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Item 1-Cover Page
Mariner Platform Solutions, LLC
also doing business as Mariner Independent
Nall Corporate Centre II
5700 W. 112th Street, Suite 500
Overland Park, KS 66211
(650) 571-1934
Form ADV Part 2A
October 8, 2025
https://independent.mariner.com/
This Brochure provides information about the qualifications and business practices of Mariner
Platform Solutions, LLC, also doing business as Mariner Independent (“we” or the “Firm”) (CRD
#305418). 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 Platform Solutions, LLC-Form ADV Part 2A
October 8, 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.
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.
•
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 use of Flourish and with the Firm’s Enterprise Partnership Alliance Program.
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 us at (650)
571-1934 or advdelivery@mariner.com .
Mariner Platform Solutions, LLC-Form ADV Part 2A
October 8, 2025
2
Item 3-Table of Contents
Item 1-Cover Page ....................................................................................................................................... 1
Item 2-Material Changes ............................................................................................................................ 2
Item 3-Table of Contents ............................................................................................................................ 3
Item 4-Advisory Business ........................................................................................................................... 4
Item 5-Fees and Compensation ................................................................................................................ 15
Item 6-Performance-Based Fees and Side-By-Side Management ........................................................ 21
Item 7-Types of Clients ............................................................................................................................. 22
Item 8-Methods of Analysis, Investment Strategies and Risk of Loss ................................................. 23
Item 9-Disciplinary Information.............................................................................................................. 37
Item 10-Other Financial Industry Activities and Affiliations ............................................................... 38
Item 11-Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..... 43
Item 12-Brokerage Practices .................................................................................................................... 46
Item 13-Review of Accounts ..................................................................................................................... 51
Item 14-Client Referrals and Other Compensation ............................................................................... 52
Item 15-Custody ........................................................................................................................................ 55
Item 16-Investment Discretion ................................................................................................................. 56
Item 17-Voting Client Securities .............................................................................................................. 58
Item 18-Financial Information ................................................................................................................ 59
Mariner Platform Solutions, LLC-Form ADV Part 2A
October 8, 2025
3
Item 4-Advisory Business
About Mariner Platform Solutions
Mariner Platform Solutions, LLC (the “Firm,” “we,” or “us”) is an investment adviser registered
with the SEC. We are a limited liability company organized under the laws of Delaware. We are
wholly owned by Mariner Advisor Network, LLC (referred to herein as the “Network”). The
Network is wholly owned by Mariner Wealth Advisors, LLC (referred to herein as “Mariner”).
Mariner is 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 Mariner, as well as entities affiliated with Leonard
Green & Partners, LLC (together with its affiliates, “LGP”) and NB Alternative Advisers, LLC
(together with its affiliates, “NBAA”), each of which operate separately from Mariner. We are
headquartered in Overland Park, Kansas.
The Firm provides advisory services through its Investment Adviser Representatives (“IARs”).
IARs are independent contractors of the Firm. IARs of the Firm generally have their own business
entities with trade names, logos, and websites that they use in marketing the services they provide
through the Firm. Such business entities are generally owned by one or more IARs of the Firm,
not the Firm itself. The names of these business entities are set out in the Firm’s Form ADV Part
1. Clients should understand that the businesses are generally legal entities of the IAR and not of
the Firm or the custodian. Additionally, the business entities owned by the IAR may provide
services other than investment advice. IARs may choose to use AdvicePeriod, a d/b/a of the Firm
instead of setting up their own business entity. In this case, the IARs are not owners of
AdvicePeriod. All IARs are under the supervision of the Firm and the advisory services of the IAR
are provided through the Firm.
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
Mariner Platform Solutions, LLC-Form ADV Part 2A
October 8, 2025
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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 models, options, structured notes and fixed income strategies. Additionally, IARs have
access to models developed and managed by other third-party investment managers for use in
client accounts.
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. IARs 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.
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.
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
Mariner Platform Solutions, LLC-Form ADV Part 2A
October 8, 2025
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managed accounts, separately managed accounts and model programs to access third-party money
managers.
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 Investment 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 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. 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
Mariner Platform Solutions, LLC-Form ADV Part 2A
October 8, 2025
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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.
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.
Financial Planning and Consulting
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 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. IAR’s are required to report such activity as an Outside Business Activity and are supervised
accordingly.
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 the use of the Mariner Wealth tax team. Certain IARs also provide tax services
on a stand-alone basis, pursuant to a separate tax engagement agreement, to individuals,
Mariner Platform Solutions, LLC-Form ADV Part 2A
October 8, 2025
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businesses, and family offices. Although the Firm is a registered investment adviser under the
Investment Advisers Act of 1940 (“Advisers Act”), the Firm and Mariner Wealth are not serving
in a fiduciary capacity in the 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.
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.
Retirement Plan Consulting and Management Services
IARs of the Firm provide consulting and advisory services for employer-sponsored retirement
plans that are designed to assist plan sponsors of employee benefit plans. Generally, such
retirement plan consulting and advisory services consist of managing or otherwise advising
sponsors in establishing, selecting, monitoring, removing and/or replacing the investment options
under the plan, consistent with the objectives, written guidelines and/or investment objectives set
forth in the written investment policy statement adopted by the plan sponsor. As the needs of the
plan sponsor dictate, the Firm offers the following areas of management or advisement: plan
investment options, asset allocation, plan structure, participant education, and managing model
portfolios through Advisor Managed Accounts. Practically such areas generally fall into the
following general core services:
•
•
•
•
•
•
•
Fee Benchmarking
Recordkeeper Search & Review
Fund Lineup Selection
Performance Measurement & Reporting
Trustee Education
Regulatory Updates
Resource to the Board for Strategy and Decision-making
When providing consulting and/or management services to plan sponsors of employee benefit
plans, plan participants should not assume that general informational materials or educational
sessions devised and/or provided by the Firm on behalf of the plan serves as the receipt of, or as a
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substitute for, personalized investment advice from the Firm, or from any other investment
professional. To the extent that any participant requires initial or ongoing personalized investment
advice, he/she is encouraged to consult with the investment professional of his/her choosing.
In addition to the services described above, IARs of the Firm may also provide discretionary
advisory services to client accounts that are governed by the Employment Retirement Income
Security Act of 1974, as amended (“ERISA”).
All retirement plan investment advisory services shall be in compliance with the applicable state
law(s) regulating retirement plan advisory services. This applies to client accounts that are plans
governed by ERISA. If the client accounts are part of the plan, and we accept appointments to
provide our services to such accounts, we acknowledge that we are a fiduciary within the meaning
of section 3(21) of ERISA (but only with respect to the provision of services described in the
applicable agreement). We emphasize continuous and regular account supervision. Once the
appropriate plan investments have been determined, we review the plan investments at least
annually and if necessary, provide advice to or otherwise add, replace or remove investment
options based upon the plan sponsor’s objectives, written guidelines and/or investment objectives.
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.
