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Marion Wealth Management, LLC
d/b/a Marion Wealth Management
2790 Mosside Boulevard, Suite 640
Monroeville, PA 15146
Telephone: 412-372-3849
https://www.marionwmg.com/
FORM ADV PART 2A
BROCHURE
April 25, 2025
Item 1 Cover Page
This brochure provides information about the qualifications and business practices of Marion Wealth
Management. If you have any questions about the contents of this brochure, contact us at 412-372-3849. The
information in this brochure has not been approved or verified by the United States Securities and Exchange
Commission or by any state securities authority.
Additional information about Marion Wealth Management is available on the SEC's website at
www.adviserinfo.sec.gov.
Marion Wealth Management is a registered investment adviser. Registration with the United States Securities
and Exchange Commission or any state securities authority does not imply a certain level of skill or training.
Item 2 Summary of Material Changes
Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially
inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and
provide you with a description of the material changes.
Since our last annual update filed on February 15, 2024, we have the following material changes to report:
•
•
Item 4: We have adjusted our ownership structure such that Jeffrey Lott is now considered a control person.
Item 5: We have updated the range of our fixed fees for financial planning.
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Item 3 Table of Contents
Item 1 Cover Page..................................................................................................................................................... 1
Item 2 Summary of Material Changes ...................................................................................................................... 2
Item 3 Table of Contents .......................................................................................................................................... 3
Item 4 Advisory Business .......................................................................................................................................... 4
Item 5 Fees and Compensation ................................................................................................................................ 8
Item 6 Performance-Based Fees and Side-By-Side Management .......................................................................... 10
Item 7 Types of Clients ........................................................................................................................................... 10
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss .................................................................... 10
Item 9 Disciplinary Information .............................................................................................................................. 16
Item 10 Other Financial Industry Activities and Affiliations ................................................................................... 17
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading............................. 17
Item 12 Brokerage Practices ................................................................................................................................... 17
Item 13 Review of Accounts ................................................................................................................................... 19
Item 14 Client Referrals and Other Compensation ................................................................................................ 19
Item 15 Custody...................................................................................................................................................... 20
Item 16 Investment Discretion ............................................................................................................................... 20
Item 17 Voting Client Securities ............................................................................................................................. 20
Item 18 Financial Information ................................................................................................................................ 20
Item 19 Requirements for State-Registered Advisers ............................................................................................ 21
Additional Information ........................................................................................................................................... 21
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Item 4 Advisory Business
Description of Firm
Marion Wealth Management, LLC, d/b/a Marion Wealth Management is a registered investment adviser primarily based in
Monroeville, PA. We are organized as a limited liability company ("LLC") under the laws of the State of PA. We are
primarily owned by Michael S. Marion and Jeffrey D. Lott.
The following paragraphs describe our services and fees. Refer to the description of each investment advisory service listed
below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words
"we," "our," and "us" refer to Marion Wealth Management and the words "you," "your," and "client" refer to you as either
a client or prospective client of our firm.
Portfolio Management Services
We offer discretionary portfolio management services. Our investment advice is tailored to meet our clients' needs and
investment objectives.
If you participate in our discretionary portfolio management services, we require you to grant us discretionary authority to
manage your account. Subject to a grant of discretionary authorization, we have the authority and responsibility to
formulate investment strategies on your behalf. Discretionary authorization will allow us to determine the specific
securities, and the amount of securities, to be purchased or sold for your account without obtaining your approval prior to
each transaction. We will also have discretion over the broker or dealer to be used for securities transactions in your
account. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power
of attorney, or trading authorization forms.
You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for
your account) by providing our firm with your restrictions and guidelines in writing.
As part of our portfolio management services, in addition to other types of investments (see disclosures below in this
section), we may invest your assets according to one or more model portfolios developed by our firm. These models are
designed for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to a more
conservative investment approach. Clients whose assets are invested in model portfolios may set restrictions on the
specific holdings or allocations within the model, such as the types of securities that can be purchased in the model by
providing us written notice related to these restrictions.
Pontera
We provide an additional service for accounts not directly held in our custody, where we may or may not have discretion,
and may leverage an Order Management System (Pontera) to implement asset allocation and opportunistic rebalancing
strategies on behalf of the client. These are primarily 401(k) accounts, HSA’s, and other assets we do not custody. We
regularly review the available investment options in these accounts, monitor them, and rebalance and implement our
strategies using different tools as necessary
If you elect to participate in this program, you will be notified via email when the Firm places trades through Pontera
implementing any and all changes to your account. The fees charged in these situations are the same as described in the
table below under “Fees and Compensation.” Fees are paid separately on the management of these “held away” assets
and clients may be provided an invoice describing the fees. Suitability documentation will be held with the Plan Custodian
and cannot be changed by the Firm.
a) Responsibilities of Marion Wealth Management. It is the responsibility of the Firm to establish and maintain
strategic direction of investment management and investment policy statement and to provide oversight for the
Sub-Advisors.
b) Responsibilities of Sub-advisors (Pontera). It is the responsibility of the subadvisor to implement the investment
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models appropriate for the investment policy statement. Sub-advisors are responsible for the day-to-day trading
activity in the accounts as well as monitoring the portfolios alignment to the investment policy statement. Sub-
advisors may also facilitate billing of investment accounts for investment advisory fees. Sub-advisors will typically
have clerical responsibility for account billing and will therefore have the Client accounts charged the
corresponding fees. Subadvisors then, retain the sub-advisor fee and distribute the Marion Wealth Management
Advisory fee to the firm.
a. Pontera – A clerical service that facilitates communications of orders from the Firm to held away
accounts i.e., employer sponsored retirement plans like 401(k)’s. Pontera enables Marion Wealth
Management to make strategic and tactical changes in investment accounts not held at the Firm’s
custodian. Pontera does not handle billing of accounts and fees must be paid through separate billing
process.
