (“Schwab”), National Financial Services LLC/Fidelity Brokerage
Services LLC (“Fidelity”) and Pershing LLC (“Pershing”), as the qualified custodian. We are not
affiliated with LPL, Schwab, Fidelity or Pershing. LPL, Schwab, Fidelity and Pershing will each hold
your assets in a brokerage account and buy and sell securities when we instruct them to. While we
recommend that you use LPL, Schwab, Fidelity and/or Pershing as custodian/broker, you will decide
whether to do so and will open your account with LPL, Schwab, Fidelity and/or Pershing by entering
into an account agreement directly with them. Not all advisors require their clients to use a particular
broker-dealer or other custodian selected by the advisor. Even though your account is maintained at
LPL, Schwab, Fidelity and/or Pershing, we can still use other brokers to execute trades for your
account as described below (see “Your brokerage and custody costs”). Additionally, while we
generally recommend the use of LPL, Schwab, Fidelity and/or Pershing, we also manage accounts
for clients custodied with other qualified custodians.
We may establish additional accounts on the behalf of clients with select qualified custodians at
which the client maintains an existing account. For retirement accounts, the client receives
notification from the custodian upon the account being established. For non-retirement accounts, the
client receives notification when an asset movement authorization is elected. Clients receive
quarterly statements from the custodian for any accounts opened on the client’s behalf.
How we select brokers/custodians
We seek to use a custodian/broker that will hold your assets and execute transactions on terms that
are, overall, most advantageous when compared with other available providers and their services.
We consider a wide range of factors, including:
• Combination of transaction execution services and asset custody services (generally without a
separate fee for custody)
• Capability to execute, clear, and settle trades (buy and sell securities for your account)
• Capability to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
• Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded
funds, etc.)
• Availability of investment research and tools that assist us in making investment decisions
• Quality of services
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• Competitiveness of the price of those services (commission rates, margin interest rates, other
fees, etc.) and willingness to negotiate the prices
• Reputation, financial strength, security and stability
• Prior service to us and our clients
• Availability of other products and services that benefit us, as discussed below (see “Products and
services available to us from Custodians”)
The Firm is not required to weigh any of these factors equally. The Firm’s selection of brokers on
the basis of considerations which are not limited to applicable commission rates may at times result
in the Firm’s clients being charged higher transaction costs than they could otherwise obtain.
Your brokerage and custody costs
For our clients’ accounts that LPL, Schwab, Fidelity and/or Pershing maintain, LPL, Schwab,
Fidelity and/or Pershing generally do not charge you separately for custody services but are
compensated by charging you commissions or other fees on trades that they execute or that settle into
your account. Certain trades (for example, many mutual funds and ETFs) may not incur
commissions or transaction fees. Commission rates for LPL, Schwab, Fidelity and Pershing
applicable to our client accounts were negotiated. We believe our commitment to LPL, Schwab,
Fidelity and Pershing benefits you because the overall commission rates you pay are lower than they
would be otherwise. In addition to commissions, LPL, Schwab, Fidelity and/or Pershing charge you
a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed
by a different broker-dealer but where the securities bought or the funds from the securities sold are
deposited (settled) into your LPL, Schwab, Fidelity or Pershing account. These fees are in addition
to the commissions or other compensation you pay the executing broker- dealer. Because of this, in
order to minimize your trading costs, we have the custodian of your account (generally, LPL,
Schwab, Fidelity or Pershing) execute most trades for your account unless we believe it is beneficial
to step out and trade at other broker dealers. We have determined that having the custodian execute
most trades is consistent with our duty to seek “best execution” of your trades. Best execution means
the most favorable terms for a transaction based on all relevant factors, including those listed above
(see “How we select brokers/custodians”). Clients utilizing the same custodian may be subject to
differing levels of custody fees, based on the billing practices of the applicable custodian.
Products and services available to us from LPL, Schwab, Fidelity and Pershing
LPL, Schwab, Fidelity and Pershing each provide us and our clients with access to their institutional
brokerage services (trading, custody, reporting, and related services), many of which are not typically
available to retail customers. They also make available various support services. Some of those
services help us manage or administer our clients’ accounts, while others help us manage and grow
our business. These support services are generally available on an unsolicited basis (we don’t have
to request them) and at no charge to us. Following is a more detailed description of these support
services:
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Services that benefit you. The institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of client assets. The
investment products available through LPL, Schwab, Fidelity and/or Pershing include some to
which we might not otherwise have access or that would require a significantly higher minimum
initial investment by our clients. The services described in this paragraph generally benefit you and
your account.
