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Cover Page - Item 1
Market Investment Group, LLC
Form ADV Part 2A Brochure
July 7, 2025
Main Office - Wichita
110 E Waterman Street, Suite 150
Wichita, KS 67202
Tel: 316-252-8707
Overland Park, KS
5267 West 95th Street
Overland Park, KS 66207
Tel: 913-730-7749
Northland Kansas City, MO
6300 North Revere Ave. Suite 230
Kansas City, MO 64151
Tel: 816-548-2000
Independence, MO
18920 East Valley View Parkway
Independence, MO 64055
Tel: 816-790-7454
Email: ria-info@marketadvisorygroup.com
Market Investment Group, LLC is an investment adviser registered with the Securities and Exchange Commission
("SEC"). An "investment adviser" means any person who, for compensation, engages in the business of advising
others, either directly or through publications or writings, as to the value of securities or as to the advisability of
investing in, purchasing, or selling securities, or who, for compensation and as part of a regular business, issues or
promulgates analyses or reports concerning securities. Registration with the SEC or any state securities authority
does not imply a certain level of skill or training.
This brochure provides information about the qualifications and business practices of Market Investment Group,
LLC. If you have any questions about the contents of this brochure, please contact us at (316) 252-8707 or at ria-
info@marketadvisorygroup.com. The information in this brochure has not been approved or verified by the United
States Securities and Exchange Commission or by any state securities authority.
information about Market
Investment Group, LLC
is available on the SEC’s website at
Additional
www.adviserinfo.sec.gov. The firm's CRD/IARD number is 334248.
Market Investment Group, LLC
Form ADV Part 2A Brochure
Page 2
Material Changes - Item 2
The purpose of this page is to inform you of any material changes since the previous version of this brochure. At
this time, we do not have any material changes to disclose.
If you would like to receive a complete copy of our current brochure free of charge at any time, please contact us
at (316) 252-8707 or at ria-info@marketadvisorygroup.com.
Market Investment Group, LLC
Form ADV Part 2A Brochure
Page 3
Table of Contents - Item 3
Contents
Cover Page - Item 1 ................................................................................................................................... 1
Material Changes - Item 2 ......................................................................................................................... 2
Table of Contents - Item 3 ........................................................................................................................ 3
Advisory Business - Item 4 ........................................................................................................................ 4
Fees and Compensation - Item 5 .............................................................................................................. 6
Performance-Based Fees and Side-By-Side Management - Item 6 .......................................................... 9
Types of Clients - Item 7............................................................................................................................ 9
Methods of Analysis, Investment Strategies and Risk of Loss - Item 8 ................................................... 10
Disciplinary Information - Item 9 ............................................................................................................ 13
Other Financial Industry Activities or Affiliations - Item 10 .................................................................... 13
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11 ........... 14
Brokerage Practices - Item 12 ................................................................................................................. 15
Review of Accounts - Item 13 ................................................................................................................. 17
Client Referrals and Other Compensation - Item 14 .............................................................................. 18
Custody - Item 15 .................................................................................................................................... 19
Investment Discretion - Item 16 ............................................................................................................. 19
Voting Client Securities - Item 17 ........................................................................................................... 19
Financial Information - Item 18 .............................................................................................................. 20
Requirements of State-Registered Advisers - Item 19 ............................................................................ 20
Market Investment Group, LLC Privacy Policy Notice ............................................................................ 20
Market Investment Group, LLC
Form ADV Part 2A Brochure
Page 4
Advisory Business - Item 4
Market Investment Group, LLC (“MIG” and/or “the firm”) is a limited liability company formed in the State of
Kansas. Market Holdings, Inc. is the principal owner of MIG. Matthew James Edward Goolsby, Danny James
Goolsby, Larry Dean Kloefkorn, and Jonathan David McCoy are the principal owners of Market Holdings, Inc. MIG
has been registered as an investment adviser since 2025.
The following paragraphs describe our services and fees. You may see the term Associated Person throughout this
Brochure. As used in this Brochure, this term refers to anyone from our firm who is an officer, employee, and all
individuals providing investment advice on behalf of our firm. Where required, such persons are properly licensed
or registered as investment adviser representatives.
Financial Planning Services
We offer broad-based financial planning services regarding management of financial resources based upon an
analysis of the client’s individual needs. We will meet with you to gather information about your financial
circumstances and objectives. Once we collect and analyse the documentation and information you provide, we
work with you to develop a financial plan designed to help you achieve your financial goals and objectives. In this
way, MIG assists the client in developing a strategy for the management of income, assets, and liabilities. In general,
financial planning services may include any one or all of the following:
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•
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• Cash Flow Analysis – Assessment of a client’s present financial situation by collecting information
regarding net worth and cash flow statements, tax returns, insurance policies, investment portfolios,
pension plans, employee benefit statements, etc. The firm advises on ways to reduce risk, coordinate, and
organize records and estate information.
Tax Analysis and Planning - The goal of tax planning is to arrange your financial affairs so as to minimize
your taxes. There are three basic ways to reduce your taxes, and each basic method might have several
variations. You can reduce your income, increase your deductions, and take advantage of tax credits.
• Retirement Analysis – Identification of a client’s long-term financial and personal goals and objectives
includes advice for accumulating wealth for retirement income or appropriate distribution of assets
following retirement. Tax consequences and implications are identified and evaluated.
Portfolio Analysis/Investment Planning – We provide investment alternatives, including asset allocation,
and effect on a client’s portfolio. We evaluate economic and tax characteristics of existing investments as
well as their suitability for a client’s objectives. We identify and evaluate tax consequences and their
implications.
Insurance Analysis – Includes risk management associated with advisory recommendations based on a
combination of insurance types to meet a client’s needs, e.g., life, health, disability, and long-term care
insurance. This will necessitate an analysis of cash needs of family at death, income needs of surviving
dependents, and disability income analysis.
Education Savings Analysis – Alternatives and strategies with respect to the complete or partial funding
of college or other post-secondary education.
Estate Analysis – Advising clients with respect to property ownership, distribution strategies, estate tax
reduction, and tax payment techniques.
Financial plans are based on a client’s financial situation based on the information provided to the firm. The
recommendations and solutions are designed to achieve the client’s desired goals, subject to periodic evaluation
of the financial plan, which may require revision to meet changing circumstances. Clients are advised to notify us
promptly of any change to their financial situation, goals, objectives, or needs.
Market Investment Group, LLC
Form ADV Part 2A Brochure
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You may choose to accept or reject our recommendations. If you decide to proceed with our recommendations,
you may do so either through our investment advisory services or by using the advisory/brokerage firm of your
choice.