529 Plans, HSA Plans, Annuities, Life Insurance and Others
Marion Wealth Management offers non-discretionary investment management services to advisory clients for specific 529
Plans. Marion Wealth Management will review and analyze 529 Plan portfolios and/or investment options then select the
option determined by the accounts written investment policy. 529 Plans are established and administered by individual
States, the State Administrator appoints a program manager to provide products and investment options. The Plan’s
investment advisor (i.e., portfolio manager) appointed by the administrator (i.e., the State) is responsible for providing the
investment options and/or managing the portfolios directing the sale of the underlying funds in which they invest. Some
plan portfolios rebalance at the instruction of the program manager, not Marion Wealth Management, in an effort to
maintain the portfolio's target asset allocation, described in Plan Guides.
You may work with our advisers in their separate capacity as insurance agents. When acting in this separate capacity as an
insurance agent, employees or supervised persons of Marion Wealth Management may recommend fixed or indexed
insurance products. We may recommend these products as part of an income and retirement planning strategy when it is
in the best interest of the client to do so. Clients will also have the option to purchase these products from another
insurance agent of their choosing. Please see Item 10 ‘Other Financial Industry Activities and Affiliations’ for more
information on commission-based compensation.
Additionally, we may advise you on various other types of accounts based on your stated goals and objectives. When we
provide this advice, we may bill on those other accounts from time to time.
Financial Planning Services
As part of our overall engagement which includes portfolio management, we offer financial planning services which typically
involve providing a variety of advisory services to clients regarding the management of their financial resources based
upon an analysis of their individual needs. These services can range from broad-based financial planning to consultative or
single subject planning. If you retain our firm for financial planning services, we will consult with you to gather information
about your financial circumstances and objectives. We may also use financial planning software to determine your current
financial position, and to define and quantify your long-term goals and objectives. Once we specify those long-term
objectives (both financial and non-financial), we may develop shorter-term, targeted objectives. Once we review and
analyze the information you provide to our firm and the data derived from our financial planning software, we may deliver
a written plan to you, designed to help you achieve your stated financial goals and objectives.
Financial plans are based on your financial situation at the time we present the plan to you, and on the financial
information you provide to us. You must promptly notify our firm if your financial situation, goals, objectives, or needs
change.
Selection of Other Advisors
As part of our overall portfolio management strategy, we may recommend Sub-Advisors to manage all or a portion of your
account where the allocation meets the needs and investment objectives of clients. To the extent possible, MWM seeks to
assess the Sub-Advisors investment strategies, past performance, and risk results in relation to its clients’ individual
portfolio allocations and risk exposure. MWM also takes into consideration each Sub-Advisor’s management style, returns,
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reputation, financial strength, reporting, pricing, and research capabilities, among other factors.
On an ongoing basis, MWM monitors the performance of those accounts being managed by Sub-Advisors. MWM seeks to
ensure the Sub-Advisors strategies and target allocations remain aligned with clients’ investment objectives and overall
best interests. MWM will be responsible for the overall direct relationship with the Client and retains the authority to
terminate the Sub-Advisors relationship at MWM’s discretion.
Donor Advised Fund Services
For those clients with objectives focused on charitable giving, we may recommend establishing donor advised funds
through various third-party charitable programs. These funds will be managed in accordance with the specific investment
policies and guidelines of the applicable Charitable Platform. Clients will establish a donor advised account, transfer funds
earmarked for charitable donation and recognize a tax deduction in the year that funds are transferred into an account
opened on a Charitable Platform. The funds remain in such an account until the Client designates a charity, an amount, and
a date to donate to such charity. Under independent advisor programs established within each Charitable Platform, donors
nominate an independent investment adviser, including MWM, to manage accounts established on the Charitable
Platforms. If nominated, MWM will manage the donor's account pursuant to investment guidelines established by each
Charitable Platform.
Pension Consulting Services
We offer pension consulting services to employee benefit plans and their fiduciaries based upon the needs of the plan and
the services requested by the plan sponsor or named fiduciary. In general, these services may include an existing plan
review and analysis, plan-level advice regarding fund selection and investment options, education services to plan
participants, investment performance monitoring, and/or ongoing consulting. Our services are described in more detail
below:
Assessment and/or Monitoring of Investments: Your IAR will meet with you to gather information regarding the
Plan’s specific investment policies and specific objectives and assist in the development of a written Investment Policy
Statement (“IPS”) that is designed to meet the individualized needs of the Plan, the Participants, and the covered
employee workforce. An IAR will regularly meet with you, to deliver recommendations regarding the Plan Participant’s
contributions and allocations among investment options available within the Plan based upon the Plan Participant’s
stated financial circumstances, investment objectives and risk tolerance.
Selection of Investments: We will conduct an initial assessment of investment options for the Plan, including Qualified
Default Investment Alternatives and make recommendations when deemed appropriate by IAR on the investment
options available to Plan participants (which decision shall remain the sole and exclusive decision of the Client and/or
their delegate); advise the Client on the nature and composition of each investment option including its performance,
risk, investment style, and management so that the Client can satisfy itself that the investment options constitute a
“broad range of investment alternatives” within the meaning of Section 404(c) of ERISA.
Third Party Service Provider Liaison: IAR will act as liaison for the Plan and the Client on an as needed basis, when
dealing with the trustee, custodian, plan actuary and other third-party service providers as directed by client.
Vendor Review/Conversion: IAR will meet with the Client to assist with assessing current vendors identified and
selected by Client. IAR may also assist in the preparation of Request for Proposals (“RFPs”) from prospective new
vendors and may assist the Client in reviewing and comparing responses to RFPs. IAR may offer suggestions for
vendors who will provide fiduciary services under ERISA, including investment advice.
These pension consulting services will generally be non-discretionary and advisory in nature. The ultimate decision to act
on behalf of the plan shall remain with the plan sponsor or other named fiduciary.
We may also assist with participant enrollment meetings and provide investment-related educational seminars to plan
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participants on such topics as:
• Diversification
• Asset allocation
• Risk tolerance
• Time horizon
Our educational seminars may include other investment-related topics specific to the particular plan.
We may also provide additional types of pension consulting services to plans on an individually negotiated basis. All
services, whether discussed above or customized for the plan based upon requirements from the plan fiduciaries (which
may include additional plan-level or participant-level services) shall be detailed in a written agreement and will be
consistent with the parameters set forth in the plan documents.