Services that may not directly benefit you. LPL, Schwab, Fidelity and Pershing also make
available to us other products and services that benefit us but may not directly benefit you or your
account. These products and services assist us in managing and administering our clients’ accounts
and include investment research. We may use this research to service all or a substantial number of
our clients’ accounts, including accounts not maintained at LPL, Schwab, Fidelity or Pershing. In
addition to investment research, LPL, Schwab, Fidelity and Pershing also make 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 our clients’ accounts
• Assist with back-office functions, recordkeeping, and client reporting
Services that generally benefit only us. LPL, Schwab, Fidelity and Pershing also offer other
services intended to help us manage and further develop our business enterprise. These services
include, but are not limited to:
• Educational conferences and sponsorship of Firm events
• Consulting on technology and business needs
• Publications and conferences on practice management and business succession
• Marketing consulting and support
LPL, Schwab, Fidelity and/or Pershing may provide some of these services themselves. In other
cases, they will arrange for third-party vendors to provide the services to us. They may also discount
or waive fees for some of these services or pay all or a part of a third party’s fees. They may also
provide us with other benefits, such as occasional business entertainment of our personnel.
Our interest in services provided by LPL, Schwab, Fidelity and Pershing
The availability of these services from LPL Schwab, Fidelity and Pershing benefits us because we
do not have to produce or purchase them. For certain IARs transitioning to the Firm, LPL, Schwab
and Fidelity have also each agreed to pay certain costs our clients will incur in transitioning accounts
to LPL, Schwab or Fidelity (such as ACAT fees) and, in certain circumstances, for costs we would
otherwise incur for certain third-party products and services once the value of the IAR’s clients’
assets in accounts at LPL, Schwab or Fidelity reaches a certain agreed upon threshold. These services
are not contingent upon us committing any specific amount of business to either LPL, Schwab or
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Fidelity in trading commissions; however, the amount of the benefit is generally based on the
amount of assets expected to transition to LPL, Schwab or Fidelity. This creates an incentive for an
IAR to recommend that you maintain your account with LPL, Schwab or Fidelity, based on interest
in receiving these services that benefit the IAR’s business and the payment for services for which
we/the IAR would otherwise have to pay rather than based on your interest in receiving the best
value in custody services and the most favorable execution of your transactions. This is a potential
conflict of interest. We believe, however, that our selection of LPL, Schwab or Fidelity as custodian
and broker is in the best interests of our clients. Our selection is primarily supported by the scope,
quality, and price of the services provided by LPL, Schwab and Fidelity (see “How we select
brokers/ custodians”) and not the services that benefit only us.
Other Economic Benefits
Receipt by an investment adviser of products and services provided by brokers, without any cash
payment by an investment adviser, based on the volume of brokerage commission revenues
generated from securities transactions executed through those brokers on behalf of the investment
adviser’s clients is commonly referred to as “soft dollars.” Section 28(e) of the Securities Exchange
Act of 1934, as amended (the “Exchange Act”), provides a “safe harbor” to investment advisers with
respect to potential liability for violating their duty to obtain best execution for a client’s securities
transactions in circumstances in which such advisers use soft dollars generated by their advised
accounts only for purposes of obtaining investment research and brokerage services (i) that provide
lawful and appropriate assistance to the investment adviser in the performance of investment
decision making responsibilities and (ii) where the commissions paid are reasonable in relation to
the value of the services provided.
The Firm does not currently have any formal soft dollar arrangements. The Firm is not required to
allocate either a stated dollar or stated percentage of its brokerage business to any broker for any
minimum time period.
Cheryl Bicknell, Chief Operating Officer of the Firm serves on the Schwab Advisor Services
Advisory Board (the “Advisory Board”). As described here, the Firm may recommend that clients
establish brokerage accounts with Schwab and/or its affiliates (e.g., TD Ameritrade Institutional) to
maintain custody of the clients’ assets and effect trades for their accounts. The Advisory Board
consists of representatives of independent investment advisory firms who have been invited by
Schwab management to participate in meetings and discussions of Schwab Advisor Services’
services for independent investment advisory firms and their clients. Generally, Board members
serve for two-year terms. Advisory Board members enter into a nondisclosure agreement with
Schwab under which they agree not to disclose confidential information shared with them. This
information generally does not include material nonpublic information about the Charles Schwab
Corporation, whose common stock is listed for trading on the New York Stock Exchange (symbol
SCHW). The Advisory Board meets in person or virtually approximately twice per year and has
periodic conference calls scheduled as needed. Advisory Board members are not compensated by
Schwab for their service, but Schwab does pay for or reimburse Advisory Board members’ travel,
lodging, meals, and other incidental expenses incurred in attending Advisory Board meetings.