In some cases, our recommendations will involve the purchase of insurance products. Associated Persons of MIG
are licensed insurance agents and can affect transactions in insurance products and earn commission-based
compensation for these activities. Clients should be aware that a conflict of interest is inherent in such an
arrangement. Clients are instructed that the fees paid to the firm for advisory services are separate and distinct
from the commissions earned by our affiliates and our dually licensed Associated Persons. Clients of MIG are not
required to purchase insurance products from the firm’s dually licensed Associated Persons, and can purchase
insurance products from any insurance agency and agent they choose.
Note: Information related legal consequences that is provided as part of the financial plan is for informative
purposes only. Clients are instructed to contact their attorney for personalized advice. Please see Item 10 below
for information about our recommendation of Eidelman Law Firm for legal services.
Portfolio Management Services
Our firm offers discretionary, and in limited cases, non-discretionary portfolio management services to our clients.
Discretionary portfolio management means we will make investment decisions and place buy or sell orders in your
account without contacting you prior to each transaction. These decisions would be made based upon your stated
investment objectives. If you wish, you may limit our discretionary authority by, for example, setting a limit on the
type of securities that can be purchased for your portfolio. Simply provide us with your restrictions or guidelines
in writing. Non-discretionary portfolio management service means that we must obtain your approval prior to
making any transactions in your account.
Our investment advice is tailored to meet our clients’ needs and investment objectives. If you decide to hire our
firm to assist you with the management of your portfolio, an Associated Person of MIG will meet with you and
gather information about your financial situation, investment objectives, and any reasonable restrictions you
would like to impose on the management of the account. The information we gather will help us implement an
asset allocation strategy that will be specific to your needs and goals.
Currently, our asset allocation and advisory services are offered in conjunction with a sub-adviser. The sub-adviser
assists our firm with back-office support, trading, report preparation, and billing. We use model portfolios
developed by the sub-adviser and/or other registered investment advisers. These other investment advisers are
responsible for the research and security selection within model portfolios, day-to-day trading, billing calculation,
and other back-office operations. MIG is responsible for the supervision of the account, portfolio reallocations and
rebalancing, and ongoing client interaction and servicing. At this time, MIG uses the following sub-adviser:
Foundations Investment Advisors LLC (CRD# 175083): Foundations Investment Advisors LLC gives us access to its
proprietary portfolio models, along with models provided or managed by Cabana Asset Management, Frontier
Wealth Management, Morningstar Investment Management, BlackRock Solutions, among others. All disclosure
information about these entities is available on the SEC’s public disclosure site, www.adviserinfo.sec.gov. All clients
will be provided with a current copy of Foundations Investment Advisors LLC’s Form ADV Part 2 Brochure at the
inception of service. This document provides important disclosures about Foundations Investment Advisors LLC’s
services, portfolio models, fees, conflicts of interest, disciplinary history (if any), and other important information
that would help clients understand the scope of sub advisory services provided by Foundations Investment
Advisors LLC.
All accounts are managed in accordance with the client’s investment needs. Investments may include various types
of securities such as equity securities, Exchange Traded Funds (ETFs), mutual funds, corporate debt securities,
commercial paper, certificates of deposit, municipal securities, and U.S. Government securities. Other types of
Market Investment Group, LLC
Form ADV Part 2A Brochure
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investments may also be recommended where such investments are appropriate based on the client’s stated goals
and objectives.
Investments and allocations are determined and based upon the client’s predefined objectives, risk tolerance, time
horizon, financial horizon, financial information, and other various suitability factors. Further restrictions and
guidelines imposed by the client may affect the composition and performance of a client’s portfolio. For these
reasons, performance of the portfolio may not be identical to other clients of MIG. On an ongoing basis, MIG
reviews the client’s financial circumstances and investment objectives, and instructs the sub-adviser to make the
necessary adjustments to the client’s portfolio.
Clients are advised to provide the firm with prompt notice of any changes in their personal financial circumstances,
investment objectives, goals, and tolerance for risk. However, MIG will contact the client at least annually to
determine whether there have been any changes in the client's personal financial circumstances, investment
objectives, and tolerance for risk.
Wrap Fee Programs
A wrap fee program combines asset management, advisory services, and trade execution for a single fee. We do
not sponsor or manage, or participate in any wrap fee programs. Our portfolio management fees are exclusive of,
and in addition to brokerage commissions, transaction fees, and other related costs and expenses, which will be
incurred by the client. However, we will not receive any portion of the commissions, fees, and costs. Please see
Item 5 below for information regarding additional fees and Item 12 below for further information on brokerage
practices, fees, and transaction costs.
Clients should note that recommended third party programs may be offered as wrap fee programs. For detailed
information regarding these programs, please carefully review the disclosure documents provided by the relevant
third-party sponsor/manager of such third-party programs.
Assets Under Management
As of July 5, 2025, we have $126,142,341 in discretionary assets under management and $0 in non-discretionary
assets under management.
Fees and Compensation - Item 5
Financial Planning Fees
MIG provides its clients financial planning and consulting services. Prior to engaging MIG to provide consulting
services, the client will be required to enter into a financial planning agreement with our firm. The Agreement will
set forth the terms and conditions of the engagement, and will describe the scope of the services to be provided
and the fee that is due from the client. MIG will charge an hourly fee of up to $500 per hour or a fixed fee of up to
$10,000 for financial planning services. 50% of the fee is payable upon execution of the financial planning
agreement, with the balance due upon completion of services. MIG does not require the prepayment of over
$1,200, six or more months in advance and all agreed upon services will be completed within 6 months of execution
of the financial planning agreement. When a financial planning client engages MIG for portfolio management
services, the financial planning services fee is credited towards the portfolio management service fee.
Either party may terminate the financial planning agreement by written notice to the other. In the event the client
terminates MIG’s financial planning services, the balance of prepaid, unearned fees (if any) will be refunded to the
client promptly.
Market Investment Group, LLC
Form ADV Part 2A Brochure
Page 7
Portfolio Management Fees
For portfolio management services, MIG charges an annual fee of up to 1.50% of assets under management (AUM).
The fee includes compensation paid to Foundations Investment Advisors LLC and most portfolio model providers.
Portfolio management fees are payable monthly in arrears and are based on the average daily value of the assets
of the month just ended. In certain situations, an added 0.15% may be applied to the management fee for certain
model providers. This additional fee usually applies to model providers who specialize in more aggressive trading
strategies. The client will be notified which model providers charge this extra management fee at the time of
signing the advisory agreement. All accounts will also be assessed a $50 annual administrative and technology fee
(“ATF”) at the end of the January billing cycle. This $50 fee applies to non-managed accounts that are included in
our portfolio management systems for accounting and monitoring purposes and listed in our performance reports.