We acknowledge our status as a fiduciary under ERISA solely with respect to the Services above that are deemed to be
fiduciary activities under ERISA. IAR’s fiduciary status is limited to the rendering of investment advice as defined in ERISA
Section 3(21)(A)(ii). IAR will not have or exercise any discretionary authority over the administration of the Plan. IAR is not
the “administrator” of the Plan (as defined in ERISA Section 3(16)(A)) and has no power to make decisions as to plan policy,
interpretations, practices, or procedures with respect to the Plan. Either party to the pension consulting agreement may
terminate the agreement upon written notice to the other party in accordance with the terms of the agreement for
services. The pension consulting fees will be prorated for the quarter in which the termination notice is given, and any
unearned fees will be refunded to the client.
Types of Investments
We offer advice on equity securities, corporate debt securities (other than commercial paper), certificates of deposit,
municipal securities, mutual fund shares, United States government securities, options contracts on securities, selection of
other advisers, money market funds, alternative investments, real estate, separately managed accounts (SMAs), REITs,
derivatives, structured products, and ETFs.
While Marion Wealth Management does not directly offer variable insurance or variable annuity products for sale to
clients, we may recommend an outside insurance company that offers these products directly to consumers. We do not
receive any commissions from our client’s purchases of variable annuity and variable insurance products. Our fees are
limited to the management fee for the insurance policies’ separate accounts.
Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also
provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
Since our investment strategies and advice are based on each client’s specific financial situation, the investment advice we
provide to you may be different or conflict with the advice we give to other clients regarding the same security or
investment.
Assets Under Management
As of December 31, 2024, our Firm had client assets under management of $454,507,917 on a discretionary basis,
$28,004,484 on a non-discretionary basis, and assets under advisement of $21,346,040.
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Item 5 Fees and Compensation
Portfolio Management Services
Our annual fee for portfolio management services varies but can be up to 1.75% depending upon the market value of your
assets under our management, the type and complexity of the asset management services provided, as well as the level of
administration requested either directly or assumed by the client. Assets in each of your accounts are included in the fee
assessment unless specifically identified in writing for exclusion. Our minimum fee is $350 a month and includes our
standard financial planning services with our portfolio management services as explained above. The standard assets
under our management fee are included in the minimum fee calculation. As a result of the minimum fee, clients who
benefit from our fee structure tend to be people with higher net worth. Fees may be negotiable, and we reserve the right
to decline situations that are not considered complicated enough to warrant our minimum fee.
Our annual portfolio management fee is billed and payable, monthly in advance, based on the balance at the end of the
prior month’s billing period. On a case-by-case basis we may elect to bill a client quarterly.
If the portfolio management agreement is executed at any time other than the first day of a calendar month, 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
month for which you are a client. Our advisory fee is negotiable, depending on individual client circumstances.
At our discretion, we may combine the account values of family members living in the same household to determine the
applicable advisory fee. For example, we may combine account values for you and your minor children, joint accounts with
your spouse, and other types of related accounts. Combining account values may increase the asset total, which may result
in your paying a reduced advisory fee based on the available breakpoints in our fee schedule stated above.
Generally, we will deduct our advisory fee directly from your account through the qualified custodian holding your funds
and securities. However, on a case-by-case basis we may allow clients to directly pay the advisory fee. We will deduct our
advisory fee only when you have given our firm written authorization permitting the fees to be paid directly from your
account. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account
statements will show all disbursements from your account. You should review all statements for accuracy.
You may terminate the portfolio management agreement via a written notice to our firm. These services will continue and
shall remain in full force and effect and be relied upon until terminated in writing and until MWM has actually received a
copy of such written termination with 30 days written notice. You will incur a pro rata charge for services rendered prior to
the termination of the portfolio management agreement, which means you will incur advisory fees only in proportion to
the number of days in the month during which you are a client. If you have pre-paid advisory fees that we have not yet
earned, you will receive a prorated refund of those fees.
Pontera
In special cases, we may employ Pontera, Inc. (a third-party service provider) to facilitate ongoing advice and management
of employer retirement accounts (e.g. 401(k), 403(b) etc.). Should we employ Pontera, additional documentation and
detailed discussion will be provided to client(s).
Pontera, Inc. does not have trading authority on the held-away account and will be paid by Marion Wealth Management
directly. Pontera does not bill nor invoice Marion Wealth Management clients. Marion Wealth Management bills Marion
Wealth Management clients directly. Pontera only communicates trading actions when directed by the Firm to Pontera. In
order to facilitate order communications, Pontera will apply the percentage allocation that was submitted by the advisor to
the balances in the account at the time Pontera communicates the order. Pontera may round partial percentages into
whole percentages when required by the financial institution.
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Financial Planning Services
Generally, financial planning services are provided as part of a comprehensive service that includes investment and
portfolio management where clients pay a fee as a percentage of assets under management. MWM may offer one-time or
ongoing financial-planning engagements. Planning components may include retirement planning, tax planning, estate
planning, insurance planning, real estate analysis, and education-funding analysis. MWM’s financial planning services are
offered on a monthly fixed fee basis. Fees vary based upon the level and scope of the services required and the complexity
of the matter but will generally range from $6,000 to $12,000 per engagement.
Prior to engaging MWM to provide planning or consulting services, clients are required to enter into a written agreement,
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 MWM commencing services. Generally, fifty
percent of the Financial Planning Services fee is due upon inception of the advisory relationship, with the balance payable
upon completion of the financial planning service.
MWM may recommend the services of other professionals for implementation purposes. The client is under no obligation
to engage the services of any such recommended professional. The client retains absolute discretion over all such
implementation decisions and is free to accept or reject any recommendation from MWM.
Pension Consulting Services
Our advisory fees for these customized services will be negotiated with the plan sponsor or named fiduciary on a case-by-
case basis.
You may terminate the pension consulting agreement via a written notice to our firm. These services will continue and
shall remain in full force and effect and be relied upon until terminated in writing and until MWM has actually received a
copy of such written termination with 30 days written notice. You will incur a pro rata charge for services rendered prior to
the termination of the agreement, which means you will incur advisory fees only in proportion to the number of days in
the quarter for which you are a client. If you have pre-paid advisory fees that we have not yet earned, you will receive a
prorated refund of those fees.