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Schwab may also provide members of the Advisory Board a fee waiver for attendance at Schwab
conferences such as IMPACT.
Trade Execution
If the client requests us to arrange for the execution of securities brokerage transactions for the
client’s account, we shall direct such transactions through broker-dealers that we reasonably believe
will provide best execution given prevailing market conditions. We generally execute transactions
for clients with the account custodian; however, transactions are cleared through other broker-
dealers, when determined to be appropriate, with whom the Firm and the financial institution(s)
have entered into agreements for prime brokerage clearing services. In addition, certain custodians
utilized by the Firm may charge custodial clients a flat dollar amount or “trade away” fee for each
trade that the Firm has executed by a different broker-dealer. As a result, the client could incur both
the fee (commission, mark-up/mark-down) charged by the executing broker and the separate
“tradeaway,” “step-out” and/or prime broker fee charged by the custodian. We shall periodically
review our policies and procedures regarding recommending broker-dealers to our clients in light
of our duty to obtain best execution. Generally, our IARs are restricted to those broker-dealers, with
whom the Firm has entered into a prime brokerage relationship. It should be noted that not all
investment advisers require their clients to use specific or particular broker-dealers or other
custodians required by the investment adviser and/or affiliated broker dealer. The fees charged by
other broker-dealers may be higher or lower than those charged by those broker/dealers or custodians
that have been approved by the Firm.
The Firm has delegated authority to place trades for certain model accounts to Mariner Wealth, as
applicable depending on the platform the client is using. If a client’s account is managed by a third-
party, trades will be placed, aggregated and allocated according to the trading policy of the manager.
Directed Brokerage
Clients do not have the option to direct us in writing to use a particular broker-dealer to execute
some or all transactions for the client.
Trade Error Policy
We have internal controls for the prevention of trade or model allocation errors, however, on
occasion, errors may occur. We recommend that you regularly review your custodial statements. In
the event you identify an error, you have 90 days from your statement date to notify us of its
existence. Upon notification, we will perform an analysis of the reported discrepancy. If the Firm is
responsible for the error, we will seek to correct the error in a way that returns your account to where
it would have been had the error not occurred. If you notify us of a potential error more than 90 days
after your statement date and the Firm is responsible for the error, The Firm will reimburse you for
any damage caused to your account from the date of the error through 90 days after your statement
date. We maintain a record of identified errors, including details of the original transaction and the
corrective actions. The trade error resolution process varies depending on the policies and practices
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of the custodian where the relevant client account is maintained. Clients may obtain additional
information about the trade error policies and practices applicable to their account by contacting the
Firm.
LPL Financial
Many of our IARs are also registered representatives of LPL (“Dually Registered Persons”) and our
primary custodial relationship is with LPL. Prior to engaging the Firm to provide investment
management services, the client will be required to enter into a formal Investment Advisory
Agreement with Registrant setting forth the terms and conditions under which Registrant shall
manage client assets, and a separate custodial agreement with each designated broker-dealer or
custodian. If the client desires to engage the IAR to provide brokerage services acting as a registered
representative of LPL, the IAR has the option to place clients in investment products sold through
LPL and will receive brokerage-related compensation for those services, such as commissions and
trail fees. Many such products have fixed commissions as they are sold through a prospectus. For
example, Dually Registered Persons, in their capacity as registered representatives of LPL, receive
compensation (such as 12b-1 fees) from the sale of mutual fund products to clients of the Firm. This
compensation is consideration for various services that the representative provides, such as
presenting information to the Firm’s clients regarding the funds and recommending shares of the
funds for investment. Payment of these fees is included in the expense ratios of the mutual funds.
Registered representatives can have a greater incentive to recommend certain funds or fund families
with 12b-1 fees or funds with higher 12b-1 fees over other funds or fund families with no or lower
12b-1 fees.
LPL provides information regarding such brokerage compensation at the time of a brokerage
transaction. When considering whether to implement a recommendation through your IAR and LPL,
clients should discuss with the IAR how LPL and the IAR will be compensated. Fees and
commissions can also be higher or lower than services provided by other vendors. Using our IARs
to provide brokerage services to you creates a potential conflict of interest that can give an IAR an
incentive to recommend services based on the compensation they will receive. This in no way
prohibits you from purchasing investment products recommended by us through other brokers or
agents which are not affiliated with us. Please refer to Item 10 for additional information on this
potential conflict of interest. Please refer to Item 5 of this Brochure for additional detail on fees.
