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Marquette Asset Management, LLC d/b/a
Marquette Wealth Management
150 South Fifth Street, Suite 2800
Minneapolis, MN 55402
612-661-3770
www.marquettewm.com
COVER PAGE - FORM ADV PART 2A
DISCLOSURE BROCHURE
March 31, 2026
This Brochure provides information about the qualifications and business practices of Marquette
Asset Management, LLC doing business as Marquette Wealth Management (“Marquette”).
Marquette is a Minneapolis-based investment adviser registered with the Securities and
Exchange Commission (“SEC”) under the Investment Advisers Act of 1940.
The information in this Brochure has not been approved or verified by the SEC or by any state
securities authority. Registration of an investment adviser does not imply any level of skill or
training. Additional information about Marquette is also available on the SEC’s website at
www.adviserinfo.sec.gov.
Please contact Christopher Vernier, Marquette’s Chief Compliance Officer, at 612-661-3787 or
chris.vernier@marquettewm.com with any questions about the contents of this Brochure.
III
ITEM 2 – MATERIAL CHANGES
We are required to provide clients with information on any material changes made to our
Brochure since our last update on March 31, 2025.
There have been no material changes.
We will provide clients with a new Brochure as necessary based on changes or new
information, at any time, without charge.
To request a Brochure, contact Christopher Vernier, Marquette’s Chief Compliance Officer, at
612-661-3787 or chris.vernier@marquettewm.com.
Additional information about Marquette is also available via the SEC’s website
www.adviserinfo.sec.gov. The SEC’s website also provides information on all persons affiliated
with Marquette who are registered as investment adviser representatives of Marquette.
IV
ITEM 3 – TABLE OF CONTENTS
COVER PAGE - FORM ADV PART 2A ........................................................................................................ III
ITEM 2 – MATERIAL CHANGES ................................................................................................................. IV
ITEM 3 – TABLE OF CONTENTS ................................................................................................................. V
ITEM 4 – ADVISORY BUSINESS ................................................................................................................. 6
ITEM 5 – FEES AND COMPENSATION ....................................................................................................... 8
ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ..................................... 9
ITEM 7 – TYPES OF CLIENTS ..................................................................................................................... 9
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ....................... 9
ITEM 9 – DISCIPLINARY INFORMATION .................................................................................................. 11
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ....................................... 11
ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND
PERSONAL TRADING ................................................................................................................................ 11
ITEM 12 – BROKERAGE PRACTICES ...................................................................................................... 12
ITEM 12.B – BROKERAGE PRACTICES – AGGREGATED TRADE ORDERS ...................................... 16
ITEM 13 – REVIEW OF ACCOUNTS .......................................................................................................... 16
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION .......................................................... 17
ITEM 15 – CUSTODY .................................................................................................................................. 17
ITEM 16 – INVESTMENT DISCRETION ..................................................................................................... 18
ITEM 17 – VOTING CLIENT SECURITIES ................................................................................................. 18
ITEM 18 – FINANCIAL INFORMATION ...................................................................................................... 19
FORM ADV PART 2B .................................................................................................................................. 20
V
ITEM 4 – ADVISORY BUSINESS
History and Ownership
Marquette Wealth Management (“Marquette”) is a Minneapolis-based investment adviser
registered with the SEC under the Investment Advisers Act of 1940.
We were founded in 2005 as a wholly owned subsidiary of Marquette Financial Companies, a
diversified financial services firm owned by the Carl R. Pohlad family. As part of a major
restructuring, the Marquette Financial Companies were acquired by UMB Financial
Corporation, a publicly held bank holding company headquartered in Kansas City, in May 2015.
Returning to our roots as an independent, privately held boutique wealth management firm,
Marquette was purchased at the end of 2017 by Marquette Wealth Management, LLC, an
entity owned by its President, Christopher M. Vernier.
Mission
Our mission is to maximize your wealth, so you feel confident in your financial future.
Financial Planning and Investment Management
Our primary advisory services are financial planning and investment management. Generally,
Marquette manages all a client’s investable assets, however some engage us to manage only
one portion with a specific investment goal. Regardless of the engagement, we encourage and
provide the opportunity for all clients to experience our financial planning process. This gives
us a better understanding of our clients’ financial situations and enables us to give our best
advice and service.