Subadvisors
For Clients referred by MWM to a Sub-Adviser, MWM will collect the investment advisory fee and provide a portion of the
fee to the Sub-Adviser.
Additional Fees and Expenses
As part of our investment advisory services to you, we may invest, or recommend that you invest, in mutual funds and
exchange traded funds. The fees that you pay to our firm for investment advisory services are separate and distinct from
the fees and expenses charged by mutual funds or exchange traded funds (described in each fund's prospectus) to their
shareholders. These fees will generally include a management fee and other fund expenses. You will also incur transaction
charges and/or brokerage fees when purchasing or selling securities. These charges and fees are typically imposed by the
broker-dealer or custodian through whom your account transactions are executed. We do not share in any portion of the
brokerage fees/transaction charges imposed by the broker-dealer or custodian. To fully understand the total cost you will
incur, you should review all the fees charged by mutual funds, exchange traded funds, our firm, and others. For
information on our brokerage practices, refer to the Brokerage Practices section of this brochure.
Compensation for the Sale of Securities or Other Investment Products
Persons providing investment advice on behalf of our firm are also licensed as independent insurance agents. These
persons will earn commission-based compensation for selling insurance products, including insurance products they sell to
you. Insurance commissions earned by these persons are separate and in addition to our advisory fees. This practice
presents a conflict of interest because persons providing investment advice on behalf of our firm, who are insurance
agents, have an incentive to recommend insurance products to you for the purpose of generating commissions rather than
solely based on your needs. You are under no obligation, contractually or otherwise, to purchase insurance products
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through any person affiliated with our firm
Item 6 Performance-Based Fees and Side-By-Side Management
We do not accept performance-based fees or participate in side-by-side management. Performance-based fees are fees
that are based on a share of capital gains or capital appreciation of a client's account. Side-by-side management refers to
the practice of managing accounts that are charged performance-based fees, while at the same time managing accounts
that are not charged performance-based fees. Our fees are calculated as described in the Fees and Compensation section
above and are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in your
advisory account.
Item 7 Types of Clients
We offer investment advisory services to individuals (other than high net worth individuals), high net worth individuals,
pension, and profit-sharing plans (but not the plan participants), charitable organizations and corporations or other
businesses not listed above.
In general, we require a minimum asset level of $750,000 to establish an investment advisory relationship. This minimum
account size may be waived when, for example, a pre-existing family relationship exists with a current client of MWM, or
for other reasons, at the discretion of MWM. As explained above, our minimum fee is $350 a month and is based on the
scope and complexity of the engagement. As a result of the minimum fee, clients who benefit from our fee structure will
be clients with a higher net worth where the standard assets under management fee meets the monthly minimum fee
requirement. Fees may be negotiable, and we reserve the right to decline situations that are not considered complicated
enough to warrant our minimum fee.
We may also combine account values for you and your minor children, joint accounts with your spouse, and other types of
related accounts to meet the stated minimum.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Our Methods of Analysis and Investment Strategies
We may use one or more of the following methods of analysis or investment strategies when providing investment advice
to you:
Technical Analysis - involves studying past price patterns, trends, and interrelationships in the financial markets to assess
risk-adjusted performance and predict the direction of both the overall market and specific securities.
Risk: The risk of market timing based on technical analysis is that our analysis may not accurately detect anomalies or
predict future price movements. Current prices of securities may reflect all information known about the security and day-
to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable
degree of accuracy.
Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial
statements, details regarding the company's product line, the experience and expertise of the company's management,
and the outlook for the company and its industry. The resulting data is used to measure the true value of the company's
stock compared to the current market value.
Risk: The risk of fundamental analysis is that information obtained may be incorrect and the analysis may not provide an
accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new
information, utilizing fundamental analysis may not result in favorable performance.
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Modern Portfolio Theory - a theory of investment which attempts to maximize portfolio expected return for a given
amount of portfolio risk, or equivalently minimize risk for a given level of expected return, by carefully diversifying the
proportions of various assets.
Risk: Market risk is that part of a security's risk that is common to all securities of the same general class (stocks and bonds)
and thus cannot be eliminated by diversification.
Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a
relatively long period of time, generally greater than one year.
Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term which may
not be the case. There is also the risk that the segment of the market that you are invested in or perhaps just your
particular investment will go down over time even if the overall financial markets advance. Purchasing investments long-
term may create an opportunity cost - "locking-up" assets that may be better utilized in the short-term in other
investments.
Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period of
time, generally less than one year, to take advantage of the securities' short-term price fluctuations.
Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the
short-term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to
long-term trading. There are many factors that can affect financial market performance in the short term (such as short-
term interest rate changes, cyclical earnings announcements, etc.) but may have a smaller impact over longer periods of
times.
Margin Transactions - a securities transaction in which an investor borrows money to purchase a security, in which case
the security serves as collateral on the loan. Marion Wealth Management does not typically recommend strategies that use
margin, however depending on the clients relationship with their custodian, margin can be used at the clients request.
Risk: If the value of the shares drops sufficiently, the investor will be required to either deposit more cash into the account
or sell a portion of the stock in order to maintain the margin requirements of the account. This is known as a "margin call."
An investor's overall risk includes the amount of money invested plus the amount that was loaned to them.
Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the
right, but not the obligation, to buy or sell a particular security at a specified price on or before the expiration date of the
option. When an investor sells a call option, he or she must deliver to the buyer a specified number of shares if the buyer
exercises the option. When an investor sells a put option, he or she must pay the strike price per share if the buyer
exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the
market price of the option at a particular time) in exchange for writing the option.
Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock.
In certain situations, an investor's risk can be unlimited.
Our investment strategies and advice may vary depending upon each client's specific financial situation. As such, we
determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial
information, liquidity needs and other various suitability factors. Your restrictions and guidelines may affect the
composition of your portfolio. It is important that you notify us immediately with respect to any material changes to
your financial circumstances, including for example, a change in your current or expected income level, tax
circumstances, or employment status.
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Cash Management
We manage cash balances in your account based on the yield, and the financial soundness of the money markets and other
short-term instruments.