Other fee payment arrangements can be negotiated on a case-by-case basis. These arrangements will be listed in
the advisory agreement signed by the firm and the client.
At this time, MIG, Market Tax Services, LLC, our affiliated accounting firm, and Eidelman Law Firm, an unaffiliated
law firm, provide combined services under a structured tier system based on the amount of assets under our
management, with each tier subject to a percentage-based fee and including discounted services and benefits from
Market Tax Services and Eidelman Law Firm. These combined service tiers are listed below:
Tier 1
$25,000-$99,999 in invested assets
• Up to 1.50% AUM fee on accounts managed by MIG
• $75 discount on current annual tax preparation
• Yearly tax planning
• $250 estate plan discount
• Annual healthcare review
Tier 4
$750,000-$999,999 in invested assets
• Up to 1.25% AUM fee on accounts managed by MIG
• $200 discount on current annual tax preparation
• Yearly tax planning
• 4 hours of CPA advice, annually
• $1,500 estate plan discount
• 4 hours of legal advice, annually
• Annual healthcare review
Tier 2
$100,000-$499,999 in invested assets
• Up to 1.50% AUM fee on accounts managed by MIG
• $115 discount on current annual tax preparation
• Yearly tax planning
• 1 hour of CPA advice, annually
• $500 estate plan discount
• 1 hour of legal advice, annually
• Annual healthcare review
Tier 5
$1,000,000-$1,999,999 in invested assets
• Up to 1.00% AUM fee on accounts managed by MIG
• 100% discount on current annual tax preparation
(Except for Schedules C, E & F, or K-1)
• Yearly tax planning
• 6 hours of CPA advice, annually
• Estate plan paid for by Market Advisory Group
• Eidelman Law Firm Care Program
• 6 hours of legal advice, annually
• Annual healthcare review
Tier 3
$500,000-$749,000 in invested assets
• Up to 1.25% AUM fee on accounts managed by MIG
• $145 discount on current annual tax preparation
• Yearly tax planning
• 2 hours of CPA advice, annually
• $1,000 estate plan discount
• 2 hours of legal advice, annually
• Annual healthcare review
Tier 6
$2,000,000 and up in in invested assets
• Up to 0.75% AUM fee on accounts managed by MIG
• 100% discount on current annual tax preparation
• Yearly tax planning
• 10 hours of CPA advice, annually
• Estate plan paid for by Market Advisory Group
• Eidelman Law Firm Care Program
• 10 hours of legal advice, annually
• Annual healthcare review
Market Investment Group, LLC
Form ADV Part 2A Brochure
Page 8
The fee is deducted from the client's account held at the custodian. The sub-adviser calculates the fee and debits
such fees from the client’s custodial account on behalf of MIG. If insufficient cash is available to pay such fees,
securities in an amount equal to the balance of unpaid fees will be liquidated to pay for the unpaid balance. In
limited cases, we may invoice the client directly for the payment of fees.
The fee listed above includes the compensation received by the model provider and the sub-adviser. We may
modify the fee at any time upon 30 days’ written notice.
Our annual fee is exclusive of and in addition to brokerage commissions, transaction fees, and other related costs
and expenses, which will be incurred by the client. However, we will not receive any portion of the commissions,
fees, and costs. Please see Item 12 – Brokerage Practices for further information on brokerage and transaction
costs.
The portfolio management agreement may be canceled at any time by the client or by MIG with 30 days’ prior
written notice to the other party. Refunds are not applicable because the fee is payable in arrears.
Additional Information About Fees and Expenses
Advisory recommendations are based on financial information and situation that you disclose to us at the time the
services are provided. Certain assumptions may be made with respect to interest and inflation rates and the use
of past trends and performance of the market and economy. Past performance is in no way an indication of future
returns. As your financial situation, goals, objectives, or needs change, you must notify us promptly.
MIG’s fees are negotiable based on the complexity of client goals and objectives and level of services rendered.
Fees are charged as described above and are not based on a share of capital gains of the funds of an advisory client.
We also allow Associated Persons servicing the account to negotiate the exact investment management fees within
the range disclosed in our Form ADV Part 2A Brochure. As a result, the Associated Person servicing your account
may charge more or less for the same service than another Associated Person of our firm. Further, our annual
investment management fee may be higher than that charged by other investment advisors offering similar
services/programs.
All fees paid to MIG for investment advisory services are separate and distinct from the fees and expenses charged
by mutual funds or exchange traded funds to their shareholders. These fees and expenses are described in each
fund's prospectus. These fees generally include management fees, other fund expenses, early redemption fees,
and possible distribution fees. A client could invest in a mutual fund directly, without the services of MIG. In that
case, the client would not receive the services provided by MIG, which are designed, among other things, to assist
the client in determining which mutual fund or funds are most appropriate to each client's financial condition and
objectives. Accordingly, the client should review both the fees charged by the funds and the fees charged by MIG
to understand fully the total amount of fees to be paid by the client and to evaluate the advisory services being
provided.
Further information regarding fees and charges assessed by a mutual fund is available in each mutual fund’s
prospectus. Although the firm uses its best efforts to purchase lower cost mutual fund shares when available, some
mutual fund companies do not offer institutional classes or funds that do not pay 12b-1 distribution fees.
Billing on Cash Positions: The firm treats cash and cash equivalents as an asset class. Accordingly, unless otherwise
agreed in writing, all cash and cash equivalent positions (e.g., money market funds, etc.) are included as part of
assets under management for purposes of calculating the firm’s advisory fee. At any specific point in time,
depending upon perceived or anticipated market conditions/events (there being no guarantee that such
anticipated market conditions/events will occur), the firm may maintain cash and/or cash equivalent positions for
defensive, liquidity, or other purposes. While assets are maintained in cash or cash equivalents, such amounts
Market Investment Group, LLC
Form ADV Part 2A Brochure
Page 9
could miss market advances and, depending upon current yields, at any point in time, the firm’s advisory fee could
exceed the interest paid by the client’s cash or cash equivalent positions.
Periods of Portfolio Inactivity: The firm has a fiduciary duty to provide services consistent with the client’s best
interest. As part of its investment advisory services, the firm will review client portfolios on an ongoing basis to
determine if any changes are necessary based upon various factors, including but not limited to investment
performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances,
and changes in the client’s investment objectives. Based upon these and other factors, there may be extended
periods of time when the firm determines that changes to a client’s portfolio are neither necessary nor prudent.