This comprehensive approach to financial planning and investment management helps clients
define the purpose of their wealth and make informed financial decisions. With client
cooperation and assistance, we construct and maintain a current balance sheet and offer tools
to organize assets, liabilities, income, and expenses on an ongoing basis. We discuss
retirement planning, education planning, estate planning, charitable giving, and tax
considerations with clients as well. This information, along with discussion of values, goals, risk
tolerance and time horizon, drives our recommendations to clients regarding asset allocation
and portfolio construction. We help develop and establish an Investment Policy Statement for
clients to guide their plan and keep their strategy on track.
In certain situations, our clients wish to have professional administration of their personal trust
accounts. In those circumstances, we work with the family to designate a Directed Trustee to
administer those accounts, and we will serve as the Investment Trust Advisor. We recommend
that clients name Bell Bank as the Directed Trustee whenever possible.
We also provide various consulting services to qualified employee benefit plans and their
fiduciaries. These services are designed to assist plan sponsors in administering and
managing their corporate retirement plans. Certain services are provided by Marquette or a
fiduciary under the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”). ERISA is the comprehensive federal law that governs the operation and
administration of private pension and welfare benefits plans. In accordance with ERISA Section
408(b)(2), each plan sponsor is provided with a written description of Marquette’s fiduciary
status, the specific services to be rendered, and all direct and indirect compensation the Firm
reasonably expects under the engagement.
Wealth management relationships frequently include retirement accounts. ERISA Prohibited
Transaction Exemption 2020-02 (“PTE 2020-02”) requires that retirement-related
recommendations be in the best interest of retirement investors and that conflicts of interest be
eliminated or mitigated. As an SEC-registered investment adviser, we continue to be subject to
these requirements. We provide information acknowledging our fiduciary status and enhanced
descriptions of the services we will provide and fees we will charge as required by the PTE
2020-02 exemption through the Retirement Disclosure. Where we recommend a rollover of
qualified plan assets, we also provide an explanation of our rationale for why the
recommendation is in the client’s best interest.
Our Process
1. Understand: We work with clients to understand their life goals, financial objectives,
comfort with risk, current and anticipated tax situation, cash-flow and liquidity needs,
and estate planning considerations. We collaborate with their attorney and accountant
where appropriate.
2. Design: We develop a personalized financial plan and design an investment portfolio
which reflects each client’s goals, risk profile and cash flow needs. We establish a
written Investment Policy Statement for clients. The Investment Policy Statement
defines goals and identifies asset classes to be used in structuring the portfolio.
3. Implement: We construct and manage portfolios in accordance with the Investment
Policy Statement. Where appropriate, we phase in investment recommendations over
time to manage tax ramifications.
4. Monitor and Supervise: We oversee the management of client portfolios. We evaluate
progress against clients’ goals. We offer ongoing performance reporting via our client
portal. We meet with clients regularly to stay on top of their evolving needs and goals.
We proactively keep clients and their attorney and accountant abreast of notable
developments and help evaluate alternatives and opportunities. We regularly review the
asset allocation and strategy to remain on target.
Each client is assigned a team who provides ongoing administrative service and offers
comprehensive wealth management.
We manage portfolios by balancing risk and expected return. We believe strongly in building
portfolios which are well diversified within and among asset classes. An asset class is a group
of securities that shares similar characteristics, behave similarly in the marketplace and are
subject to the same rules and regulations. The most common asset classes are fixed income,
equity securities, cash, real assets, and alternative investments. Real assets include
investments such as real estate and precious metals while alternative investments currently
include private equity investments, reinsurance funds and master limited partnerships (MLPs).
We recommend a custom target allocation based on each client’s unique situation. Portfolios
are then constructed with bonds, exchange traded funds (ETFs), mutual funds, and where
appropriate, real and/or alternative assets. We will hold individual stock positions for clients
upon request.
We maintain sub-advisory arrangements as needed when an appropriate mutual fund or
exchange traded fund vehicle is not available to achieve the goals of the Investment Policy
Statement.
As of December 31, 2025, we had $872 million in assets under our discretionary management.
The value of assets under management is based on the market value of all assets held in
discretionary portfolios.
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Prices for individual stocks, bonds, mutual funds, exchange traded funds and certain
alternative investments are generally obtained from our accounts’ custodians. To the extent an
asset is not priced by one of our custodians, our portfolio reporting and trading provider,
Envestnet, provides values if the security is held elsewhere on its platform. If a price is not
available from either of these sources, we will obtain a price from sources deemed reliable.
We obtain the market value of nonmarketable securities, if any, reflected in our reports from
sources deemed to be reliable. Our market valuation methodology for those alternative
investments is disclosed to participants on an annual basis. We had $4.6 million of
discretionary assets in such nonmarketable alternative investments as of December 31, 2025.