LPL services that generally benefit us. Our IARs will also receive from LPL (1) bonuses based on
their production, (2) restricted stock units of shares of LPL’s parent company, LPL Investment
Holdings, Inc., (3) reimbursement of fees they pay to LPL for items such as administrative services,
and (4) other items of value such as complimentary or reduced-cost attendance at LPL’s national
sales conference or other events. These financial incentives from LPL are based on their overall
business production.
LPL also provides various benefits and payments to Dually Registered Persons to assist the
representative with the costs (including foregone revenues during account transition) associated
with transitioning his or her business to LPL (collectively referred to as “Transition Assistance”).
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The proceeds of such Transition Assistance payments are intended to be used for a variety of
purposes, including but not necessarily limited to, providing working capital to assist in funding the
Dually Registered Person’s business, satisfying any outstanding debt owed to the Dually Registered
Person’s prior firm, offsetting account transfer fees (ACATs) payable to LPL as a result of the Dually
Registered Person’s clients transitioning to LPL’s custodial platform, technology set-up fees,
marketing and mailing costs, stationary and licensure transfer fees, moving expenses, office space
expenses, staffing support and termination fees associated with moving accounts.
The amount of the Transition Assistance payments is often significant in relation to the overall
revenue earned or compensation received by the Dually Registered Person at his/her prior firm.
Such payments are generally based on the size of the Dually Registered Person’s business
established at his/her prior firm and/or assets under custody with LPL. Please refer to the relevant
Part 2B brochure supplement for more information about the specific Transition Payments your
IAR can or will have received.
Transition Assistance payments and other benefits are provided to associated persons of the Firm in
their capacity as registered representatives of LPL. However, the receipt of Transition Assistance
by such Dually Registered Persons creates conflicts of interest relating to the Firm’s advisory
business because it creates a financial incentive for Registrant’s representatives to recommend that
its clients maintain their accounts with LPL. In certain instances, the receipt of such benefits is
dependent on a Dually Registered Person maintaining its clients’ assets with LPL and therefore the
Firm has an incentive to recommend that clients maintain their account with LPL in order to generate
such benefits.
The Firm attempts to mitigate these conflicts of interest by evaluating and recommending that
clients use LPL’s services based on the benefits that such services provide to our clients, rather than
the Transition Assistance earned by any particular Dually Registered Person. As discussed further
in Section B – Best Execution of this Item 12, the Firm considers a number of factors when
recommending that clients maintain accounts with LPL. However, clients should be aware of this
conflict and take it into consideration in deciding whether to custody their assets with LPL.
LPL services that can or will not directly benefit clients. LPL also makes available to us other
products and services that benefit us but can or will not directly benefit our clients or their accounts
held at LPL. These products and services assist us in managing and administering our clients’
accounts. They include investment research, both LPL’s own and that of third parties. The Firm and
its IARs can use this research to service all or a substantial number of our clients’ accounts, including
accounts not maintained at LPL. In addition to investment research, LPL 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;
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• Facilitate payment of the Firm’s advisory fees from clients’ accounts; and
• Assist with back-office functions, recordkeeping, and client reporting.
• Financial Planning and Investment Proposals
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Item 13-Review of Accounts
For those clients to whom the Firm provides investment advisory services, account reviews are
conducted at least annually by its IARs. All investment advisory clients are advised that it remains
their responsibility to advise their IAR of any changes in his/her/its financial situation, investment
objectives and/or risk tolerance. All clients (in person, virtual meeting, or telephone) are
encouraged to discuss and review all such changes with their IAR on an annual basis. Clients who do
not respond to requests to meet will be sent communication via mail or email to help them
understand their current financial position and assist their IAR in the continued management of the
account(s)
IAR’s can or will conduct account reviews on an other-than-periodic basis upon the occurrence of a
triggering event, such as a change in client financial situation, investment objectives, risk tolerance,
market corrections, and client request.
Financial planning clients do not receive reviews of their written plans unless they take action to
schedule a financial consultation with their IAR. We do not provide ongoing services to
Comprehensive Financial Planning or Hourly Consulting clients unless they separately contract
with us for a post-financial plan meeting or update to their initial written financial plan.