Tax Considerations
Our strategies and investments may have unique and significant tax implications. However, unless we specifically agree
otherwise, and in writing, tax efficiency is not our primary consideration in the management of your assets. Regardless of
your account size or any other factors, we strongly recommend that you consult with a tax professional regarding the
investing of your assets.
Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Your custodian will
default to the First-In First-Out ("FIFO") accounting method for calculating the cost basis of your investments. You are
responsible for contacting your tax advisor to determine if this accounting method is the right choice for you. If your tax
advisor believes another accounting method is more advantageous, provide written notice to our firm immediately and we
will alert your account custodian of your individually selected accounting method. Decisions about cost basis accounting
methods will need to be made before trades settle, as the cost basis method cannot be changed after settlement.
Risk of Loss
Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our
services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate
clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial
goals and objectives will be met. Past performance is in no way an indication of future performance.
Other Risk Considerations
When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each
of which may affect the probability and magnitude of any potential losses. The following risks may not be all-inclusive but
should be considered carefully by a prospective client before retaining our services.
Liquidity Risk: The risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of
active liquid markets. You may receive a lower price, or it may not be possible to sell the investment at all.
Credit Risk: Credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or
bonds. A bond issuing entity can experience a credit event that could impair or erase the value of an issuer’s securities held
by a client.
Inflation and Interest Rate Risk: Security prices and portfolio returns will likely 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 fixed income investments to decline.
Horizon and Longevity Risk: The risk that your investment horizon is shortened because of an unforeseen event, for
example, the loss of your job. This may force you to sell investments that you were expecting to hold for the long term. If
you must sell at a time that the markets are down, you may lose money. Longevity Risk is the risk of outliving your savings.
This risk is particularly relevant for people who are retired or are nearing retirement.
Recommendation of Particular Types of Securities
We recommend various types of securities, and we do not primarily recommend one particular type of security over
another since each client has different needs and different tolerance for risk. Each type of security has its own unique set
of risks associated with it, and it would not be possible to list here all the specific risks of every type of investment. Even
within the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated
return of an investment, the higher the risk of loss associated with the investment. A description of the types of securities
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we may recommend to you and some of their inherent risks are provided below.
Money Market Funds: A money market fund is technically a security. The fund managers attempt to keep the share price
constant at $1/share. However, there is no guarantee that the share price will stay at $1/share. If the share price goes
down, you can lose some or all of your principal. The U.S. Securities and Exchange Commission ("SEC") notes that "While
investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater
return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account
(money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know
how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a
positive outcome. However, if it goes down, and you earn less than you expected to earn, you may end up needing more
cash. A final risk you are taking with money market funds has to do with inflation. Because money market funds are
considered to be safer than other investments like stocks, long term average returns on money market funds tend to be
less than long term average returns on riskier investments. Over long periods of time, inflation can eat away at your
returns.
Certificates of Deposit: Certificates of Deposit (“CD”) are generally a safe type of investment since they are insured by the
Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low,
there is risk that inflation outpaces the return of the CD. Certain CDs are traded in the marketplace and not purchased
directly from a banking institution. In addition to trading risk, when CDs are purchased at a premium, the premium is not
covered by the FDIC.
Municipal Securities: Municipal securities, while generally thought of as safe, can have significant risks associated with
them including, but not limited to: the credit worthiness of the governmental entity that issues the bond; the stability of
the revenue stream that is used to pay the interest to the bondholders; when the bond is due to mature; and, whether or
not the bond can be "called" prior to maturity. When a bond is called, it may not be possible to replace it with a bond of
equal character paying the same amount of interest or yield to maturity.
Bonds: Corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also
vary widely based on the financial health of the issuer; the risk that the issuer might default; when the bond is set to
mature; and, whether or not the bond can be "called" prior to maturity. When a bond is called, it may not be possible to
replace it with a bond of equal character paying the same rate of return.
Stocks: There are numerous ways of measuring the risk of equity securities (also known simply as "equities" or "stock"). In
very broad terms, the value of a stock depends on the financial health of the company issuing it. However, stock prices can
be affected by many other factors including, but not limited to the class of stock (for example, preferred or common); the
health of the market sector of the issuing company; and the overall health of the economy. In general, larger, better-
established companies ("large cap") tend to be safer than smaller start-up companies ("small cap") are but the mere size of
an issuer is not, by itself, an indicator of the safety of the investment.
Mutual Funds and Exchange Traded Funds: Mutual Funds and Exchange Traded Funds ("ETF") are professionally managed
collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market
instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades
the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide
diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily
invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates
in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ
from mutual funds since they can be bought and sold throughout the day like stock and their price can fluctuate
throughout the day. The returns on mutual funds and ETFs can be reduced by the costs of managing the funds. Also, while
some mutual funds are "no load" and charge no fee to buy into, or sell out of, the fund, other types of mutual funds do
charge such fees which can also reduce returns. Mutual funds can also be "closed end" or "open end". So-called "open
end" mutual funds continue to allow in new investors indefinitely, whereas "closed end" funds have a fixed number of
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shares to sell which can limit their availability to new investors.
ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF’s
performance to match that of its Underlying Index or other benchmark, which may negatively affect the ETF's
performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or
benchmarks on a daily basis, mathematical compounding may prevent the ETF from correlating with performance of its
benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index,
or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may
invest in securities or financial instruments that are not included in the Underlying Index, but which are expected to yield
similar performance.