ITEM 5 – FEES AND COMPENSATION
Wealth management relationships
Our standard annual fee for wealth management relationships is based on the market value of
assets managed as follows:
1.00% on the first $3,000,000
0.75% on the next $2,000,000
0.50% thereafter
We will consider accounts within a family relationship as combined for fee calculation purposes
in appropriate cases. We reserve the right to charge additional fees for extraordinary services.
We offer a 10% discount on portfolios for charitable and non-profit entities.
Neither our firm nor its employees receive 12b-1 fees, loads, or kickbacks, nor do we benefit in
any way from other types of fee-sharing arrangements from the funds or other providers we
utilize on our clients’ behalf.
Our fees do not include fund-level management or administrative fees, trading expenses
charged by brokers, custodians, mutual funds, exchange traded funds or other third-party
managers.
Investment trust advisor accounts
Our standard annual fee for Investment Trust Advisor accounts is based on the market value of
assets managed as follows:
1.15% on the first $3,000,000
0.90% on the next $2,000,000
0.65% thereafter
Less the investment trust advisor fee charged by Bell Bank.
Self-directed accounts
We may allow clients to open self-directed accounts to hold securities for which we have no
investment responsibility or discretion. We reserve the right to charge an annual fee of 0.10%
of the market value to cover administrative expenses.
Calculation and Billing Process
Our annual fee is charged quarterly, in arrears. Wealth management fees for accounts held at
Schwab are charged based on the average daily market value of the assets and cash in the
account during the prior calendar quarter. The average daily balance of funds borrowed on
margin against the holdings of the account (“margin balance”) are added back to the account
for purposes of determining the average daily market value of the account.
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Investment trust advisor fees for accounts held at Bell Bank are charged monthly or quarterly
based on the average daily market value of the assets and cash in the account during the prior
period.
Our fees for accounts held elsewhere are charged at the end of each calendar quarter based
on the market value of the assets and cash in the account on the last day of the calendar
quarter.
If an account is opened after the start of, or terminated prior to the end of, a quarter, the fee for
such quarter is prorated based on the number of days during the quarter the account is open.
Quarterly fees for accounts held elsewhere are pro-rated to reflect inflows or outflows in
excess of 10% of the value on the first day of the quarter.
Fee rates are guaranteed for a period of one (1) year after the investment management
agreement is signed by us. Thereafter, fees may be changed with thirty (30) days’ written
notice.
Other fees and expenses
Schwab serves as our preferred qualified custodian for our clients’ accounts. To the extent
Schwab imposes a trading fee, clients are responsible for paying the expenses from their
accounts. Other fees, such as most cashiering and market-value-based fees for principal and
income accounting for certain agency accounts, are included in the fees we charge. Clients
pay Schwab a flat custody fee for certain alternative assets, an $8.50 overnight check fee, and
$25 processing fee for wire transfers requiring paper-based authorizations or Docusign.
Clients are not required to use Schwab as the custodian for their account and may negotiate
such services and fees with other custodians of their choice. We reserve the right to charge
additional fees as appropriate if clients choose a custodian other than Schwab.
ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
We do not charge Performance Based Fees.
ITEM 7 – TYPES OF CLIENTS
We provide wealth management services to high net worth and other individuals and their
trusts, private foundations, donor-advised funds, and other entities.
We provide portfolio management services to 401(k) and profit-sharing plans, charitable
institutions, corporations, business entities, foundations, and donor advised funds.
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
Our investment philosophy is based on years of empirical research. It underlies an investment
approach designed to reduce subjective biases, focus on factors with higher expected returns
and deliver sustainable, long-term value for our clients.
Our investment approach focuses on client goals; we implement solutions to achieve those
goals and remain disciplined through periods of market volatility. Client portfolios and asset
allocations are utilized to reflect the goals, risk preference, cash flow needs, tax situation and
estate plans.
Most of our clients utilize a global asset allocation approach to achieve their goals, though we
do manage accounts that are focused exclusively on the U.S. markets. Our disciplined process
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recognizes that active management can provide advantages as compared to a passive,
capitalized weighted index approach toward investing. Those advantages are more
recognizable in less efficient parts of the market, namely small capitalization stocks, emerging
markets, and fixed income.
In constructing portfolios, systematic, factor-based investing is considered an active strategy
and differs significantly from generic index-based strategies despite broad based terms like
“value”, “growth”, “quality” or “momentum”.