Retirement Plan Consulting clients receive reviews of their pension plans for the duration of the
pension consulting service. IAR’s also provide ongoing services to pension consulting clients where
we meet with such clients upon their request to discuss changes to their circumstances and resulting
updates to their plans.
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Item 14-Client Referrals and Other Compensation
Recommendation of Brokers to Clients
As discussed in Item 12 of this Brochure, the Firm typically recommends LPL as the broker-dealer
or custodian to clients. If the client desires to engage the IAR to provide brokerage services acting
as a registered representative of LPL, the IAR has the option to place clients in investment products
sold through LPL and will receive brokerage-related compensation for those services. The
recommendation by Registrant’s IARs that a client purchase a security and/or insurance commission
product presents a conflict of interest as the receipt of commissions can provide an incentive to
recommend investment products based on commissions received, rather than on a particular client’s
need. No client is under any obligation to purchase any commission products from Registrant’s
IARs. Clients are reminded that they can purchase investment products recommended by Registrant
through other non-affiliated broker dealers or insurance agents. Please contact the CCO should you
have any questions regarding the above conflict of interest.
Referral/Solicitor Fees
From time to time, the Firm and/or its IARs may enter into arrangements with third parties or other
financial intermediaries for lead generation, client referrals or solicitation for program accounts
(collectively, “solicitation arrangements”). These solicitation arrangements range from largely
impersonal referrals to specific client introductions to an IAR of the Firm. Under solicitation
arrangements, the third parties and financial intermediaries are independent contractors.
Under such solicitation agreements, we pay referral fees (non-commission based) to third party
Promoters for the referral of their clients to our Firm. All such agreements are in writing and comply
with the requirements of Rule 206(4)-1 of the Advisers Act and applicable state and federal laws.
The compensation paid under the solicitation arrangements is structured in various ways, including a
one-time fee, a flat fee per lead or referral, and sharing a portion of the ongoing Account Fee. Any
such fee shall be paid solely from the Firm’s investment advisory fee and shall not result in any
additional charge to the client.
For clients who are introduced to us by an unaffiliated Promoter, the client is given, prior to or at
the time of entering into any advisory contract with the client, a copy of the Promoter’s disclosure
statement containing the terms and conditions of the solicitation arrangement including
compensation. Any affiliated Promoter of ours, or a Promoter in which an affiliate holds a direct or
indirect ownership interest, shall disclose the nature of his/her relationship to prospective clients at
the time of the solicitation.
Depending on the Promoter’s arrangement with the Network, a Promoter may not be compensated
for referring a client who opens a brokerage account rather than an advisory account. Solicitation
arrangements give rise to conflicts of interest because the referring party has a financial incentive
to introduce new investment advisory clients to the Network and its IARs. LPL’s participation in
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these referral arrangements does not diminish its fiduciary obligations to its clients.
The Firm’s IARs may also act as Promoters by referring potential clients to third party investment
advisory firms. When the client enters into an agreement with the third-party advisory firm, the Firm
is paid a portion of the annual management fee that the third-party advisory firm collects from
each client solicited by the Firm. IARs provide each solicited client written disclosures at the time
of solicitation, outlining the solicitation arrangement and the compensation to be paid to the Firm for
soliciting the client. Upon receipt of the fees, the Firm will pay a portion of such solicitation fee to
the IAR soliciting the potential client. The third-party advisory firm, not the Firm, provides
investment management services to each solicited client and is responsible for ensuring client
suitability.
We receive client referrals from our affiliates for which we pay a referral fee. We refer clients to
our affiliates for which we receive a referral fee. The compensation has generally included a
recurring payment of a percentage of the client’s annual advisory fee.
From time to time, we may receive indirect compensation from service providers or third-party
vendors in the form of gifts, entertainment and/or gratis attendance at industry conferences,
meetings and other educational events. When received, these occasions are evaluated to ensure they
are reasonable in value and customary in nature to ensure their occurrence does not present any
conflicts of interest. In addition, service providers and/or third-party vendors provide us economic
benefits in the form of serving as sponsors for certain of our events and/or conferences.
We receive an economic benefit from Schwab, Fidelity and Pershing in the form of the support
products and services each custodian makes available to us and other independent investment
advisors whose clients maintain their accounts at each custodian. In addition, Schwab and Fidelity
have also agreed to pay for certain products and services for which we would otherwise have to pay
once the value of our clients’ assets in accounts at Schwab reaches a certain amount. These products
and services, how they benefit us, and the related conflicts of interest are described above (see Item
12-Brokerage Practices).