The Pathway DC Solution
The Pathway DC solution provides a comprehensive service solution for small Defined
Contribution (DC) plans which incorporates institutional investment vehicles in plan line ups, plan
design, and available technology solutions to deliver necessary information in an electronic format
(including education, quarterly reports and annual benchmarking). This solution provides clients
with 3(38) fiduciary support on the investments by Mariner as well as 3(16) plan administration
support provided by the recordkeeper. We are contracted with Empower, T. Rowe Price, and
Vestwell as the underlying recordkeepers. Accordingly, as these recordkeepers are considered
preferred providers, clients should be aware that their options are limited to choose one of these
three providers. If a client prefers a different recordkeeper, they may be better served to opt for a
customized approach, rather than the Pathway DC Solution.
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);
Mariner Platform Solutions, LLC-Form ADV Part 2A
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• Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
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.
Our Material Conflicts of Interest
Our material conflicts of interest are described in this brochure.
Investment advisory, financial planning, tax and/or retirement service recommendations as
described above may pose a conflict between the interests of the Firm and the interests of clients.
For example, a recommendation to engage the Firm for investment advisory services or to increase
the level of investment assets with the Firm, including through rollovers or other transfers of
retirement plan accounts or IRAs, would pose a conflict, as it would increase the advisory fees
paid to the Firm. Clients are not obligated to implement any recommendations made by the Firm
or maintain an ongoing relationship with the Firm. If a client elects to act on any of the
recommendations made by the Firm, the client is under no obligation to execute the transaction
through the Firm.
In addition, please note the following:
Advisory Services (the Firm) vs. Brokerage Services. In most cases, the total compensation that
our Firm receives (consisting primarily of advisory fees) for providing investment advisory
services is more than a brokerage firm may receive (consisting primarily of commissions and other
transaction-based payments, including trail compensation) for providing brokerage services. Also,
the advisory fees you would pay to us in an investment advisory account do not decrease even
where the level of investment trading activity in your advisory account is low. IARs receive a
percentage share of the fees they generate.
While we are not prohibited from doing so, if you are an investment advisory client of the Firm,
in most cases we do not expect to recommend that you roll over plan accounts or IRAs into
brokerage IRAs serviced by a brokerage firm, because we generally intend to manage these
accounts on an integrated basis together with your other advisory accounts, and those of your
household (if applicable).
Mariner Platform Solutions, LLC-Form ADV Part 2A
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Rollovers and Account Type Changes
Regardless of the investments and services you select, the Firm will make more money if you roll
over assets from a retirement plan or IRA for which we do not provide services, to a retirement
plan or IRA for which we do provide services, whether the rollover is from (1) a plan to an IRA,
(2), an IRA to an IRA, (3) a plan to another plan, or (4) an IRA to a plan (as those terms are
described above). As noted above, IARs are compensated based on the total client fees they
generate for the Firm. Therefore, both our Firm and our individual wealth advisors have financial
incentives to recommend plans and/or IRA rollovers to plans and IRAs serviced by us. You are
under no obligation, contractually or otherwise, to complete the rollover. Furthermore, if you do
complete the rollover, you are under no obligation to have the assets in an IRA managed by us.
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 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 subadvisory
relationship with Mariner. 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 subadvisory 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.
Personalized Equity Portfolios
We offer our clients personalized equity portfolios. This strategy is generally designed to provide
clients with broad equity exposure with the added benefit of tax loss harvesting. It may also be
used to create personalized equity strategies based on client circumstances around tax or stock
concentrations or based on their values-based preferences. We rely on the screens provided by our
portfolio management system to implement the portfolios with respect to sector, industry, or
values-based identification.
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.
Additionally, certain of our clients hold positions in a series fund which is managed by an
unaffiliated investment advisor and through which they are able to access certain private equity
and hedge fund portfolios.
Mariner Platform Solutions, LLC-Form ADV Part 2A
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Robo-Advisory Program
For some legacy clients, our wealth advisors may have recommended a web-based electronic
investment advisory program operated and provided by Betterment LLC, a third-party investment
adviser (“Betterment”). Under this arrangement, clients access Betterment exclusively through
their website. Clients provide Betterment with their risk tolerance, financial circumstances and
other information and their portfolio is created with asset allocations in exchange-traded funds
(ETFs) that match tolerance levels and goals. Betterment then provides investment advice to the
client and directs trades to its affiliated broker-dealer, Betterment Securities. In addition to the
advisory fee a client agrees to pay the Firm, clients pay Betterment a fee that covers the investment
advice, execution, and custody of the client’s account in the Betterment Program (the “Program”).
Clients should understand that with Robo-Advisory Services:
• Advice provided by Betterment is computer-generated, and therefore inherently has several
limitations including, but not limited to, the following: (i) neither the Firm nor Betterment
can ensure that the Program can achieve any particular tax result for any client or that the
mathematical algorithms employed are designed properly, updated with new data, and can
accurately predict future security, market, industry, and sector performance; (ii) the
algorithm may rebalance Program accounts without regard to the then-current market
conditions or on a more frequent basis than the client might otherwise expect; and (iii) the
algorithm may not address prolonged market condition changes.
• We will be unable to manage your Program account in a way we may otherwise advise for
advisory accounts we manage. Betterment can amend the terms of the client’s agreement
at any time upon notice to the client. A client’s participation in the web-based electronic
investment advisory program is subject to numerous conditions (as noted on the website);
Clients must agree to arbitration of any disputes they may have with Betterment; and
• Betterment fees are billed in arrears while the Firm bills primarily in advance.
Annuity Products
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
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 a 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
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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.
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. Clients are encouraged to review the variable
annuity prospectus prior to investing.
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.
Client Agreement
(the “Agreement”). Additionally, we will only
implement our
Prior to engaging an IAR of the Firm, the client will be required to enter into one or more written
agreements setting forth the terms, conditions, and objectives under which we shall render our
investment
services
recommendations after a client has arranged for and furnished all information and authorization
regarding accounts with appropriate financial institutions. Clients are advised to promptly notify
their IAR if there are ever any changes in their financial situation or investment objectives.
Assets Under Management
Our total assets under management are approximately $5,615,227,678 with $4,927,393,122
managed on a discretionary basis and $687,834,557managed on a non-discretionary basis as of
December 31, 2024.
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Item 5-Fees and Compensation
The specific manner in which our fees are charged is established in the Agreement. While certain
clients may be billed in arrears, we will generally bill our fees in advance on a quarterly basis
based upon the value of assets under management and/or advisement on the last day of the previous
quarter, as valued by the applicable custodian, 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, or a third-
party service provider engaged by 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 a statement to the client, at least
quarterly, indicating all amounts disbursed from the account including the amount of advisory fees
paid directly to us. We urge clients to carefully review such account statements for accuracy.
A client may make additions to and withdrawals from the account at any time, subject to our right
to terminate an account. As provided for in the client’s Agreement, if assets are deposited into an
account after the inception of a quarter that exceed the threshold set forth in the specific client’s
Agreement, the fee payable with respect to such assets will be prorated based on the number of
days remaining in the quarter. The Firm typically reserves the right to adjust the threshold upon
advance notice to clients. No threshold may be applicable, as set forth in the applicable Agreement.
If the Agreement is executed at any time other than the first day of a calendar quarter, our fees will
apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number
of days in the quarter for which you are a client. The Agreement between us and a client will
continue in effect until terminated by either party pursuant to the terms of the Agreement. In the
event the Agreement is terminated, the fee for the final billing period will be prorated through the
effective date of termination, and the outstanding or unearned portion of the fee will be charged or
refunded to you, as appropriate.