Our due diligence process emphasizes fund managers and styles of investing which have
shown discipline, consistency, transparency, reasonable fees, and tax awareness. We
incorporate both quantitative and qualitative factors in our analysis and maintain a rigorous,
detailed approach and long-term view to creating the solutions necessary to meeting a client’s
objectives.
In constructing a portfolio, we create well-defined, diversified portfolios across a variety of
asset classes that would be consistent with a targeted level of risk. Individual portfolio
allocations are based on the risk characteristics and correlations between different asset
classes.
Specific investment strategies are implemented using an optimal combination of mutual funds,
exchange traded funds and individual securities where appropriate. We use subadvisors to
manage portfolios for clients who choose to focus some or all their investments in companies
managed to achieve enhanced environmental, social and/or governance (“ESG”) objectives or
other values-aligned investing.
Typical asset classes include U.S. equities across the market capitalization spectrum from
Micro to Large, International equities including emerging markets and Fixed Income where it
fits a need.
Risk of Loss
Investing involves taking risks. Not investing also involves risks. If clients are not exposed to
the securities markets, they will not participate in the price appreciation those markets
experience over long periods of time.
Simply put, investment risk can be defined as fluctuation in price. For individuals, price
fluctuations pose two types of risk:
• Objective Risk: how much loss of value can be sustained in the short-to-medium term
and still meet long-term objectives?
• Subjective risk: how much loss of value can be endured without serious harm to a
client’s emotional well-being and ability to sleep at night?
Investment risk is comprised of numerous individual risks which can be classified into two
general categories: systematic and unsystematic risk.
Systematic risk, also known as market risk, relates to broad factors that affect the overall
economy or financial markets. It cannot be attributable to the specific risk of individual
investments. Systematic risk affects all securities, although in different proportions, and is both
unpredictable and impossible to completely avoid. Common examples of systematic risk
include:
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• macroeconomic risk factors such as changes in interest rates, inflation, fluctuations in
currencies, recessions, etc.
• geopolitical risk factors including instability or unrest in one or more regions of the world
including terrorist attacks, wars, pandemics, etc.
Though systematic risk cannot be avoided, it can be managed by holding portfolios which
include a variety of asset classes while maintaining exposure across global markets.
Unsystematic risk, also known as specific or diversifiable, is a risk unique to a specific
company, industry, or product. Common examples of unsystematic risk include:
• business risks including management or operational risk, product risk, obsolescence
risk
regulatory risk
•
• credit or balance sheet risk
Unsystematic risk can be reduced through a diversified investment portfolio. Our philosophy
and process of constructing well diversified portfolios amongst and within asset classes
including geographic diversity is consistent with reducing this type of risk.
All portfolios involve investing in securities which present a risk of loss that clients should be
prepared to bear.
ITEM 9 – DISCIPLINARY INFORMATION
Registered investment advisers are required to disclose all material facts regarding any legal
or disciplinary events that would be material to an evaluation of Marquette or the integrity of the
firm.
Marquette has no legal or disciplinary events to report.
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
As noted in Item 4, Marquette maintains sub-advisory agreements with other registered
investment advisors. We use these advisers to diversify portfolios across asset classes not
provided by Marquette. Marquette does not receive compensation from these advisors.
Marquette has no other financial industry affiliations.
ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
AND PERSONAL TRADING
We have a formal Code of Ethics (“Code”). The purpose of the Code is to reinforce the
fiduciary principles that govern conduct. All employees, interns, and contract employees, are
access persons and must act in the best interest of the client, avoid any real or potential
conflicts of interest and conduct their personal activities with the utmost integrity. Following is a
summary of the Code:
1. The Code contains standards of business conduct including prohibitions on insider
trading, fraudulent or deceptive acts and statements, and the malicious creation or
spreading of rumors. Employees are subject to restrictions on certain outside activities,
securities transactions, and gifts to and from clients, broker-dealers, vendors, or
research providers.
2. The Code requires compliance with federal securities laws.
3. The Code requires review and reporting of personal securities transactions.
4. The Code obligates employees to report violations and Marquette to enforce sanctions.
5. The Codes requires annual acknowledgement by employees of the provisions of the
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Code as amended from time to time.
The Code is designed to ensure that the personal securities transactions, activities, and
interests of our employees will not interfere with (i) making decisions in the client’s best interest
and (ii) implementing such decisions while, at the same time, allowing employees to invest for
their own portfolios.
When we have been given full investment discretion over employees’ portfolios, and a firm-
wide asset allocation change is made, those portfolios are aggregated, with client portfolios. In
such circumstances, employee and client portfolios receive securities at a total average price.