With respect to the AssetMark Platform, the Firm may, subject to negotiation with AssetMark,
receive certain allowances, reimbursements or services from AssetMark in connection with the
Firm’s investment advisory services to its clients, as described below and in further detail in the
Appendix 1 of the AssetMark Platform Disclosure Brochure.
Direct and Indirect Support for Firm
AssetMark may sponsor annual conferences for participating Financial Advisory Firms and/or
Financial Advisors designed to facilitate and promote the success of the Financial Advisory Firm
and/or Financial Advisor and/or AssetMark advisory services.
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Community Inspiration Award
AssetMark offers the Community Inspiration Award to honor selected Financial Advisors across
the US who have inspired others by supporting charitable organizations in their communities.
AssetMark will make a cash donation, subject to the published rules governing the program, to the
Firm’s nominated charity in accordance with guidelines as outlined in the AssetMark Platform
Disclosure Brochure.
Other Compensation
The IAR can also receive additional compensation from product sponsors. However, such
compensation can or will not be tied to any product sales. They can include such compensation as
gifts valued at less than $100 annually, an occasional dinner or sporting event, or reimbursement in
connection with educational meetings or training events. Product sponsors can also pay for
education or training events.
As outlined in Item 12 of this Brochure, the Firm will recommend LPL, Schwab, Fidelity and
Pershing for the execution and settlement of client transactions and custody of their assets. As part
of these arrangements, the Firm receives products and services from these broker-dealers, including
software to enable direct electronic downloading of client account information, electronic trading, and
access to investment research and information provided by broker-dealers. Clients do not pay higher
commissions or transaction fees as a result of these products and services furnished by broker-dealers
to the Firm. Although IARs registered with LPL can receive commissions in LPL accounts, the
Firm earns no commissions from these transactions. Transaction charges or other charges for
services to clients by broker-dealers can be more or less than other broker-dealers not recommended
by the Firm that charge for comparable services. Clients are not required to use a specific broker-
dealer to retain the services of the Firm. Please refer to Item 12 above for complete information on the
benefits received by the Firm from these broker-dealers.
Mutual funds purchased or sold in broker-dealer accounts can generate transaction fees that would
not exist if the purchase or sale were made directly through the mutual fund company. Mutual funds
held in broker-dealer accounts also charge management fees. These mutual fund management fees
can be more or less than the mutual fund management fees charged if the client held the mutual fund
directly with the mutual fund company. These management fees are in addition to the management
fee charged by the Firm.
On occasion, LPL provides funding in the form of loans as incentive to independent registered
representatives to establish broker-dealer relationships with LPL. Such loans are to assist in the
transition and expansion of their practice.
Some IARs will also receive from LPL bonuses based on their production, issued restricted stock
units of shares of LPL’s parent company, LPL Investment Holdings, Inc., reimbursement of fees
they pay to LPL for items such as administrative services, and other things of value such as
complimentary or reduced-cost attendance at LPL’s national sales conference or other events.
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These financial incentives from LPL are based on their overall business production. However, in
some cases, the incentives are greater for assets they service in advisory programs. This can present a
conflict of interest as the need to meet production levels can influence investment
recommendations.
The Firm receives asset-based advisory fees as a result of its clients’ participation in the LPL
sponsored programs. The amount of these fees can be more or less than what the Firm would receive
if a client participated in other LPL programs or paid separately for investment advice, brokerage
and other client services. Additionally, the Firm or one or more of its IARs will receive all or a
portion of certain third-party fees that are paid by program clients. Therefore, the Firm has a financial
incentive when recommending that its clients open an account under the LPL managed account
program. As part of the Firm’s fiduciary duty to its clients, the Firm and its IARs will endeavor at
all times to put the interest of the clients first and will only make recommendations when they are
reasonably believed to be in the best interests of the client. Please refer to Item 5of this Brochure
for further details regarding fees.
Sponsorships & Third-Party Support
Enterprise Partnership Alliance
Mariner has in place an Enterprise Partnership Alliance program through which firms are able to
sponsor events such as seminars and conferences. Firms that partake in this partnership alliance may
include investment managers, recordkeepers and other third parties with which the firm does
business and/or may recommend to clients. Firms that currently participate in this program, include,
but are not necessarily limited to: Apollo, Baystate Financial, Blackrock, Blackstone, CAIS, Cantor,
Dimensional Fund Advisors (DFA), Fidelity, Goldman Sachs, Hargrove Firm powered by Net Law,
Inland, John Hancock, JP Morgan, MFS, Orion, Palmer Square, Pontera, Schwab, State Street,
StoneCastle, Vanguard, and Vanilla. This list is subject to change from time to time.