Notwithstanding, unless otherwise agreed in writing, the firm’s annual investment advisory fee will continue to
apply during these periods, and there can be no assurance that investment decisions made by the firm will be
profitable or equal any specific performance level(s).
Sales Compensation
Associated Persons of MIG are licensed insurance agents. As such, Associated Persons can affect transactions in
insurance products and earn commission-based compensation for these activities. Clients are instructed that the
fees paid to the firm for advisory services are separate and distinct from the commissions earned by our dually
licensed Associated Persons.
The sale of annuity contracts or insurance products offered by Associated Persons are intended to complement
MIG’s advisory services. However, the receipt of commission-based compensation presents a conflict of interest
because our firm and Associated Persons who are licensed insurance agents have an incentive to recommend
insurance products to you for the purpose of generating commissions rather than recommendations made solely
based on your needs. MIG has policies and procedures in place to monitor all client transactions and all client
transaction costs will be disclosed to the client. Clients to whom the firm offers advisory services are informed that
they are under no obligation to use the firm’s Associated Persons for insurance services and may use the insurance
brokerage firm and agent of their choice.
We strive to identify all potential and actual material conflicts of interest between you, our firm, and our Associated
Persons in this Disclosure Brochure. If additional conflicts arise in the future, we will notify you in writing and/or
provide you an updated Disclosure Brochure.
Performance-Based Fees and Side-By-Side Management - Item 6
Performance-based fees are based on a share of capital gains on or capital appreciation of the client’s assets. Side
by-side management refers to managing accounts that pay performance-based fees alongside those that do not
pay performance-based fees. Our firm and Associated Persons do not accept performance-based fees.
Types of Clients - Item 7
We generally offer investment advisory services to individuals, pension and profit-sharing plans and their
participants, trusts, estates, charitable organizations, corporations, and other business entities.
MIG does not require a minimum amount of assets to establish an advisory relationship.
Market Investment Group, LLC
Form ADV Part 2A Brochure
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Methods of Analysis, Investment Strategies and Risk of Loss - Item 8
All asset allocation models are developed by the sub-advisers and/or other third-party model providers (listed
under Item 4 above) in accordance with investment programs developed by these entities. MIG will not
implement its own methods of analysis and investment strategies. Clients should refer to the relevant sub-
advisers' and/or third-party model providers Form ADV Brochures for more information about the methods of
analysis and investment strategies used by those firms. Security analysis methods used by the recommended sub-
advisers and/or other third-party model providers may include fundamental analysis, technical analysis, and
cyclical analysis.
Investment Strategies
The investment strategy for a specific client is based upon the objectives stated by the client during consultations
and documented in the client profile. The client may change these objectives at any time. Each client’s profile
contains information related to the client’s risk tolerance and any investment restrictions. Any other
documentation as required by our firm that documents the client’s objectives and their desired investment
strategy will be retained as part of the client’s file.
Investing in securities involves risk of loss that clients should be prepared to bear. Clients should fully
understand the nature of the contractual relationship(s) into which they are entering and the extent of their
exposure to risk. Certain investing strategies may not be suitable for many members of the public. You should
carefully consider whether the strategies employed would be appropriate for you in light of your experience,
objectives, financial resources, and other relevant circumstances.
Recommendation of Particular Types of Securities: As disclosed under the “Advisory Business” section in this
Brochure, we provide advice on various types of securities and we do not necessarily 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 of 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
it.
General Investment Risk: All investments come with the risk of losing money. Investing involves substantial risks,
including complete possible loss of principal plus other losses and may not be suitable for many members of the
public. Investments, unlike savings and checking accounts at a bank, are not insured by the government to protect
against market losses. Different market instruments carry different types and degrees of risk and you should
familiarize yourself with the risks involved in the particular market instruments in which you intend to invest.
Loss of Value: There can be no assurance that a specific investment will achieve its investment objectives and
past performance should not be seen as a guide to future returns. The value of investments and the income
derived may fall as well as rise and investors may not recoup the original amount invested. Investments may also
be affected by any changes in exchange control regulation, tax laws, withholding taxes, international, political and
economic developments, and governmental economic or monetary policies.
Interest Rate Risk: Fixed income securities and funds that invest in bonds and other fixed income securities may
fall in value if interest rates change. Generally, the prices of debt securities rise when interest rates fall, and their
prices fall when interest rates rise. Longer-term debt securities are usually more sensitive to interest rate changes.
Credit Risk: Investments in bonds and other fixed income securities are subject to the risk that the issuer(s) may
not make required interest payments. An issuer suffering an adverse change in its financial condition could lower
the credit quality of a security, leading to greater price volatility of the security. A lowering of the credit rating of
Market Investment Group, LLC
Form ADV Part 2A Brochure
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a security may also offset the security's liquidity, making it more difficult to sell. Funds investing in lower quality
debt securities are more susceptible to these problems and their value may be more volatile.
Foreign Exchange Risk: Foreign investments may be affected favorably or unfavorably by exchange control
regulations or changes in the exchange rates. Changes in currency exchange rates may influence the share value,
the dividends or interest earned and the gains and losses realized. Exchange rates between currencies are
determined by supply and demand in the currency exchange markets, the international balance of payments,
governmental intervention, speculation, and other economic and political conditions. If the currency in which a
security is denominated appreciates against the US Dollar, the value of the security will increase. Conversely, a
decline in the exchange rate of the currency would adversely affect the value of the security.
Concentrated Position Risk: Certain accounts may, or may be advised to, hold concentrated positions in specific
securities. Therefore, at times, an account may, or may be advised to, hold a relatively small number of securities
positions, each representing a relatively large portion of assets in the account. As a result, the account will be
subject to greater volatility than a more sector diversified portfolio. Investments in issuers within an industry or
economic sector that experiences adverse economic, business, political conditions or other concerns will impact
the value of such a portfolio more than if the portfolio’s investments were not so concentrated. A change in the
value of a single investment within the portfolio will affect the overall value of the portfolio and will cause greater
losses than it would in a portfolio that holds more diversified investments.
Risks Associated with Investing in Equities: Investments in equities generally refers to buying shares of stocks by
an individual or firms in return for receiving a future payment of dividends and capital gains if the value of the
stock increases. There is an innate risk involved when purchasing a stock that it may decrease in value and the
investment may incur a loss.