Our management fee is negotiable, depending on individual client circumstances. A client may
withdraw account assets, subject to the usual and customary securities settlement procedures.
Clients should note that we design our portfolios as long-term investments and asset withdrawals
can impair the achievement of a client’s investment objectives. The applicability of the proration
as set forth herein is governed by the specific Agreement with each client. Clients should refer to
their applicable Agreements to understand the specific billing practices applicable to their assets.
As set forth in a client’s Agreement, we may charge a client fixed fees and apply an annual
adjustment of an agreed-upon percentage.
Additions may be in cash or securities provided that we reserve the right to liquidate any
transferred securities or decline to accept particular securities into a client’s account. We may
consult with our clients about the options and ramifications of transferring securities. However,
clients are advised that when transferred securities are liquidated, they are subject to transaction
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fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or tax
ramifications.
For a limited portion of client accounts, we utilize the Adhesion Wealth unified managed account
program to access third-party money managers for certain client accounts. Accounts in Adhesion
Wealth unified managed account program are charged an additional annual fee of 0.08% by
Adhesion Wealth and an annual manager fee up to 0.50% depending on the manager(s) selected,
in addition to the annual advisory fee and additional annual advisory fee described above. We
make available and, where appropriate and permitted by applicable law, may select our own
manager option within the Adhesion Wealth unified managed account program to manage client
accounts. Where we select this option for a client, we will receive the manager fee for those
accounts. This creates a conflict of interest because we will receive the manager fee in addition to
the annual advisory fee and additional annual advisory fee. Clients will receive statements from
the custodian that present the fees charged to accounts and may also ask us at any time for a
description and accounting of the annual advisory fees, additional annual advisory fees and
manager fees being charged.
Investment Advisory Fees
The structure and level of our advisory fee will vary by client based upon the services provided
and other considerations deemed relevant by the Firm and its IARs, but typically takes the form of
a percentage of assets under management and/or advisement, ranging up to 2.50% per annum. As
set forth in your Agreement, the Firm may apply a minimum fee. Unless otherwise agreed with a
client, advisory fees are applied to all assets under management and assets under advisement, if
applicable. Clients that receive financial planning and consulting services from the Firm in
addition to investment advisory services may be subject to an additional fee, which is added to the
advisory fee, in connection with such services. For consulting and reporting services, the structure
and level of fees will vary by client based upon the services provided and other considerations
deemed relevant by the Firm. As set forth in your Agreement, we may charge you fixed fees and
apply an annual adjustment of an agreed-upon percentage. At our discretion, we may agree to
‘household’ certain client accounts for purposes of fee calculation depending on the client
relationship and overall services provided. All fee arrangements are subject to negotiation and fees
for similarly situated clients may differ for a variety of reasons. Please see your Agreement for the
fees applicable to your account.
To the extent that a client authorizes the use of margin, the market value of the client’s account
and corresponding fee payable by the client may be increased. Clients authorizing margin are
advised of the potential conflict of interest whereby the client’s decision to employ margin may
correspondingly increase the management fee payable to the Firm.
Financial Planning and Consulting Fees (Stand-Alone)
The Firm’s financial planning and consulting fees are generally billed on a fixed fee basis, an
hourly rate basis, or based upon a percentage (%) per annum for services provided at any asset
level, depending upon the level and scope of the service(s) required and the professional(s)
rendering the service(s). As applicable, clients are billed directly for financial planning services.
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Financial planning service fees are payable in advance and are immediately due upon receipt of
invoice for the financial planning services. All fee arrangements are subject to negotiation.
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.
Fees for Retirement Plan Consulting and Management Services
For employer sponsored retirement plans, the advisory fee will vary by client based upon the
services provided but shall be reasonable in conformity with U.S. Department of Labor
regulations. The structure and level of fees relating to these services will vary by client based upon
the services provided and other considerations deemed relevant by the Firm, but typically takes
the form of a fixed fee or a percentage of assets under management. We will generally bill these
fees in arrears and payment is typically collected by directly remitted payments from clients or
through client directed deductions through a plan’s record keeper.
Our Pathway DC Solution is based on a set fee schedule, which may vary by provider, but is
generally a tiered asset-based fee, and in some cases, a separate flat fee paid by a Plan Sponsor.
Please see your advisory agreement for specific fees applicable to you
Private Fund Fees
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 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.
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Third-Party Manager Fees
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 the third-party’s disclosure documents 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 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. For certain sub-advisers there may be a separate written agreement
between you and the sub-adviser to pay an additional amount directly to the sub-adviser.
Robo-Advisory Program (Betterment)
In addition to the advisory fee a client agrees to pay the Firm, clients in the Program pay Betterment
a fee that covers the investment advice, execution, and custody of the client’s account in the
Betterment Program. The Betterment fee is billed in arrears.
Additional Fees and Expenses
Our fees are exclusive of administration expenses, brokerage commissions, transaction fees, fund
expenses and other related costs and expenses which shall be incurred by a client. Custody fees
will vary depending on the custodian. Clients utilizing the same custodian may be subject to
differing levels of custody fees, based on the billing practices of the applicable custodian. For
example, custodians grandfathered reduced custody fees with respect to client accounts that were
assigned to the Firm as a result of AdvicePeriod’s acquisition by the Firm’s parent company. All
brokerage charges and related transaction costs are charged to the account(s) as they occur. Clients
incur certain charges imposed by custodians, brokers, third party managers and other third parties
such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials,
transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage
accounts and securities transactions.
When beneficial to the client, certain transactions may be effected through brokers other than the
account custodian, in which event, except in situations in which the custodian has waived the
additional fee, the client generally will incur both the fee (commission, mark-up/mark-down)
charged by the executing broker and a separate “tradeaway,” “step-out” and/or prime broker fee
charged by the custodian.
Mutual funds, closed-end funds, ETFs, structured products and other pooled investment vehicles
are subject to commissions, fees and expenses which are disclosed in the fund’s prospectus or
offering documents. Such charges, fees and commissions are exclusive of and in addition to our
advisory fee. Clients may be charged a sales load for any mutual funds where applicable.
Many funds offer multiple share classes available for investment based upon certain eligibility
and/or purchase requirements. For instance, in addition to more commonly offered retail mutual
fund share classes (typically, Class A (including load-waived A shares), B and C shares for mutual
funds), some funds offer institutional share classes or other share classes specifically designed for
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purchase by an account for a fee-based investment advisory program. However, these share classes
may also have higher transaction costs and may have minimum purchase criteria that limit
availability to larger transactions. Clients should not assume that their assets will be invested in
the share class (regardless of the type of fund structure – mutual fund, closed-end fund, hedge
fund, private equity fund or other alternative vehicle) with the lowest possible expense ratio.
Brokerage Products
Advisory clients should note that they have the option to purchase investment products
recommended by us through other non-affiliated brokers, agents or agencies. Non-discretionary
brokerage accounts opened or maintained to purchase investment products (i.e., 529s, mutual
funds and variable annuities) by engaging dually registered IARs, in their individual capacities, as
registered representatives, will result in the unaffiliated broker-dealer and the related registered
representative(s) receiving certain commissions, fees and costs, as applicable, on the brokerage
product.
The recommendation to purchase commission products from an unaffiliated broker-dealer presents
a conflict of interest, as the receipt of commissions provides an incentive to recommend investment
products based on commissions to be received. No client is under any obligation to purchase
commission products.