Other Support Services
The Firm may also receive from Fidelity, Schwab or Pershing (or another broker-dealer/custodian,
investment platform and/or mutual fund sponsor) without cost (and/or at a discount) support
services and/or products, certain of which assist us to better monitor and service client accounts
maintained at such institutions. Possible support services the firm receives include: sponsorships of
Firm events and/or conferences, investment-related research, pricing information and market data,
software and other technology that provide access to client account data, compliance and/or practice
management-related publications, discounted or gratis consulting services, discounted and/or gratis
attendance at conferences, meetings, and other educational and/or social events, marketing support,
transition support services, computer hardware and/or software and/or other products used by the
Firm in furtherance of its investment advisory business operations.
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The aforementioned Enterprise Partnership Alliance and other support services could create a
potential conflict of interest in that an advisor may have an incentive to recommend that a client
utilize the services of a particular third-party provider (e.g., custodian, broker-dealer, money
manager, recordkeeper, etc...), as a result of the additional support or sponsorships of those firms.
The Firm has procedures in place to monitor the conflicts of interest presented by these
relationships.
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Item 15-Custody
The Firm does not maintain actual custody of client funds or securities. Under federal regulations,
our Firm is deemed to have custody of client funds solely because the Firm has the authority and
ability to debit its fees directly from clients’ accounts that are being charged an asset-based advisory
fee. To mitigate any potential conflicts of interests, all client assets are maintained with an
independent qualified custodian, as discussed earlier in this Brochure.
Situations where the Firm is deemed to have custody may also include affiliates serving as trustee
or co-trustee of client accounts; however, at the time of this filing, there are no clients for which this
is true.
Notably, in most cases a client’s broker-dealer also will act as the custodian of the client’s assets
for little or no extra cost. Clients should be aware, however, of the differences between having their
assets held at a broker-dealer versus at a bank or trust company. Some of these differences include,
but are not limited to, custodian costs, trading issues, security of assets, client reporting and
technology.
We have the ability to instruct your account custodian on certain transfers or withdrawals from your
account(s). Specifically, we may instruct the account custodian to distribute assets via check to your
name and address of record on file with the custodian. With your written permission on file with
the custodian, we may also transfer assets to a bank account or account held at another custodian
provided the account is in your name. All third-party distributions from your custodial account(s)
must be signed by you. We do not have authority to instruct the custodian to distribute assets from
your account at the custodian to a third-party.
The Firm will only implement its investment management recommendations after the client has
arranged for and furnished the Firm with all information and authorization regarding its accounts
held at a qualified custodian.
Clients are provided, at least quarterly, with written transaction confirmation notices and regular
written summary account statements directly from the qualified custodian and/or program sponsor
that holds and maintains their assets. These custodial statements will reflect the account holdings,
transactions for the period reported, and any additions and withdrawals from the account, including
the withdrawal of the Firm’s advisory fees. IARs utilize third party software applications to produce
written reports summarizing periodic account activity and performance, which they can provide to
their clients from time to time. These reports will vary from custodial statements based on
accounting procedures, reporting dates, or valuation methodologies of certain securities. Clients are
urged to carefully review all custodial statements, compare them to any reports and/or statements
provided by the Firm and its IARs, and notify the Firm of any discrepancies as soon as possible,
including any error they believe can or will have occurred in the fee calculation. Please refer to Item
12 above for additional important disclosure information relating to the Firm’s practices and
relationships with custodians.
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Item 16-Investment Discretion
The Firm provides investment advisory services on a discretionary basis. Prior to the Firm assuming
discretionary authority over a client’s account, the client shall be required to execute an Investment
Advisory Agreement naming the Firm as the client’s attorney and agent in fact, granting the Firm
full authority to determine, without obtaining specific client consent, securities to be bought or sold,
or the amount of securities to be bought or sold under Direct Asset Management Services.
Clients can, at any time, impose investment restrictions in writing on the Firm’s discretionary
authority (i.e. limit the types/amounts of particular securities purchased for their account, exclude the
ability to purchase securities with an inverse relationship to the market, limit or proscribe the use of
margin in the account, etc.) Overall, the ability to have discretion over an account allows an advisor
to periodically change the allocation of the client’s account to maintain a balance between the
client’s portfolio and their risk tolerance as part of a strategic plan or implement changes due to
markets and due diligence information as part of a tactical plan for the client.