Risks Associated with Investing in Investment Company Securities: Mutual funds and Exchange Traded Funds
(“ETFs”) 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 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. The returns on
mutual funds and ETFs can be reduced by the costs to manage the funds. Investing in mutual funds and ETFs
carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Investments
in these securities are not guaranteed or insured by the FDIC or any other government agency. In addition, while
some mutual funds are “no load” and charge no fee to buy into, or sell out of, other types of mutual funds do
charge such fees which can also reduce returns.
Risks Associated with the Recommendation of Other Advisers: In the event we recommend a third-party
investment adviser to manage all or a portion of your assets, we will advise you on how to allocate your assets
among various classes of securities or third-party investment managers, programs, or managed model portfolios.
As such, we will primarily rely on investment model portfolios and strategies developed by the third-party
investment advisers and their portfolio managers. If there is a significant deviation in characteristics or
performance from the stated strategy and/or benchmark, we may recommend changing models or replacing a
third-party investment adviser. The primary risks associated with investing with a third party is that while a
particular third party may have demonstrated a certain level of success in the past; it may not be able to replicate
that success in future markets. In addition, as we do not control the underlying investments in third party model
portfolios, there is also a risk that a third party may deviate from the stated investment mandate or strategy of
the portfolio, making it a less suitable investment for our clients. To mitigate this risk, we seek third parties with
proven track records that have demonstrated a consistent level of performance and success over time. A third
party’s past performance is not a guarantee of future results and certain market and economic risks exist that
Market Investment Group, LLC
Form ADV Part 2A Brochure
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may adversely affect an account’s performance that could result in capital losses in your account. Please refer to
the third-party investment adviser’s advisory agreements, Form ADV Brochure, and associated disclosure
documents for details on their specific investment strategies, methods of analysis, and associated risks.
Risks Associated with Investing in Private Funds: Private investment funds are not registered with the Securities
and Exchange Commission and may not be registered with any other regulatory authority. Accordingly, they are
not subject to certain regulatory restrictions and oversight to which other issuers are subject. There may be little
public information available about their investments and performance. Moreover, as sales of shares of private
investment companies are generally restricted to certain qualified purchasers, it could be difficult for a client to
sell shares of a private investment company at an advantageous price and time. Since shares of private investment
companies are not publicly traded, from time to time it may be difficult to establish a fair value for the client’s
investment in these companies.
Risks Associated with Investing in Options: Transactions in options carry a high degree of risk. A relatively small
market movement will have a proportionately larger impact, which may work for or against the investor. The
placing of certain orders, which are intended to limit losses to certain amounts, may not be effective because
market conditions may make it impossible to execute such orders. Selling ("writing" or "granting") an option,
generally entails considerably greater risk than purchasing options. Although the premium received by the seller
is fixed, the seller may sustain a loss well in excess of that amount. The seller will also be exposed to the risk of
the purchaser exercising the option and the seller will be obliged either to settle the option in cash or to acquire
or deliver the underlying investment. If the option is "covered" by the seller holding a corresponding position in
the underlying investment or a future on another option, the risk may be reduced.
Use of Certain Securities that Employ Derivative Instruments: Securities that utilize derivative instruments can
lead to liquidity, credit, interest rate and market risks. Investments in derivative instruments may be subject to
greater volatility than investments in traditional securities, including the high degree of leverage often embedded
in such instruments, and potential material and prolonged deviations between the theoretical value and realizable
value of a derivative. Some derivatives have the potential for unlimited loss. Derivatives may at times be illiquid.
Certain derivatives may be difficult to value, and valuation may be more difficult in times of market turmoil.
Derivative investments can increase portfolio turnover and transaction costs. Derivatives also are subject to
counterparty risk and credit risk. New regulation of derivatives may make them more costly, or may otherwise
adversely affect their liquidity, value or performance. In addition, derivatives may be subject to the additional
risks, including: Foreign Currency Forward Contracts Risk, Futures Contracts Risk, Hedging Risk, and Swap
Agreements Risk.
Utilization of Alternative Investments: Strategies utilizing alternative investments are generally made with the
objective for long-term appreciation and are subject to limited liquidity. When we invest in securities not
managed by us, we have limited control over the management of such investments. Alternative investment
strategies pursued by the funds may be subject to additional risks including, but not limited to, derivatives
(including options and futures contracts) risk, liquidity risk of underlying securities, credit risk and commodities
risk. Certain alternative strategies involve the risk that a counterparty to a transaction will not perform as
promised, which would incur losses to a fund. Furthermore, alternative strategies may employ leverage, involve
extensive short positions and/or focus on narrow segments of the market, which may magnify the overall risks
and volatility associated with such investments.
For more detailed discussions of the specific risks associated with Alternative Investments, please refer to the
respective prospectuses and Private Placement Memorandum(s). The risk of loss described herein should not be
considered to be an exhaustive list of all the risks which clients should consider.
Cybersecurity Risks: Our firm and our service providers are subject to risks associated with a breach in
cybersecurity. Cybersecurity is a generic term used to describe the technology, processes, and practices designed
to protect networks, systems, computers, programs, and data from cyber-attacks and hacking by other computer
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users, and to avoid the resulting damage and disruption of hardware and software systems, loss or corruption of
data, and/or misappropriation of confidential information. In general, cyber-attacks are deliberate; however,
unintentional events may have similar effects. Cyber-attacks may cause losses to clients by interfering with the
processing of transactions, affecting the ability to calculate net asset value or impeding or sabotaging trading.
Clients may also incur substantial costs as the result of a cybersecurity breach, including those associated with
forensic analysis of the origin and scope of the breach, increased and upgraded cybersecurity, identity theft,
unauthorized use of proprietary information, litigation, and the dissemination of confidential and proprietary
information. Any such breach could expose our firm to civil liability as well as regulatory inquiry and/or action. In
addition, clients could be exposed to additional losses as a result of unauthorized use of their personal
information. While our firm has established business continuity plans, incident response plans and systems
designed to prevent cyber-attacks, there are inherent limitations in such plans and systems, including the
possibility that certain risks have not been identified. Similar types of cyber security risks also are present for
issuers of securities in which we invest, which could result in material adverse consequences for such issuers and
may cause a client's investment in such securities to lose value.