Annuities and life insurance products recommended by our advisors may contain charges such as
mortality and expense fees, administrative fees, and optional rider fees. These fees vary by
company and are disclosed in the materials related to the insurance product. In addition, our
insurance agency affiliate will receive one-time or trail commission from the insurance company
depending on the specific contract. Please refer to the insurance product materials for details.
Item 12 further describes the factors that we consider in selecting or recommending broker-dealers
for client transactions and determining the reasonableness of their compensation (e.g.,
commissions) and compensation received by the Firm.
Conflicts of Interest
When allocating investment opportunities among clients, the Firm and/or its IARs have an
incentive to favor the investment programs, products and clients that generate the most revenue
for the Firm and/or its IARs.
Martin Bicknell, the CEO and President of the Firm, has significant, indirect ownership stakes in
the Firm’s parent company, Mariner, and in Mariner’s parent company, 1248. As further detailed
in Item 10, because Mariner and 1248 own or have interests in various other investment-related
service providers and investment managers, (collectively referred to as affiliates), the Firm has an
indirect financial incentive to recommend other services provided by affiliates because revenues
earned by the affiliates from such services ultimately flow to Mariner and 1248. The Firm has
mitigated this conflict by disclosing it to clients and providing IARs with tools to set up and
periodically perform a review of client accounts to ensure that the investments are suitable for the
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client in light of, among other factors, the client’s investment objective and financial
circumstances.
As further detailed in Item 10, the Firm and the principal voting owners, Mariner, 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 the Firm. 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 wealth advisors with considerations of various
factors, including but not limited to, the client’s investment objective and financial circumstances.
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.
Compensation of Employees
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, the Firm and its affiliates offer a variety of services to our clients beyond
investment advisory services. Certain IARs 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.
As permitted by applicable law, we compensate certain employees for business development
activities, including the attraction or retention of client assets.
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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 certain products managed by third parties that charge
performance-based fees.
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 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. Certain limited investment opportunities are available only to clients of certain
IARs of the Firm.
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Item 7-Types of Clients
IARs of the Firm generally provide investment advice to the following types of clients:
Individuals (including high net worth individuals)
•
• Pension and profit-sharing plans
• Trusts, estates, or charitable organizations
• Corporations or business entities other than those listed above
As discussed elsewhere in this Brochure, we may impose minimum account size requirements
with respect to certain of our advisory services. In addition, certain third-party managers may
impose more restrictive account requirements and varying billing practices than us. In such
instances, we may alter our corresponding account requirements and/or billing practices to
accommodate those of the manager(s).
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Item 8-Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis and Investment Strategies
Wealth Management Services
The Firm and its IARs generally construct portfolios for clients using a broad mix of investment
types, including but not limited to individual stocks, bonds, ETFs, closed-end funds, mutual funds,
private pooled investment vehicles, structured notes, options, derivatives, alternative investments
and digital assets. The Firm and its IARs will manage clients’ assets through the direct purchase
of securities, by allocating to other managers and/or by investing in a variety of funds. IARs work
to determine each client’s asset allocation based on the client’s specific objectives and unique
circumstances. IARs begin the relationship with a clear and thorough understanding of each
client’s objectives, time horizon, risk profile and income needs. We utilize a long-term strategy
when providing and implementing our advice. However, should a client’s situation change or the
basis for making an investment change, there are occasions where we will utilize a short-term
strategy and securities are held less than one year.
In developing investment strategies for accounts invested in the Firm models, both quantitative
and qualitative reviews are conducted in an effort to identify the appropriate investment strategies
in each asset category detailed below. Certain strategies may include responsible investments that
consider environmental, social and governance (“ESG”) factors. In developing investment
strategies for clients managed directly by an IAR (not within a Firm model), each IAR will utilize
its own due diligence methodology, including utilization of research provided by third parties.
Within a client’s portfolio, IARs may employ one or more of the strategies detailed below as well
as other investment strategies. Within a strategy, IARs may choose to invest client accounts in
individual securities and/or utilize other managers through investment in funds.
Principal Investment Strategies for Model Accounts
The Firm may construct models for model accounts consisting of equities (through separately
managed accounts), ETFs, mutual funds and other investment vehicles which pursue investment
strategies focused on global equities, global bonds, real assets, and alternatives (private funds and
insurance linked products), among others.
Principal Investment Strategies for Accounts Managed Directly by IARs
IARs of the Firm may construct models for accounts they manage directly using closed end funds,
ETFs, equities, fixed income securities, mutual funds and other investment vehicles which pursue
investment strategies focused on global equities, global bonds, real assets and alternatives (private
funds and insurance linked products), among others.
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Other Available Investment Strategies
From time to time, IARs recommend that clients authorize the active discretionary management
of a portion of their assets by and/or among certain third-party manager(s) where appropriate based
upon the stated investment objectives of the client. The client will receive a copy of the third-party
manager’s Form ADV Part 2A.
Options Strategies
Certain IARs recommend options strategies to clients. Options are investments whose ultimate
value is determined from the value of the underlying investment. Some of our options strategies
utilize a significant amount of leverage on a client’s underlying collateral positions which involves
the borrowing of funds from brokerage firms, banks and other institutions in order to be able to
increase the amount of capital available for marketable securities investments.
Structured Notes
Certain IARs recommend structured notes strategies to clients. Structured notes are a contract
between an issuing financial institution and the purchaser and possess certain intricate derivative-
like features. Our structured notes strategies utilize leverage.
Variable Prepaid Forwards
We offer variable prepaid forward strategies to our clients. A variable prepaid forward 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.
Personalized Equity Portfolios
Certain IARs recommend direct indexing strategies for clients. Direct indexing is a method of
investing where one or more broad indexes is replicated or mimicked by purchasing numerous
individual stock positions. In taxable accounts, a strategy of tax loss harvesting is often employed
in direct indexing accounts. Certain deviations from strictly mimicking indexes may be present to
accommodate previously held low-basis stock positions in clients’ accounts, or their stated values-
based investing preferences.
Equity Strategies
Certain IARs recommend equity strategies for clients. The equity strategies vary by mandate, all
with a focus on capital appreciation as a primary objective. Philosophies include dividend-based
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strategies, GARP (growth at a reasonable price), value, growth, socially conscious and direct
indexing. In strategies other than direct indexing, individual securities are selected based upon
fundamental analysis performed by research investment professionals. These professionals rely
primarily on publicly available information in their analysis, supplemented by third-party research
and analytical tools.
Fixed Income Strategies
Certain IARs recommend fixed income strategies for clients. The primary objective of the
managed account fixed income strategies is capital preservation Secondary objectives include
providing steady income and the potential for capital appreciation. For managed accounts over
$500,000, the 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.
For managed accounts under $500,000, we managed laddered bond strategies in which bonds are
purchased according to a model and are only sold because of changing opinions on the bond’s
credit quality or a bond maturing.
Risk of Loss
Investing in securities involves a risk of loss that you should be prepared to bear, including loss of
your original principal. Past performance is not indicative of future results; therefore, you should
not assume that future performance of any specific investment or investment strategy will be
profitable. We do not provide any representation or guarantee that your goals will be achieved.