Variable Annuities: A variable annuity is a form of insurance where the seller or issuer (typically an insurance company)
makes a series of future payments to a buyer (annuitant) in exchange for the immediate payment of a lump sum (single-
payment annuity) or a series of regular payments (regular-payment annuity). The payment stream from the issuer to the
annuitant has an unknown duration based principally upon the date of death of the annuitant. At this point, the contract
will terminate, and the remainder of the funds accumulated will be forfeited unless there are other annuitants or
beneficiaries in the contract. Annuities can be purchased to provide an income during retirement. Unlike fixed annuities
that make payments in fixed amounts or in amounts that increase by a fixed percentage, variable annuities pay amounts
that vary according to the performance of a specified set of investments, typically bond and equity mutual funds. Many
variable annuities typically impose asset-based sales charges or surrender charges for withdrawals within a specified
period. Variable annuities may impose a variety of fees and expenses, in addition to sales and surrender charges, such as
mortality and expense risk charges; administrative fees; underlying fund expenses; and charges for special features, all of
which can reduce the return. Earnings in a variable annuity do not provide all the tax advantages of 401(k)s and other
before-tax retirement plans. Once the investor starts withdrawing money from their variable annuity, earnings are taxed at
the ordinary income rate, rather than at the lower capital gains rates applied to other non-tax-deferred vehicles which are
held for more than one year. Proceeds of most variable annuities do not receive a "step-up" in cost basis when the owner
dies like stocks, bonds and mutual funds do. Some variable annuities offer "bonus credits." These are usually not free. In
order to fund them, insurance companies typically impose mortality and expense charges and surrender charge periods. In
an exchange of an existing annuity for a new annuity (so-called 1035 exchanges), the new variable annuity may have a
lower contract value and a smaller death benefit; may impose new surrender charges or increase the period of time for
which the surrender charge applies; may have higher annual fees; and provide another commission for the broker.
Real Estate: Real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency
and increasing concerns about the future long-term variability of stock and bond returns. In fact, real estate is known for
its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount
of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall
economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates
and the credit markets, which affect the demand and supply of capital and thus real estate values. Along with changes in
market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for
property concentrations by area or by property type. Because property returns are directly affected by local market basics,
real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes
and bear additional risk by being too influenced by local or sector market changes.
Real Estate Investment Trust: A Real Estate Investment Trust ("REIT") is a corporate entity which invests in real estate
and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or
privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable
income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong or the
REIT must either dip into reserves, borrow to pay dividends, or distribute them in stock (which causes dilution). After 2012,
the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit
markets are no longer frozen, but banks are demanding, and getting, harsher terms to re-extend REIT debt. Some REITs
may be forced to make secondary stock offerings to repay debt, which will lead to additional dilution of the stockholders.
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Fluctuations in the real estate market can affect the REIT's value and dividends.
Options Contracts: Options are complex securities that involve risks and are not suitable for everyone. Option trading can
be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with
risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset
at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts:
A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having
a long position on a stock. Buyers of calls hope that the stock will increase substantially before the option expires.
A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to
having a short position on a stock. Buyers of puts hope that the price of the stock will fall before the option expires.
Selling options is more complicated and can be even riskier.
The option trading risks pertaining to options buyers are:
• Risk of losing your entire investment in a relatively short period of time.
• The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the
call (for a call option) or if the stock is higher than the strike price of the put (for a put option).
• European style options, which do not have secondary markets on which to sell the options prior to expiration, can
only realize their value upon expiration.
• Specific exercise provisions of a specific option contract may create risks.
• Regulatory agencies may impose exercise restrictions, which stops you from realizing value.
The option trading risks pertaining to options sellers are:
• Options sold may be exercised at any time before expiration.
• Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call
options sold and continues to risk a loss due to a decline in the underlying stock.
• Writers of Naked Calls risk unlimited losses if the underlying stock rises.
• Writers of Naked Puts risk substantial losses if the underlying stock drops.
• Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include
liquidation by the broker.
• Writers of call options could lose more money than a short seller of that stock could on the same rise on that
underlying stock. This is an example of how the leverage in options can work against the option trader.
• Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised.
• Call options can be exercised outside of market hours, such that effective remedy actions cannot be performed by
the writer of those options.
• Writers of stock options are obligated under the options that they sold even if a trading market is not available or
that they are unable to perform a closing transaction.
• The value of the underlying stock may surge or ditch unexpectedly, leading to automatic exercises.
Other option trading risks are:
• The complexity of some option strategies is a significant risk on its own.
• Option trading exchanges or markets and option contracts themselves are open to changes at all times.
• Options markets have the right to halt the trading of any options, thus preventing investors from realizing value.
• Risk of erroneous reporting of exercise value.
•
If an options brokerage firm goes insolvent, investors trading through that firm may be affected.
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•
Internationally traded options have special risks due to timing across borders.
Risks that are not specific to options trading include market risk, sector risk and individual stock risk. Option trading risks
are closely related to stock risks, as stock options are a derivative of stocks.
Derivatives: Derivatives are types of investments where the investor does not own the underlying asset. There are many
different types of derivative instruments, including, but not limited to, options, swaps, futures, and forward contracts.
Derivatives have numerous uses as well as various risks associated with them, but they are generally considered an
alternative way to participate in the market. Investors typically use derivatives for three reasons: to hedge a position, to
increase leverage, or to speculate on an asset's movement. The key to making a sound investment is to fully understand
the characteristics and risks associated with the derivative, including, but not limited to counterparty, underlying asset,
price, and expiration risks. The use of a derivative only makes sense if the investor is fully aware of the risks and
understands the impact of the investment within a portfolio strategy. Due to the variety of available derivatives and the
range of potential risks, a detailed explanation of derivatives is beyond the scope of this disclosure.
Structured Products: A structured product, also known as a market-linked product, is generally a pre-packaged investment
strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt
issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment
banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. The derivative
component is often an option. The note provides for periodic interest payments to the investor at a predetermined rate,
and the derivative component provides for the payment at maturity. Some products use the derivative component as a put
option written by the investor that gives the buyer of the put option the right to sell to the investor the security or
securities at a predetermined price. Other products use the derivative component to provide for a call option written by
the investor that gives the buyer of the call option the right to buy the security or securities from the investor at a
predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of
principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation (FDIC) insured;
they may only be insured by the issuer, and thus have the potential for loss of principal in the case of a liquidity crisis, or
other solvency problems with the issuing company. Investing in structured products involves a number of risks including
but not limited to: fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and
credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited
liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict.
Alternative Investment Risk: Alternative investments include investment into partnerships, alternative mutual funds, non-
traditional ETFs, managed futures, and/or real estate investments, as well as utilizing derivative instruments, such as
options, futures, or index-based instruments, and/or leverage strategies. Alternative investments may have complex terms
and features that are not easily understood and are not suitable for all investors. These investments entail a high degree of
risk. It is possible to experience total loss or a substantial loss of principal investment. In the absence of a public market for
these securities, there is lack of liquidity and an expected investment time horizon usually in excess of five years. There are
no guarantees that distributions and/or payments of distributions will be received and can decrease or diminish overtime.