Public Health-Related Risk: Public health crises, such as viral outbreaks and other communicable diseases, can
spread quickly throughout the country and the world. Various measures taken by countries, including the United
States, both on a macro countrywide level and on a local level, to combat such crises, including quarantines, travel
bans, bans on public events, bans on large public gatherings, closures of public venues (e.g., restaurants, concert
halls, museums, theaters, schools, and stadiums), or shelter-in-place orders can significantly impact world
economies. The effect on the economy and on the public can be severe. The impact of epidemics or pandemics,
or widespread fear that such events may occur, could cause uncertainty for or negatively affect the global
economy, as well as the economies of individual countries, the financial performance of individual companies and
sectors, and markets generally in significant and unforeseeable ways. Any such impact could adversely affect the
prices and liquidity of the securities and other instruments in which clients are invested, which in turn could
negatively impact the account performance and cause investment losses. Recent examples include pandemic
risks related to COVID-19 and aggressive measures taken worldwide in response by governments, including
closing borders, restricting international and domestic travel, restrictions on businesses whose operations are
deemed likely to encourage the spread of a virus, including curtailments of operations and reductions in staff,
the downstream effects of those restrictions, and the imposition of prolonged quarantines of large
populations. The impact of such crises could be short term or may last for extended periods of time, and in either
case could result in substantial market disruptions, economic downturns, or recessions.
Disciplinary Information - Item 9
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events
that would be material to your evaluation of us or the integrity of our management. There is no history of
reportable material legal or disciplinary events by our firm or our management persons.
Other Financial Industry Activities or Affiliations - Item 10
Registrations with Other Investment Advisers
Associated Persons of our firm are dually registered as investment adviser representatives of Foundations
Investment Advisors LLC (“FIA”), an SEC registered investment adviser, and receive regular compensation for
advisory business conducted through FIA. In addition, FIA acts as a sub-adviser and model portfolio provider for
our firm. This presents a conflict of interest because we have an incentive to recommend the services of FIA over
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the services of another investment adviser with which we have no relationship. However, you are under no
obligation, contractually or otherwise, to utilize the advisory services of FIA.
Insurance Activities
Market Advisory Group, LLC, MAG Life, LLC, and Market Medicare Advisers, LLC are our affiliated insurance
agencies and Associated Persons of MIG are licensed insurance agents. Our dually licensed Associated Persons
can affect transactions in insurance products and earn commission-based compensation for these activities.
Clients are instructed that the fees paid to the firm for advisory services are separate and distinct from the
commissions earned by our dually licensed Associated Persons.
Receipt of commission-based compensation presents a conflict of interest because our firm and persons providing
investment advice on behalf of our firm who are licensed insurance agents have an incentive to recommend
insurance products to you for the purpose of generating commissions rather than recommendations made solely
based on your needs. We address this conflict of interest by recommending insurance products only where we,
in good faith, believe that it is suitable for the client’s particular needs and circumstances and only after a full
presentation of the recommended insurance product to our client. In addition, we explain the insurance
underwriting process to our clients in illustrating how the insurer also reviews the client’s application and
disclosures prior to the issuance of a resulting insuring agreement. Ultimately, all insurance sales are on a non-
discretionary basis and are offered by duly licensed and supervised insurance professionals by our affiliated entity.
Clients are under no obligation contractually or otherwise, to purchase insurance products through any person or
entity affiliated with our firm.
Tax and Accounting Services
Market Tax Services, LLC is our affiliated accounting and tax preparation firm. Certain of our Associated Persons
also provide tax and accounting services through Market Tax Services, LLC and receive compensation for these
activities. In addition, all accounting and tax preparation services included in our advisory services are provided
by Market Tax Services, LLC. Clients are under no obligation contractually or otherwise, to obtain accounting and
tax preparation services through any person or entity affiliated with our firm.
Human Resource Outsourcing Services
Market HR Services, LLC is our affiliated human resource and payroll outsourcing firm. Certain of our Associated
Persons also provide services through Market HR Services, LLC and receive compensation for these activities.
Clients are under no obligation contractually or otherwise, to obtain human resource and payroll outsourcing
services through any person or entity affiliated with our firm.
Legal Services
Although our firm and Associated Persons are not attorneys, our firm has formed an alliance with Eidelman Law
Firm, an unaffiliated law firm, to provide clients with estate planning and other legal services. We actively
recommend the service of Eidelman Law Firm to clients who express a need to obtain estate planning and other
legal services. Certain Associated Persons of our firm also provide operational support services to Eidelman Law
Firm. All compensation received by Eidelman Law Firm for legal services is separate from and in addition to fees
paid to MIG. Clients are under no obligation contractually or otherwise, to obtain legal services through Eidelman
Law Firm.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11
Description of Our Code of Ethics
MIG has adopted a Code of Ethics (the “Code”) to address investment advisory conduct. The Code focuses
primarily on fiduciary duty, personal securities transactions, insider trading, gifts, and conflicts of interest. The
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Code includes MIG’s policies and procedures developed to protect clients’ interests in relation to the following
topics:
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▪
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The duty at all times to place the interests of clients first;
The requirement that all personal securities transactions be conducted in such a manner as to be
consistent with the code of ethics;
The responsibility to avoid any actual or potential conflict of interest or misuse of an employee’s
position of trust and responsibility;
The fiduciary principle that information concerning the identity of security holdings and financial
circumstances of clients is confidential; and
The principle that independence in the investment decision-making process is paramount.
A copy of MIG’s Code of Ethics is available upon request to Eva Lund, Compliance Designee, at (816) 548-2000 or
at ria-info@marketadvisorygroup.com.
Personal Trading Practices
At times, MIG and/or its Advisory Representatives may take positions in the same securities as clients. This is
considered a conflict of interest with clients. MIG and its Advisory Representatives will generally be “last in” and
“last out” for the trading day when trading occurs in close proximity to client trades, however, we will uphold our
fiduciary responsibilities to our clients. Front running (trading shortly ahead of clients) is prohibited. Should a
conflict occur because of materiality (e.g., a thinly traded stock), disclosure will be made to the client(s) at the
time of trading. Mutual fund purchases are not subject to these policies because the transactions are executed at
NAV at the end of the trading day.
Where client accounts are managed by a sub-adviser, the firm and persons associated with the firm would not
necessarily be aware of timing of trades being considered prior to the transaction. However, where the firm
and/or its Associated Persons are aware that a sub-adviser is considering specific transactions for clients’ accounts
on a specific trading day where there is a potential material conflict, they will make every effort to be “last in”
and “last out” for the trading day when trading occurs in close proximity to client trades.
Brokerage Practices - Item 12
MIG does not maintain custody of your assets that we manage, although we will be deemed to have custody of
your assets if you give us authority to directly 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, bank, or trust
company, for example. We primarily recommend that our clients use Charles Schwab & Co., Inc. (“Schwab”), a
registered broker-dealer, member SIPC, as the qualified custodian.