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Item 17-Voting Client Securities
The Firm does not take any action or render any advice with respect to voting of proxies solicited by
or with respect to the issuers of securities in which client assets are invested. In addition,
Registrant does not take any action or render any advice with respect to any securities held in any
accounts that are named in or subject to class action lawsuits. We do, however, forward to clients
any information that we receive regarding class action legal matters involving any security held in
client accounts. Clients will receive their proxies or other solicitations directly from the
custodian. Clients can contact the Firm to discuss any questions they have regarding a particular
solicitation.
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Item 18-Financial Information
The Firm is not required to provide financial information in this Brochure because we: (1) do not
take custody of client funds or securities, other than deduction of advisory fees as described in Item
15 of this Brochure; (2) are not aware of any financial commitment that is likely to impair our ability
to provide the services identified in this Brochure; (3) have not been the subject of a bankruptcy
proceeding; and (4) do not require the prepayment or solicit prepayment of more than $1,200 in fees
per client six (6) months in advance.
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MARINER INDEPENDENT ADVISOR NETWORK, LLC
PRIVACY POLICY NOTICE
Our Commitment to your Privacy
As a client or prospective client of Mariner Independent Advisor Network, LLC (the “Firm”), you
share both personal and financial information with us. Your privacy is important to us, and we are
dedicated to safeguarding your personal and financial information.
Information Provided
In the normal course of business, such as when you open an account, direct us to buy securities, seek
advice about your investments, or enter into a contract, we typically obtain nonpublic personal
information about our prospective and current clients, which may include but is not limited to:
• Personal identity such as name, address and Social security number;
•
Information regarding securities transactions effected by us or others;
•
Information reported on applications or other forms provided by the client, including but not
limited to net worth, assets, income, accounts and balances; and
Information developed as part of financial plans, analysis and other advisory services.
•
How We Manage and Protect Your Personal Information
In order to protect current, prospective and former clients’ nonpublic, personal information, we
maintain physical, electronic and procedural safeguards. The Firm also limits access to personal
information to individuals who need to know that information in order to service your account and
provides training to its employees on proper handling of personal information.
•
Our Privacy Policy restricts the use of your information and requires that it be held in strict
confidence. Specifically:
• We do not share any of the above referenced non-public personal information about current,
prospective and/or former clients to third parties, other than to our affiliates for everyday
business purposes (but not information about your creditworthiness), nor is it our practice to
disclose such information to third parties unless necessary to administer, manage, service, and
provide related services for client accounts, to offer our products and services to you through
marketing, or as permitted to do so by law.
In the event we deem it necessary to share information with outside companies that perform
administrative or marketing services for the Firm, our contractual arrangements with these
service providers require them to treat current, prospective and/or former client information as
confidential and to not use it for any purpose beyond the scope of the agreement.
• Except as otherwise stated above, we will only release non-public personal information if a client
or client representative directs us to do so, or if we are compelled by law to disclose personal
information, such as to government entities, credit bureaus or in response to subpoenas.
• We will not share your non-public personal information with a non-affiliate for purposes of the
non-affiliate to market to you, unless your financial advisor leaves the Firm, retires or sells his
or her practice.
In situations where a financial institution does disclose customer information to nonaffiliates, other
than permitted or required by law, customers must be given the opportunity to opt out or prevent
such disclosure. As described herein, the Firm does not share or disclose current, prospective and/or
former clients’ nonpublic, personal information to nonaffiliates except where permitted or required
by law.
Definitions
Affiliates. Companies related by common ownership or control. They can be financial and
nonfinancial companies.
Nonaffiliates. Companies not related by common ownership or control. They can be financial and
nonfinancial companies.
State-Specific Information
VT Residents: For accounts with a Vermont mailing address, we may disclose all of the information
we collect, as described above to companies that perform marketing services on our behalf.
CA Residents: For accounts with a California mailing address, we may disclose all of the
information we collect, as described above to companies that perform marketing services on our
behalf. California residents may also have additional rights in connection with their non-financial
data, as outlined in our California Privacy Policy Notice.
Tax Services
To the extent our employees or affiliates are providing tax services as certified public accountants,
we are governed by professional standards set forth by the American Institute of Certified Public
Accountants Ethical Standards and governing state accountancy laws.
Information that we receive from you for the specific purposes of receiving tax services provided
by the Firm shall be retained and eventually disposed of in accordance with applicable federal and
state laws that govern general public accountants.
Client Notifications
We will annually provide a notice to clients of our privacy policy. In the event of any material
changes to our privacy policy, we will provide clients with notice of such changes.