In addition to the general investment risks listed herein, there are additional material risks
associated with the types of strategies in which your account invests from time to time. Please refer
to the relevant prospectus or offering materials for more information regarding risk factors for a
particular investment in an ETF, closed-end fund, mutual fund or other pooled investment vehicle.
Depending on the different types of investments and strategies employed for your account, there
are varying degrees of risk:
• 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 in material losses.
• 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
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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.
• Equity Risk–Stocks are susceptible to fluctuations and to the volatile increases and
decreases in value as their issuer’s confidence in or perceptions of the market change.
Investors holding common stock of any issuer are generally exposed to greater risk than if
they hold preferred stock or debt obligations of the issuer.
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• Company Risk–There is always a level of company or industry risk when investing in stock
positions. This is referred to as unsystematic risk and can be reduced through appropriate
diversification. There is the risk that a company will perform poorly or that its value will
be reduced based on factors specific to it or its industry.
• Options Risk–Options on securities are subject to greater fluctuations in value than
investing in the underlying securities. Purchasing and writing put or call options are highly
specialized activities and involve greater investment risk. Puts and calls are the right to sell
or buy a specified amount of an underlying asset at a set price within a set time. Options
like other securities carry no guarantees, and investors should be aware that it is possible
to lose all of your initial investment, and sometimes more. Option holders risk the entire
amount of the premium paid to purchase the option. If a holder’s option expires “out-of-
the-money” the entire premium will be lost. Option writers may carry an even higher level
of risk since certain types of options contracts can expose writers to unlimited potential
losses. Extreme market volatility near an expiration date could cause price changes that
result in the option expiring worthless. Since options derive their value from an underlying
asset, which may be a stock or securities index, any risk factors that impact the price of the
underlying asset will also indirectly impact the price and value of the option.
• Margin Risk–Margin trading involves interest charges and risks, including the potential to
lose more than deposited or the need to deposit additional collateral in a falling market. A
margin transaction occurs when an investor uses borrowed assets by using other securities
as collateral to purchase financial instruments. The effect of purchasing a security using
margin is to magnify any gains or losses sustained by the purchase of the financial
instruments on margin. To the extent that a client authorizes the use of margin, and margin
is thereafter employed by the Firm in the management of a client’s investment portfolio,
the market value of the client’s account and corresponding fee payable by the client to the
Firm will be increased. As a result, in addition to understanding and assuming the
additional principal risk associated with the use of margin, clients authorizing margin are
advised of the potential conflict of interest whereby the client’s decision to employ margin
will correspondingly increase the advisory fee payable to the Firm.
• Short selling–This is an investment strategy which involves the selling of assets that the
investor does not own. The investor borrows the assets from a third-party lender (i.e.,
Broker-Dealer) with the obligation of buying identical assets at a later date to return to the
third-party lender. Individuals who engage in this activity shall only profit from a decline
in the price of the assets between the original date of sale and the date of repurchase.
• Covered Call Risk–The writer of a covered call forgoes the opportunity to benefit from an
increase in the value of the underlying interest above the option price but continues to bear
the risk of a decline in the value of the underlying interests.
• Small- and Medium–Capitalization Companies – Depending on the strategy, the Firm
invests client assets in the stocks of companies with small- to medium-sized market
capitalizations. While the Firm believes they often provide significant profit opportunities,
those stocks, particularly smaller-capitalization stocks, involve higher risks in some
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respects than investments in stocks of larger companies. For example, prices of small-
capitalization and even medium capitalization stocks are often more volatile than prices of
large-capitalization stocks, and the risk of bankruptcy or insolvency of many smaller
companies is higher than for larger, “blue-chip” companies. In addition, due to thin trading
in some small capitalization stocks, an investment in those stocks is likely illiquid (see
discussion below).
• Socially Conscious Investing–Depending on the strategy or client-specific restrictions, a
client’s account may undergo exclusionary or inclusionary screening based on
environmental, social and corporate governance criteria, as well as other criteria based on
religious beliefs. These criteria are nonfinancial reasons to exclude or include or security
and therefore the client’s account or strategy may forgo some market opportunities
available to portfolios that don’t use such screening. Stocks selected following these
criteria may shift into and out of favor with stock market investors depending on market
and economic conditions, and the client’s or strategy’s performance may at times be better
or worse than the performance of accounts or strategies that do not use such criteria.
• Fixed Income Risk–Investing in bonds involves the risk that the issuer will default on the
bond and be unable to make payments. In addition, individuals depending on set amounts
of periodically paid income face the risk that inflation will erode their spending power.
Fixed-income investors receive set, regular payments that face the same inflation risk. In
addition, a rise in interest rates will generally result in the decline in the value of fixed
income securities. Fixed income securities are also subject to reinvestment risk in that if
interest rates are falling during a period of reinvestment returns will be lower. Interest rate
risk increases as portfolio duration increases. Reinvestment risk increases as portfolio
duration decreases.
• Non-Investment Grade Bonds–Depending on the strategy, a client account will invest in
bonds (commonly known as “junk bonds”) that are of below investment grade quality
(rated below Baa3 by Moody’s Investors Service, Inc. or below BBB- by Standard &
Poor’s Ratings Group and Fitch Ratings or, if unrated, reasonably determined by the Firm
to be of comparable quality (“non-investment grade bonds”). An account’s investments in
non-investment grade bonds are predominantly speculative because of the credit risk of
their issuers. While normally offering higher yields, non-investment grade bonds typically
entail greater potential price volatility and will likely be less liquid than investment grade
securities.
• Distressed Securities–An account, depending on the strategy, will invest in securities of
companies that are experiencing or have experienced significant financial or business
difficulties. Distressed securities may generate significant returns for an account, but also
involve a substantial degree of risk. In certain circumstances, an account will lose a
substantial portion or all of its investment in a distressed company or be required to accept
cash or securities with a value less than an account’s original investment. The market prices
of such investments are also subject to abrupt and erratic market movements and above
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average price volatility, and the spread between the bid and asked prices of such
investments will likely be greater than for non-distressed securities.
• ETF, Closed-end Fund and Mutual Fund Risk–ETF, closed-end fund and mutual fund
investments bear additional expenses based on a pro-rata share of operating expenses,
including potential duplication of management fees. The risk of owning an ETF, closed-
end fund or mutual fund generally reflects the risks of owning the underlying securities
held by the ETF, closed-end fund or mutual fund. If the ETF, closed-end fund or mutual
fund fails to achieve its investment objective, the account’s investment in the fund may
adversely affect its performance. In addition, because ETFs and many closed-end funds are
listed on national stock exchanges and are traded like stocks listed on an exchange, (1) the
account may acquire ETF or closed end fund shares at a discount or premium to their NAV,
and (2) the account may incur greater expenses since ETFs are subject to brokerage and
other trading costs. Since the value of ETF shares depends on the demand in the market,
we may not be able to liquidate the holdings at the most optimal time, adversely affecting
performance. Closed-end funds, which are not publicly offered, provide only limited
liquidity to investors. Closed-end funds generally are not required to buy their shares back
from investors upon request. In addition, they are allowed to hold a greater percentage of
illiquid securities in their investment portfolios than mutual funds.