Custom indexing risk: Custom Indexing allows clients to set more specific criteria for the holdings in their portfolios while
still seeking to replicate the performance of each client’s preferred benchmark index. Custom Indexing strategies generally
invest in and gain exposure to only a representative sample of the securities in a benchmark index; they seek to replicate
the aggregate characteristics similar to those of the benchmark. As a result, they may fail to replicate the index
characteristics and, therefore, underperform the benchmark index. Tax Disclosure: Some strategies using custom indexing
may result in multiple transactions in pursuit of tax loss harvesting that may add complexity to investor’s tax preparation.
Item 9 Disciplinary Information
We are required to disclose the facts of any legal or disciplinary events that are material to a client's evaluation of our
advisory business or the integrity of our management. We do not have any required disclosures under this item.
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Item 10 Other Financial Industry Activities and Affiliations
Independent Insurance Agents
Persons providing investment advice on behalf of our firm are licensed as independent insurance agents. These persons
will earn commission-based compensation for selling insurance products, including insurance products they sell to you.
Insurance commissions earned by these persons are separate and in addition to our advisory fees. See the Fees and
Compensation section in this brochure for more information on the compensation received by independent insurance
agents who are affiliated with our firm.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
Description of Our Code of Ethics
We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code of Ethics includes
guidelines for professional standards of conduct for persons associated with our firm. Our goal is to protect your interests
at all times and to demonstrate our commitment to our fiduciary duties of honesty, good faith, and fair dealing with you.
All persons associated with our firm are expected to adhere strictly to these guidelines. Persons associated with our firm
are also required to report any violations of our Code of Ethics. Additionally, we maintain and enforce written policies
reasonably designed to prevent the misuse or dissemination of material, non-public information about you or your account
holdings by persons associated with our firm.
Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the telephone number on the
cover page of this brochure.
Participation or Interest in Client Transactions
Neither our firm nor any persons associated with our firm has any material financial interest in client transactions beyond
the provision of investment advisory services as disclosed in this brochure.
Personal Trading Practices
Our firm or persons associated with our firm may buy or sell the same securities that we recommend to you or securities in
which you are already invested. A conflict of interest exists in such cases because we have the ability to trade ahead of you
and potentially receive more favorable prices than you will receive. To mitigate this conflict of interest, it is our policy that
neither our firm nor persons associated with our firm shall have priority over your account in the purchase or sale of
securities.
Aggregated Trading
Our firm or persons associated with our firm may buy or sell securities for you at the same time we or persons associated
with our firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with
your orders to purchase securities ("aggregated trading"). Refer to the Brokerage Practices section in this brochure for
information on our aggregated trading practices.
Item 12 Brokerage Practices
We primarily recommend the brokerage and custodial services of Charles Schwab & Co., Inc.(“Schwab”), but may also
recommend Interactive Brokers Group. Your assets must be maintained in an account at a “qualified custodian,” generally
a broker-dealer or bank. In recognition of the value of the services the Custodian provides, you may pay higher
commissions and/or trading costs than those that may be available elsewhere. Our selection of custodian is based on
many factors, including the level of services provided, the custodian’s financial stability, and the cost of services provided
by the custodian to our clients, which includes the yield on cash sweep choices, commissions, custody fees and other fees
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or expenses.
We seek to recommend a custodian/broker that will hold your assets and execute transactions on terms that are, overall,
the most favorable compared to other available providers and their services. We consider various factors, including:
• Capability to buy and sell securities for your account itself or to facilitate such services
• The likelihood that your trades will be executed
• Availability of investment research and tools
• Overall quality of services
• Competitiveness of price
• Reputation, financial strength, and stability
• Existing relationship with our firm and our other clients
Research and Other Soft Dollar Benefits
We do not have any soft dollar arrangements.
Economic Benefits
As a registered investment adviser, we have access to the institutional platform of your account custodian. As such, we will
also have access to research products and services from your account custodian and/or another brokerage firm. These
products may include financial publications, information about particular companies and industries, research software, and
other products or services that provide lawful and appropriate assistance to our firm in the performance of our investment
decision-making responsibilities. Services may include access to client account data (such as duplicate trade confirmations
and account statements); the ability to have investment advisory fees deducted directly from client account; trade
execution and allocate aggregated trade orders for multiple client accounts; and providing pricing and other market data.
Schwab also provides us with services that help us manage and further develop our business enterprise. Such services
generally benefit only us. For example, Schwab has paid for the expenses incurred by certain advisory personnel to attend
Schwab Conferences. Such research products and services are generally provided to all investment advisers that utilize the
institutional services platforms of these custodians and are not considered to be paid for with soft dollars. However, you
should be aware that the commissions charged by a particular broker for a particular transaction or set of transactions may
be greater than the amounts another broker who did not provide research services or products might charge. The
availability of products and services benefits us because we do not have to produce or purchase them. They are not
contingent upon Marion Wealth Management committing any specific amount of business to a custodian in trading
commissions or assets in custody. The fact that we receive these benefits is an incentive for us to recommend the use of a
particular custodian rather than making such a decision based exclusively on your interest in receiving the best value in
custody services and the most favorable execution of your transactions. This is a conflict of interest. We believe, however,
that taken in the aggregate our recommendation of a particular custodian and broker is in the best interest of our clients.
Our selection is primarily supported by the scope, quality and price of a custodian’s services, and not services that benefit
only us.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage
services or research.
Directed Brokerage
We routinely require that you direct our firm to execute transactions through Charles Schwab & Co., Inc. or Interactive
Brokers Group. As such, we may be unable to achieve the most favorable execution of your transactions and you may pay
higher brokerage commissions than you might otherwise pay through another broker-dealer that offers the same types of
services. Not all advisers require their clients to direct brokerage.