The primary factor in suggesting a broker/dealer or custodian is that the services of the recommended firm are
provided in a cost-effective manner. While quality of execution at the best price is an important determinant,
best execution does not necessarily mean lowest price and it is not the sole consideration. The trading process of
any broker/dealer suggested by MIG must be efficient, seamless, and straight-forward. Overall custodial support
services, trade correction services, and statement preparation are some of the other factors determined when
suggesting a broker/dealer.
Products and Services Available to Us from Schwab
Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like ours. They
provide our clients and us with access to their institutional brokerage services (trading, custody, reporting, and
related services), many of which are not typically available to Schwab retail customers. However, certain retail
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investors may be able to get institutional brokerage services from Schwab without going through us. Schwab also
makes available various support services. Some of those services help us manage or administer our clients’
accounts, while others help us manage and grow our business. Schwab’s support services are generally available
on an unsolicited basis (we don’t have to request them) and at no charge to us.
Services that Benefit You: Schwab’s 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 include some to which we might not otherwise have access or that would require a significantly
higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit
you and your account.
Services that Do Not Directly Benefit You: Schwab also makes available to us other products and services that
benefit us but do not directly benefit you or your account. These products and services assist us in managing and
administering our clients’ accounts and operating our firm. They include investment research, both Schwab’s own
and that of third parties. We use this research to service all or a substantial number of our clients’ accounts,
including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available
software and other technology that:
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•
•
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 also offers other services intended to help us manage and further
develop our business enterprise. These services include:
Educational conferences and events
Publications and conferences on practice management and business succession
•
• Consulting on technology and business needs
• Consulting on legal and compliance-related needs
•
• Access to employee benefits providers, human capital consultants, and insurance providers
• Marketing consulting and support
• Recruiting and custodial search consulting
Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the
services to us. Schwab also discounts or waives its fees for some of these services or pays all or a part of a third
party’s fees. Schwab also provides us with other benefits, such as occasional business entertainment for our
personnel. If you did not maintain your account with Schwab, we would be required to pay for those services
from our own resources.
MIG understands its duty for best execution and considers all factors in making recommendations to clients. These
research services may be useful in servicing all MIG clients and may not be used in connection with any particular
account that may have paid compensation to the firm providing such services. While MIG may not always obtain
the lowest commission rate, MIG believes the rate is reasonable in relation to the value of the brokerage and
research services provided.
The availability of the above-listed services from Schwab benefits us because we do not have to produce or
purchase them. We don’t have to pay for Schwab’s services.
Schwab has also agreed to pay for certain technology, research, marketing, and compliance consulting products
and services on our behalf once the value of our clients’ assets in accounts at Schwab reaches certain thresholds.
The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab rather
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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 Schwab as custodian and broker is in the best interests of our clients.
Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How We Select
Brokers/Custodians”) and not Schwab’s 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
MIG allows clients to direct brokerage. MIG may be unable to achieve most favorable execution of client
transactions if clients choose to direct brokerage. This may have a higher cost for clients because without the
ability to use Schwab, MIG will not be able to aggregate orders to reduce transactions costs, resulting in higher
brokerage commissions and less favorable prices. Not all investment advisers allow their clients to direct
brokerage.
Aggregation of Orders (Block Trading)
When suitable, our firm and/or the sub-adviser will combine multiple orders for shares of the same securities
purchased for advisory accounts we manage (this practice is commonly referred to as “block trading”). The shares
are then distributed across participating accounts in a fair and equitable manner. The distribution of the shares
purchased is typically proportionate to the size of the account, but it is not based on account performance or the
amount or structure of management fees. Accounts owned by our firm or persons associated with our firm may
participate in block trading with your accounts; however, they will not be given preferential treatment. We do
not combine multiple orders for shares of the same mutual funds purchased for advisory accounts we manage
because mutual funds do not trade in blocks.
Review of Accounts - Item 13
Accounts are reviewed by the Associated Person named as adviser of record on the account. The frequency of
reviews is determined based on the client’s investment objectives, but reviews are conducted no less frequently
than annually. Additional reviews are usually triggered by a change in the client’s investment objectives, tax
considerations, large deposits or withdrawals, large purchases or sales, loss of confidence in corporate
management, or changes in macro-economic climate.
A financial plan is a snapshot in time and no ongoing reviews are conducted, unless you have engaged us for
periodic updates. We recommend a plan review at least annually. Unless otherwise agreed, the plan review will
be subject to an additional fee.
The client’s independent custodian provides account statements directly to the client no less frequently than
quarterly. Sub advisers will also provide clients with performance reports on at least a quarterly basis. The
custodian’s statement is the official record of the client’s securities account and supersedes any statements or
reports created on behalf of the client by MIG.
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Client Referrals and Other Compensation - Item 14
Economic Benefits Received from Non-Clients for Providing Investment Advice to Clients
Economic Benefits Received from Custodians
MIG has brokerage and clearing arrangements with Schwab. MIG may receive additional benefits from these firms
in the form of electronic delivery of client information, electronic trading platforms, institutional trading support,
proprietary and/or third-party research, continuing education, practice management advice, and other services
provided by custodians for the benefit of investment advisory clients. Please refer to item 12 above for more
information about the receipt of additional benefits from broker-dealers/account custodians.
Economic Benefits Received from Vendors
In some cases, MIG and Associated Persons receive additional compensation from product sponsors and vendors,
Including Foundations Investment Advisors LLC and Magellan Financial & Insurance Services, Inc., its affiliated
insurance marketing organization. Compensation could include such items as gifts valued at less than $500
annually; an occasional dinner or ticket to a sporting event; reimbursement in connection with educational
meetings with an Associated Person, reimbursement for compliance consulting services, client workshops, or
events; marketing events, advertising initiatives, including services for identifying prospective clients. Product
sponsors may also pay for or reimburse MIG for the costs associated with MIG’s Associated Persons attending
various education or training events, as well as MIG sponsored conferences and events. This represents a conflict
of interest because we are incentivized to use vendors based on benefits received, rather than our clients’ needs.
We address this conflict of interest by recommending vendors that we, in good faith, believe are appropriate for
the client’s particular needs. Clients are under no obligation contractually or otherwise, to use any of the vendors
recommended by us.
Economic Benefits Received from Product Sponsors
Product sponsors such as mutual fund, ETF and annuity companies may pay for or reimburse MIG for the costs
associated with the firm’s employees and investment adviser representatives attending various education or
training events, as well as MIG’s sponsored conferences and events.
The receipt of additional economic benefits presents a conflict of interest because our firm and Associated
Persons have an incentive to recommend and use vendors based on the additional economic benefits obtained
rather than solely on the client’s needs. We address this conflict of interest by recommending vendors that we,
in good faith, believe are appropriate for the client’s particular needs. Clients are under no obligation
contractually or otherwise, to use any of the vendors recommended by us.