•
the fund manager may only be able
Interval Fund Risks–Interval funds are classified as closed-end funds, but they have some
distinctive features that make them different. Interval funds continuously or periodically
offer their shares at a price based on the fund’s net asset value. But most of them do not
trade on a national securities exchange and instead buy back or “repurchase” shares directly
from investors. Repurchases are offered periodically (often quarterly), which means
investors are provided with limited liquidity. Accordingly, investments in interval funds
can expose investors to liquidity risk, and that risk is greater in funds that invest in
securities of companies with smaller market capitalizations, derivatives or securities with
substantial market and/or credit risk. There is no guarantee that investors will be able to
sell their shares at any given time or in the desired amount. Interval funds may offer to
repurchase as low as 5% of shares in a given quarter. If in a time of market stress, a lot
to
of investors attempt to exit their positions,
accommodate this slowly over multiple quarters. Because of this it’s best to consider
investments in interval funds to be illiquid.
• REITs and Real Estate Risk–The value of an account’s investments in real estate
investment trusts (“REITs”) may change in response to changes in the real estate market.
An account’s investments in REITs may subject it to the following additional risks:
declines in the value of real estate, changes in interest rates, lack of available mortgage
funds or other limits on obtaining capital and financing, overbuilding, extended vacancies
of properties, increases in property taxes and operating expenses, changes in zoning laws
and regulations, casualty or condemnation losses, and tax consequences of the failure of a
REIT to comply with tax law requirements. An account will bear a proportionate share of
the REIT’s ongoing operating fees and expenses, which may include management,
operating and administrative expenses.
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•
International Investing Risk–International investing, especially in emerging markets,
involves special risks, such as currency exchange and price fluctuations, as well as political
and economic risks.
• Emerging Markets Risk–The risks associated with foreign investments are heightened
when investing in emerging markets. The governments and economies of emerging market
countries may show greater instability than those of more developed countries. Such
investments tend to fluctuate in price more widely and to be less liquid than other foreign
investments.
• Liquidity Risk–Liquidity is the ability to readily convert an investment into cash. The less
liquid an asset is, the greater the risk that, if circumstances require an investor to sell the
asset quickly, it will be sold at a price below fair value. Generally, an asset is more liquid
if it represents a standardized product or security and there are many traders interested in
making a market in that product or security. For example, Treasury Bills are highly liquid,
while real estate properties are not.
• 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 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
Mariner Platform Solutions, LLC-Form ADV Part 2A
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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.
• 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.
• Alternative Investment Risk–Alternative investments encompass a broad array of
strategies, each with its own unique return and risk characteristics that must be considered
on a case-specific basis.
•
Insurance Linked Securities–Investments in insurance linked securities (“ILS”) are subject
to various types of risk: The primary risk relates to reinsurance triggering events, for
example: (i) natural catastrophes, such as hurricanes, tornados, or earthquakes of a
particular size/magnitude in a designated geographic area; or (ii) non-natural events, such
as large commercial accidents (e.g., marine or aviation). Such events, if they occur at
unanticipated frequencies or severities, could result in reduced investment returns for ILS
investors and even the loss of principal. There is no way to predict with complete accuracy
whether a triggering event will occur, and because of this significant uncertainty, ILS carry
a high degree of risk. Valuation risk is the risk that the ILS is priced incorrectly due to
factors such as incomplete data, market instability, model & human error. In addition,
pricing of ILS is subject to the added uncertainty caused by the inability to generally predict
whether, when or where a natural disaster or other triggering event will occur.
• 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
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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; 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
Mariner Platform Solutions, LLC-Form ADV Part 2A
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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.
• Management Risk–Investments also vary with the success and failure of the investment
strategies, research, analysis and determination of portfolio securities. If the strategies do
not produce the expected returns, the value of your investments will decrease.
• Non-Diversification Risk–If a strategy is “non-diversified,” its investments are not
required to meet certain diversification requirements under federal law. A “non-
diversified” strategy is permitted to invest a greater percentage of its assets in the securities
of a single issuer than a diversified strategy. Thus, the strategy may have fewer holdings
than other strategies. As a result, a decline in the value of those investments would cause
the strategy’s overall value to decline to a greater degree than if the strategy held a more
diversified portfolio.
• Repurchase Agreements–A client may enter into repurchase agreements, where a party
agrees to sell a security to the client and agrees to repurchase the security at an agreed-
upon price at a stated time. A repurchase agreement is like a loan by the client to the other
party that creates a fixed return for the client. All repurchase agreements are collateralized
with underlying securities. A client could incur a loss on a repurchase transaction if the
other party defaults, the value of the underlying collateral declines or the client’s ability to
sell the collateral is restricted or delayed.
• Reverse Repurchase Agreements –A client may enter into reverse repurchase agreements,
where a client sells a security to a party for a specified price, with the simultaneous
agreement by the client to repurchase that security from that party on a future date at an
agreed upon price. Similar to borrowing, reverse repurchase agreements provide a client
with cash for investment purposes, which creates leverage and subjects the client to the
risks of leverage. Reverse repurchase agreements also involve the risk that the other party
may fail to return the securities in a timely manner or at all. A client could lose money if it
is unable to recover the securities and the value of collateral held by the client, including
the value of the investments made with cash collateral, is less than the value of securities.
• 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
Mariner Platform Solutions, LLC-Form ADV Part 2A
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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.
• Other Risks, Information and Sources of Information–Client accounts are also subject to
investment style risk. A client account invested in one of the investment strategies managed
by the Firm or an IAR of the Firm involves the risk that the investment strategy may
underperform other investment strategies or the overall market. The Firm does not offer
any products or services that guarantee rates of return on investments for any time period
to any client. All clients assume the risk that investment returns may be negative or below
the rates of return of other investment advisers, market indices or investment products.
• 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.
•
Inflation Risk–Security prices and portfolio returns will vary in response to changes in
inflation and interest rates. Inflation causes the value of future dollars to be worth less and
may reduce the purchasing power of a client’s future interest payments and principal.
Inflation also generally leads to higher interest rates, which may cause the value of many
types of security investments to decline.
•
Interest Rate Risks–The prices of, and the income generated by, most debt and equity
securities will most likely be affected by changes in interest rates and by changes to the
effective maturities and credit ratings of these securities. In addition, falling interest rates
may cause an issuer to redeem or refinance a security before its stated maturity date, which
would typically result in having to reinvest the proceeds in lower-yielding securities.
• Credit Risk–Debt securities are a credit risk, which is the possibility that the credit strength
of an issuer will weaken and/or an issuer of a debt security will fail to make timely
payments of principal or interest and the security will go into default.
• 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.
Mariner Platform Solutions, LLC-Form ADV Part 2A
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• 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.
• VPFs -A variable prepaid forward (VPF) 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 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.
Allocations to third-party managers and investors in third-party investment funds (including
registered funds and private funds) are subject to the following additional risks:
• Third-Party Aggressive Investment Technique Risk–Managers and investment funds may
use investment techniques and financial instruments that may be considered aggressive,
including but not limited to investments in derivatives, such as futures contracts, options
on futures contracts, securities and indices, forward contracts, swap agreements and similar
instruments. Such techniques may also include taking short positions or using other
techniques that are intended to provide inverse exposure to a particular market or other
asset class, as well as leverage, which can expose a client’s account to potentially dramatic
changes (losses or gains). These techniques may expose a client to potentially dramatic
changes (losses) in the value of its allocation to the manager and/or investment fund.