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Aggregated Trades
We combine multiple orders for shares of the same securities purchased for discretionary advisory accounts we manage
(this practice is commonly referred to as "aggregated trading"). We will then distribute a portion of the shares to
participating accounts in a fair and equitable manner. Generally, participating accounts will pay a fixed transaction cost
regardless of the number of shares transacted. In certain cases, each participating account pays an average price per share
for all transactions and pays a proportionate share of all transaction costs on any given day. In the event an order is only
partially filled, the shares will be allocated to participating accounts in a fair and equitable manner, typically in proportion
to the size of each client’s order. Accounts owned by our firm or persons associated with our firm may participate in
aggregated trading with your accounts; however, they will not be given preferential treatment.
We do not aggregate trades for non-discretionary accounts. Accordingly, non-discretionary accounts may pay different
costs than discretionary accounts pay. If you enter into non-discretionary arrangements with our firm, we may not be able
to buy and sell the same quantities of securities for you and you may pay higher commissions, fees, and/or transaction
costs than clients who enter into discretionary arrangements with our firm.
Item 13 Review of Accounts
Your adviser will monitor your accounts on an ongoing basis and will conduct account reviews at least annually, to ensure
the advisory services provided to you are consistent with your investment needs and objectives. Additional reviews may be
conducted based on various circumstances, including, but not limited to:
• contributions and withdrawals
• year-end tax planning
• market moving events
• security specific events
• changes in your risk/return objectives
The individuals conducting reviews may vary from time to time, as personnel join or leave our firm.
We will provide you with additional or regular written reports in conjunction with account reviews. Reports we provide to
you will contain relevant account and/or market-related information such as an inventory of account holdings and account
performance, etc. You will receive trade confirmations and monthly or quarterly statements from your account
custodian(s).
Your adviser will review financial plans as needed, depending on the arrangements made with you at the inception of your
advisory relationship to ensure that the advice provided is consistent with your investment needs and objectives.
Generally, we will contact you periodically to determine whether any updates may be needed based on changes in your
circumstances. Changed circumstances may include, but are not limited to marriage, divorce, birth, death, inheritance,
lawsuit, retirement, job loss and/or disability, among others. We recommend meeting with you at least annually to review
and update your plan, if needed. Additional reviews will be conducted upon your request. Such reviews and updates may
be subject to our then current hourly rate. Written updates to the financial plan will be provided in conjunction with the
review. If you implement financial planning advice, you will receive trade confirmations and monthly or quarterly
statements from relevant custodians.
Item 14 Client Referrals and Other Compensation
We directly compensate non-employee (outside) consultants, individuals, and/or entities (solicitors) for client referrals. In
order to receive a cash referral fee from us, solicitors must comply with the requirements of the jurisdictions in which they
operate. If you were referred to us by a solicitor, you should have received a copy of this brochure along with the solicitor's
disclosure statement at the time of the referral. The solicitor that referred you to us will receive a one-time, flat referral
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fee upon the referral being provided. You will not pay additional fees because of this referral arrangement.
Solicitors that refer business to more than one investment adviser may have a financial incentive to recommend advisers
with more favorable compensation arrangements. We request that our solicitors disclose to you whether multiple referral
relationships exist, and those comparable services may be available from other advisers for lower fees and/or where the
solicitor's compensation is less favorable.
Item 15 Custody
As paying agent for our firm, your independent custodian will directly debit your account(s) for the payment of our
advisory fees. This ability to deduct our advisory fees from your accounts causes our firm to exercise limited custody over
your funds or securities. We do not have physical custody of any of your funds and/or securities. Your funds and securities
will be held with a bank, broker-dealer, or other qualified custodian. You will receive account statements from the qualified
custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will
indicate the amount of our advisory fees deducted from your account(s) each billing period. You should carefully review
account statements for accuracy.
Certain clients may grant MWM the authority to make disbursements to third parties from the client’s account at a
qualified custodian via a standing letter or authorization (SLOA). This causes our firm to exercise limited custody.
Accordingly, MWM has procedures in place to follow the safeguards specified by the SEC to exempt the Firm from
undergoing an annual audit.
Item 16 Investment Discretion
Under MWM’s investment advisory agreement, which advisory clients must execute at the outset of an advisory
relationship, clients grant investment discretion to the Firm with respect to trading activity in their accounts. When a client
chooses to grant investment discretion to MWM, MWM will have authority to supervise and direct the investments of and
for the client’s account without pre-approval from the client. Pursuant to this discretionary authority, MWM will determine
which securities are bought or sold for the account and the total amount of such purchases and sales. In all cases, such
discretion is exercised in a manner consistent with the stated investment objectives for the particular client account.
While MWM does not typically accept non-discretionary assignments, in those cases where a client has not granted
investment discretion to MWM, MWM makes 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 MWM direct the execution of purchase or sale orders to implement the recommended transactions for
the client’s account.
Item 17 Voting Client Securities
We will not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice regarding
corporate actions and the exercise of your proxy voting rights. If you own shares of applicable securities, you are
responsible for exercising your right to vote as a shareholder.
In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to
receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have
authorized our firm to contact you by electronic mail, in which case, we would forward any electronic solicitations to vote
proxies.
Item 18 Financial Information
Our firm does not have any financial condition or impairment that would prevent us from meeting our contractual
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commitments to you. We do not take physical custody of client funds or securities, or serve as trustee or signatory for
client accounts, and we do not require the prepayment of more than $1,200 in fees six or more months in advance.
Therefore, we are not required to include a financial statement with this brochure.
We have not filed a bankruptcy petition at any time in the past ten years.
Item 19 Requirements for State-Registered Advisers
We are a federally registered investment adviser; therefore, we are not required to respond to this item.
Additional Information
Trade Errors
In the event a trading error occurs in your account, our policy is to restore your account to the position it should have been
in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade,
adjusting an allocation, and/or reimbursing the account.
Class Action Lawsuits
We do not determine if securities held by you are the subject of a class action lawsuit or whether you are eligible to
participate in class action settlements or litigation nor do we initiate or participate in litigation to recover damages on your
behalf for injuries as a result of actions, misconduct, or negligence by issuers of securities held by you.
04/25/2025 Marion Wealth Management is a Registered Investment Advisor with the SEC 21