Sale of Insurance Products
Associated Persons of MIG will solicit, offer, and sell insurance products to you for commissions in their separate
capacity as insurance agents. This represents a conflict of interest since our Associated Persons have an incentive
to recommend insurance products based on the commissions received rather than solely on the client’s needs.
We address this conflict of interest by recommending insurance products that we, in good faith, believe are
suitable for the client’s particular needs. You are under no obligation to implement recommendations through
your Associated Persons and are free to choose any insurance company you wish to implement the
recommendations.
Compensation for Client Referrals
MIG does not engage promoters or otherwise compensate third parties for client referrals.
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Custody - Item 15
We do not have physical custody of any client funds and/or securities. The client will be asked to authorize the
sub-adviser with the ability to instruct the custodian to deduct the management fees directly from the account.
This is considered a form of custody. The client may terminate this authorization at any time by contacting MIG.
The client will receive at least quarterly account statements from the qualified custodian that holds and maintains
the account. The account statements from the qualified custodian will indicate the amount of the management
fee deducted from the account each billing period.
With respect to third party standing letters of authorization (“SLOA”) where a client grants us authority to direct
custodians to disburse funds to one or more third party accounts, we are deemed to have custody pursuant to
Rule 206(4)-2 (the “Custody Rule”). We have taken steps to have controls and oversight in place to comply with
the no-action letter issued by the SEC on February 21, 2017 (the “SEC no-action letter”). We are not required to
comply with the surprise examination requirements of the Custody Rule if we comply with the representations
noted in the SEC no-action letter. Where our firm acts pursuant to a SLOA, we believe we are making a good faith
effort to comply with the representations noted in the SEC no-action letter. Additionally, since many of the
representations noted in the SEC no-action letter involve the qualified custodian’s operations, we will collaborate
closely with our custodian(s) to ensure that the representations are met.
Your funds and securities will be held with a bank, broker-dealer, or other independent, qualified custodian. You
will receive account statements from the independent, 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. You should carefully review account statements for accuracy. We urge you to
compare the account statements received directly from the custodians to any performance report statements
prepared by MIG or the sub-adviser. If you have questions regarding your account or if you did not receive a
statement from your custodian, please contact us at (316) 252-8707 or at ria-info@marketadvisorygroup.com.
Investment Discretion - Item 16
MIG’s portfolio management services are offered on a discretionary and in limited cases, non-discretionary basis.
This authority is granted to us by you in the Asset Management Agreement. This allows our firm and/or the sub-
adviser to choose the quantity of the securities to be purchased or sold and whether to place buy or sell orders
for your account without obtaining your approval for each transaction.
Non-discretionary portfolio management service means that we must obtain your approval prior to making any
transactions in your account.
If you wish, you may limit our discretionary authority by, for example, setting a limit on the type of securities that
can be purchased for your account. Simply provide us with your restrictions or guidelines in writing. Please refer
to the “Advisory Business” section in this Brochure for more information on our discretionary management
services.
Voting Client Securities - Item 17
MIG does not vote proxies. It is the client's responsibility to vote proxies. Clients will receive proxy materials
directly from the custodian. Questions about proxies may be made via the contact information on the cover page.
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Financial Information - Item 18
We are required in this Item to provide you with certain financial information or disclosures about MIG’s, financial
condition. MIG does not require the prepayment of over $1,200, six or more months in advance. Additionally,
MIG has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to
clients, and MIG has not been the subject of a bankruptcy proceeding.
Requirements of State-Registered Advisers - Item 19
This section is not applicable because our firm is SEC-registered.
Market Investment Group, LLC Privacy Policy Notice
This notice is being provided to you in accordance with the Securities and Exchange Commission’s rule regarding
the privacy of consumer financial information (“Regulation S-P”). Please take the time to read and understand
the privacy policies and procedures that we have implemented to safeguard your nonpublic personal information.
•
•
•
Information We Collect
Market Investment Group, LLC must collect certain personally identifiable financial information about its
customers to provide financial services and products. The personally identifiable financial information that we
gather during the normal course of doing business with you may include:
information we receive from you on applications or other forms;
information about your transactions with us, our affiliates, or others;
information we receive from a consumer reporting agency.
Information We Disclose
We do not disclose any nonpublic personal information about our customers or former customers to anyone,
except as permitted or required by law, as necessary to provide services to you or if you have given us permission
in writing. In accordance with Section 248.13 of Regulation S-P, we may disclose all of the information we collect,
as described above, to certain nonaffiliated third parties such as our attorneys, accountants, auditors and persons
or entities that are assessing our compliance with industry standards. We enter into contractual agreements with
all nonaffiliated third parties that prohibit such third parties from disclosing or using the information other than
to carry out the purposes for which we disclose the information.
Regulation S-AM: Under Regulation S-AM, we are prohibited from using eligibility information that we receive
from an affiliate to make a marketing solicitation unless: (1) the potential marketing use of that information has
been clearly, conspicuously and concisely disclosed to the consumer; (2) the consumer has been provided a
reasonable opportunity and a simple method to opt out of receiving the marketing solicitations; and (3) the
consumer has not opted out.
Market Investment Group, LLC, Market Tax Services, LLC, Market Advisory Group, LLC, MAG Life, LLC, Market HR
Services, LLC, and Market Medicare Advisers, LLC share eligibility information obtained from clients with each
other to make marketing solicitations. We also share eligibility information obtained from clients with Eidelman
Law Firm, an unaffiliated law firm.
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Regulation S-ID: Regulation S-ID requires our firm to have an Identity Theft Protection Program (ITPP) that
controls reasonably foreseeable risks to customers or to the safety and soundness of our firm from identity theft.
We have developed an ITPP to adequately identify and detect potential red-flags to prevent and mitigate identity
theft.
Confidentiality And Security
We restrict access to nonpublic personal information about you to those Employees who need to know that
information to provide financial products or services to you. We maintain physical, electronic, and procedural
safeguards that comply with federal standards to guard your nonpublic personal information.
Accuracy
Market Investment Group, LLC strives to maintain accurate personal information in our client files at all times.
However, as personal situations, facts and data change over time; we encourage our clients to provide feedback
and updated information to help us meet our goals.
Contact US
If you have any questions about our privacy policies, or if you do not want to allow us, our affiliated insurance
firms, or our affiliated tax and accounting practice to share your information with each other or with or Eidelman
Law Firm, to make marketing solicitations, please contact Eva Lund, Compliance Designee, at (816) 548-2000 or
at ria-info@marketadvisorygroup.com.