• Liquidity and Transferability–Certain investment funds – for example, private funds and
interval funds -- offer their investors only limited liquidity and interests are generally not
freely transferable. In addition to other liquidity restrictions, investments investment funds
may offer liquidity at infrequent times (i.e., monthly, quarterly, annually or less
frequently). Accordingly, investors in investment funds should understand that they may
not be able to liquidate their investment in the event of an emergency or for any other
reason.
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• Possibility of Fraud and Other Misconduct–When client assets are allocated to a manager
or investment funds, the Firm does not have custody of the assets. Therefore, there is the
risk that the manager or investment fund or its custodian could divert or abscond with those
assets, fail to follow agreed upon investment strategies, provide false reports of operations,
or engage in other misconduct. Moreover, there can be no assurances that all managers and
investment funds will be operated in accordance with all applicable laws and that assets
entrusted to the manager or investment funds will be protected.
• Counterparty Risk–The institutions (such as banks) and prime brokers with which a
manager or investment fund does business, or to which securities have been entrusted for
custodial purposes, could encounter financial difficulties. This could impair the operational
capabilities or the capital position of a manager or create unanticipated trading risks.
The summary above is qualified in its entirety by the risk factors set forth in the applicable offering
materials for the applicable product.
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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.
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October 8, 2025
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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 the Firm, the
principal voting owners, and each of their respective affiliates or parties in which the Firm 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 the Firm’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 the Firm, 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, the Firm 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 wealth
advisors 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
wealth advisors 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 controls Mariner Independent Advisor Network, LLC (CRD No.
283824) (“MIAN”), a 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), a 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), a 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), a SEC registered investment adviser.
The Firm is affiliated, and under common control, with Baystate Wealth Management (CRD No.
151664), a 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), a SEC registered investment adviser
• 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.
Relevant information, terms and conditions relative to the aforementioned affiliated private funds,
including the investment objectives and strategies, minimum 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, 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.
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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), an SEC registered investment adviser
• Lifeworks Advisors, LLC (CRD No. 288255), a SEC registered investment adviser
• Dynasty Wealth Management, LLC (CRD No. 153377), a 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 and control, 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. However, certain of our IARs are registered with other
unaffiliated broker dealers which causes a conflict of interest due to commissions received from
the financial products, such as 529 plans, variable annuities and direct mutual funds, by the IAR.
We are affiliated, and under common control, with W G Securities, LLC (CRD No. 140869) (“W
G”), a capital acquisition broker registered with the SEC and various state jurisdictions, member
of FINRA 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
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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.
Certain IARs are licensed insurance agents. With respect to the provision of financial planning
services, IARs may recommend insurance products offered by such carriers for whom they
function as an agent and receive a commission for doing so. Please be advised there is a potential
conflict of interest in that there is an economic incentive to recommend insurance and other
investment products of such carriers. Insurance products will only be recommended when the IAR
has a reasonable belief that the entry into the transaction is in the client’s best interests and is
consistent with the client’s stated investment objectives, tolerance for risk, liquidity, and
suitability. Clients may utilize any insurance carrier or insurance agency they desire. However, for
products requiring a securities and insurance license, such as variable insurance products, clients
may be limited to those insurance carriers that have a selling agreement with a broker- dealer in
which the advisor is associated. The Firm does not receive investment advisory compensation in
relation to these investments. See Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading for further details on addressing conflicts of interests in these
situations.
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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
Mariner Wealth.
Specialty Tax
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 advisor 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 MWA pursuant to a separate agreement between the
client and Vanilla.
Other Affiliates
We wholly own Honor Bound Partners, LLC (“HBP”) which wholly owns MIAN, 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 MIAN.
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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 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
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this may create. We also monitor outside business activities of our IARs to review situations that
would 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 advdelivery@mariner.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 investments. This also includes products and services
offered by other financial entities in which a principal voting owner of the Firm – Mariner, 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 a financial incentive as revenues earned by the
related person ultimately flow to the principal voting owners of the Firm. . 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.
• Supervised persons must comply with our policy on the handling and use of material inside
information. Supervised persons 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, supervised persons may not disclose
confidential information except to other supervised persons 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.
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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
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 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
Schwab, Fidelity or Pershing. 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 Schwab, Fidelity and/or Pershing as custodian/broker, you will decide whether to do so
and will open your account with Schwab, Fidelity and/or Pershing by entering into an account
agreement directly with them. We do not open the account for you, although we may assist you in
doing so. 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 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
Schwab, Fidelity and/or Pershing, we also manage accounts for clients custodied with other
qualified custodians.
We may establish additional accounts on behalf of clients with select qualified custodians. 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
• Competitiveness of the price of those services (commission rates, margin interest rates,
other fees, etc.) and willingness to negotiate the prices
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• 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 Schwab, Fidelity and/or Pershing maintain, 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 Schwab, Fidelity and Pershing applicable to our client
accounts were negotiated. We believe our commitment to Schwab, Fidelity and Pershing benefits
you because the overall commission rates you pay are lower than they would be otherwise. In
addition to commissions, 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 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, 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. For example, custodians
grandfathered reduced custody fees for certain clients assigned to the Firm as a result of
AdvicePeriod’s acquisition by the Firm’s parent company.
Products and services available to us from Schwab, Fidelity and Pershing
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:
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 Schwab, Fidelity and/or Pershing include some to which
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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. 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 Schwab, Fidelity or Pershing. In addition
to investment research, 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. 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
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 Schwab, Fidelity and Pershing
The availability of these services from Schwab, Fidelity and Pershing benefits us because we do
not have to produce or purchase them. For certain IARs transitioning to the Firm, Schwab and
Fidelity have also each agreed to pay certain costs our clients will incur in transitioning accounts
to 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 Schwab or Fidelity reaches a certain agreed upon threshold. These services
are not contingent upon us committing any specific amount of business to either Schwab or Fidelity
in trading commissions; however, the amount of the benefit is generally based on the amount of
assets expected to transition to Schwab or Fidelity. This creates an incentive for an IAR to
recommend that you maintain your account with 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
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custody services and the most favorable execution of your transactions. This is a potential conflict
of interest. We believe, however, that our selection of Schwab 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 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.
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
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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 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.
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Item 13-Review of Accounts
IARs of the Firm provide advisory clients with periodic reviews of relevant activity in their
accounts. IARs of the Firm may provide printed or electronic portfolio performance reports of the
client’s account which will include a review and evaluation of the client’s portfolio because of the
client’s investment goals and objectives. Some of the data provided in the performance reports
include, but is not limited to, account activity, asset allocation and portfolio holdings and a review
of account performance versus a benchmark. Clients are reminded to contact the Firm and/or their
IARs if there are any changes in the client’s financial situation or other information and will
disclose a method by which the client may make such contact. Periodically, IARs of the Firm will
deliver to each client electronically a request for current information about the client to determine
whether there have been any changes in the client’s financial situation, investment objectives, or
instructions. Each client agrees to inform the Firm and/or its IARs in writing of any material
change in the client’s financial circumstances which might affect the manner in which the client’s
assets should be invested. Those changes deemed material or appropriate will be forwarded to the
client’s IAR. In addition, the IARs responsible for making investment decisions for a client will
be reasonably available to the client for consultation. The Firm also encourages its IARs to review
each client’s portfolio performance reports at least annually with the client. IARs are trained to
inquire about the client’s risk tolerance, time horizon, life changing events, etc. to discover any
material changes of which the client and IAR might not have been aware. IARs will also discuss
other important investment subjects with the client, such as account performance, investment
limitations, and future financial planning.
See Item 15 for information on the frequency of client reports.
Mariner Platform Solutions, LLC-Form ADV Part 2A
October 8, 2025
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Item 14-Client Referrals and Other Compensation
We have entered into and are currently a party to referral agreements whereby we pay a referral
fee to Promoters/Introducers and/or receive payment for referring clients to another business or
related party, in accordance with the requirements of Rule 206(4)-1 of the Advisers Act and any
corresponding state securities law requirements. All such referral fees shall be paid solely from
our advisory fee. 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.
As previously described in Item 10, if we determine that it is appropriate based on the client’s
investment objectives and investor status, we will recommend that clients invest in a private fund
managed by an affiliate. These affiliated private funds charge fees in addition to and separate from
the fees charged by the Firm. Clients are advised that a conflict of interest exists to the extent we
recommend an investment in affiliated private funds.
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.
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October 8, 2025
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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.
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
Flourish
The Firm makes available to clients the cash management program offered by Flourish (“Flourish
Cash”). A Flourish Cash account is a brokerage account whereby the cash balance is swept from
the brokerage account to deposit accounts at one or more third-party banks that have agreed to
accept deposits from customers of Flourish Cash. Flourish Cash deposits are protected by FDIC
Coverage through a network of Program Banks. Flourish requires no minimum deposit to open an
account. The Firm earns fees if clients participate in this program, which reduces the net interest
earned by clients from Flourish by 20 basis points.
The Firm will participate in a revenue sharing program of Flourish. Flourish shall pay to the Firm
8 basis points of revenue earned by Flourish on all cash at Flourish associated wit the Firm. This
relationship with Flourish creates a conflict of interest. This arrangement creates a conflict of
interest because the Firm has an incentive to direct client accounts to Flourish in consideration of
the incentives or consideration the Firm will receive.
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
Mariner Platform Solutions, LLC-Form ADV Part 2A
October 8, 2025
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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.
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.
Mariner Platform Solutions, LLC-Form ADV Part 2A
October 8, 2025
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Item 15-Custody
Situations where the Firm is deemed to have custody of client assets include IARs or affiliates
serving as trustee or co-trustee of client accounts, where the Firm operates under a standing letter
of authorization or instructs custodians on a client’s instruction to move assets to third parties, or
where the Firm or its IARs otherwise may have access to client assets. In such cases, we undergo
an annual surprise examination of client assets by an independent auditor.
We have the authority to debit our clients’ custodial accounts for advisory fees. We are deemed to
have custody of those assets if, for example, we are authorized to instruct a client’s custodian to
deduct our advisory fees directly from the account or if we are granted authority to move money
from a client’s account to another person’s account. At all times, the custodial bank maintains
actual custody of those assets.
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.
Clients should receive at least quarterly statements from the broker dealer, bank or other qualified
custodian that holds and maintains client’s investment assets. We urge clients to carefully review
such statements and compare such official custodial records to the reports that we provide to clients
and to promptly report material discrepancies to us. To the extent requested by our clients, our
reports can vary from custodial statements based on accounting procedures, reporting dates, or
valuation methodologies of certain securities.
Mariner Platform Solutions, LLC-Form ADV Part 2A
October 8, 2025
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Item 16-Investment Discretion
Discretionary Authority
We typically receive discretionary authority from the client at the outset of an advisory relationship
to select the identity and amount of securities to be bought or sold. In all cases, however, such
discretion is to be exercised in a manner consistent with the stated investment objectives for the
particular client account. Generally, there are no limitations on the securities we will purchase or
sell, the amount of the securities we will purchase or sell, the broker or dealer we will use to
execute a transaction and commission rates paid.
Clients may impose reasonable restrictions, limitations or other requirements with respect to their
individual accounts. Any limitations on our discretionary authority to manage securities accounts
on behalf of clients would be initiated and imposed by the client. Examples of common guideline
restrictions include limitations prohibiting the purchase or sale of a particular security or type of
security. Specific client investment restrictions may limit our ability to manage those assets like
other similarly managed portfolios. This may impact the performance of the account relative to
other accounts and the benchmark index. These clients are informed that their restrictions may
impact performance.
Employer sponsored retirement clients can determine to engage the Firm to provide investment
management services on a discretionary basis as provided for in Section 3(38) of ERISA. Prior to
the Firm assuming discretionary authority over the management of a Plan’s assets, the client shall
be required to execute an Agreement setting forth the scope of the services to be provided.
Non-Discretionary Authority
To the extent the Firm manages a client’s account on a non-discretionary basis, the Firm will make
investment recommendations to the client as to which securities are to be purchased or sold, and
the amounts to be purchased or sold. Upon approving the recommended transactions, the client
may request that the Firm direct the execution of purchase or sale orders to implement the
recommended transactions for the client's account. The Firm then may be given authority to
determine the brokers or dealers through which the transactions will be executed, and the
commission rates, if any, paid to effect the transactions. As described above with respect to
discretionary accounts, the client may direct that transactions be effected with specific brokers or
dealers.
Employer sponsored retirement plan clients can determine to engage the Firm to provide
investment advisory services on a non-discretionary basis as provided for in Section 3(21) of
ERISA. Prior to the Firm assuming non-discretionary authority over the management of a Plan’s
assets, the client shall be required to execute an Agreement setting forth the scope of the services
to be provided.
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Consulting Services
If so elected in your Agreement, we will provide recommendations related to the assets that you
designate for consulting services but will not be responsible for the execution of the
recommendations unless you have directed us to do so. We will periodically monitor and review
these accounts, but we will not be responsible for the continuous and regular supervision or
management of accounts categorized as consulting services.
Reporting Services
We also provide reporting services related to the assets that you designate in your Agreement. We
do not manage or provide investment recommendations and are not responsible for the investments
in accounts categorized as reporting only assets.
Mariner Platform Solutions, LLC-Form ADV Part 2A
October 8, 2025
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Item 17-Voting Client Securities
Clients shall be responsible for directing the manner in which proxies solicited by issuers of
securities beneficially owned by clients shall be voted. However, if a client’s account(s) is
managed by an investment manager, client may authorize the investment manager to vote proxies
for securities held in client’s account(s) by completing the proper authorization documents,
including those required by the Custodian. Clients acknowledge that the investment manager may
engage a service provider to assist with administrative functions related to voting client proxies.
Mariner Platform Solutions, LLC-Form ADV Part 2A
October 8, 2025
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Item 18-Financial Information
Registered investment advisers are required in this Item to provide you with certain financial
information or disclosures about our financial condition. We have no financial commitment that
impairs our ability to meet contractual and fiduciary commitments to clients and have not been the
subject of a bankruptcy proceeding.
Mariner Platform Solutions, LLC-Form ADV Part 2A
October 8, 2025
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MARINER PLATFORM SOLUTIONS, LLC
PRIVACY POLICY NOTICE
Our Commitment to your Privacy
As a client or prospective client of Mariner Platform Solutions, 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.