Completed orders are allocated as specified in the initial trade order. Partially filled orders are
allocated on a pro rata basis.
Unless an employee has given full-investment discretion to us, our Code requires pre-
clearance of employee transactions and prohibits employees from buying or selling securities
on the same day as clients. The Code designates certain classes of securities transactions as
exempt from this requirement, based upon a determination that such transactions would not
materially interfere with clients’ best interest.
Employee trading is continually monitored under the Code to reasonably prevent conflicts of
interest between Marquette’s employees and its clients.
Clients or prospective clients may obtain a copy of the Code by contacting Christopher Vernier,
our Chief Compliance Officer, at 612-661-3787 or chris.vernier@marquettewm.com.
We will not execute any principal or agency cross-securities transactions in client portfolios.
Principal transactions are generally defined as transactions where an adviser, acting as
principal for their own account or the account of an affiliated broker-dealer, buys from or sells
any security to any advisory client. A principal transaction may also be deemed to have
occurred if a security is crossed between an affiliated fund and another client portfolio. An
agency cross transaction is defined as a transaction where a person acts as an investment
adviser in relation to a transaction in which the investment adviser, or any person controlled by
or under common control with the investment adviser, acts as broker for both the advisory
client and for another person on the other side of the transaction. Agency cross transactions
may arise where an adviser is dually registered as a broker-dealer or has an affiliated broker-
dealer. Marquette is not dually registered as, or affiliated with, a broker-dealer.
ITEM 12 – BROKERAGE PRACTICES
We generally have two types of client portfolios, full discretion and directed. In full discretion
portfolios, we possess sole authority with respect to transactions, timing of transactions and
choice of brokers. Such authority can be limited by clients at any time with respect to any or all
such factors.
We may allow clients to maintain self-directed accounts when such accounts are merely part of
an overall wealth management relationship. Clients may execute trades directly with Schwab in
those accounts or may direct us to initiate trades on their behalf. We will use the same brokers
for those trades as we use for discretionary trades.
The Custodians and Brokers We Use
We do not maintain custody of the assets we manage; however, we may be deemed by our
regulators to have custody of assets if we have authority to withdraw assets from client
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accounts (see Item 15 Custody, below). Client assets must be maintained in an account at a
“qualified custodian,” generally a broker-dealer or bank.
We recommend our wealth management clients use Schwab, a FINRA-registered broker-
dealer and member SIPC, as the qualified custodian. We are not affiliated with Schwab.
Schwab will hold client assets in a brokerage account and will buy and sell securities via our
instructions. While we recommend that clients use Schwab as custodian/broker, clients decide
whether to do so and will open accounts with Schwab by entering into an account agreement
directly with them. Even though client accounts are maintained at Schwab, we can still use
other brokers that can be used to execute trades, as described later in this section.
Occasionally, clients name us as Investment Trust Advisor for personal trust accounts of which
Bell Bank serves as Directed Trustee. Bell Bank serves as qualified custodian for those
accounts.
How We Select Brokers/Custodians
We seek to recommend a custodian/broker who will hold client assets and execute
transactions on terms that are most advantageous to clients overall when compared to other
available providers and their services.
A wide range of factors are considered, including but not limited to:
• A combination of transaction execution services along with asset custody services
(generally without a separate fee for custody)
• capability to execute, clear and settle trades (buy and sell securities for client accounts)
• ability to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
• breadth of investment products made available (stocks, bonds, mutual funds, exchange
traded funds (ETFs), etc.)
• quality of services including its commitment to cybersecurity
• competitiveness of the price of those services (commission rates, margin interest rates,
other fees, etc.) and willingness to negotiate them.
reputation, financial strength, and stability of the provider
•
• ability to get the best price
• knowledge of market, securities, and industries, and
• of other products and services that benefit us, as discussed below (see “Products and
Services Available to Us from Schwab”)
Custody and Brokerage Costs
Schwab generally does not charge separately for custody services, nor does it charge
commissions on trades that we execute in clients’ Schwab accounts. Schwab charges a flat
dollar amount as a “prime broker” or “trade away” fee for each trade we execute with a different
broker-dealer. This fee does not apply to mutual funds managed by Schwab and other
companies with which Schwab has an agreement. These fees are in addition to the
commissions or other compensation paid to the executing broker dealer.
Bell Bank receives a commission for equity trades that it executes for trust accounts where it
serves as Directed Trustee. The commission rate is currently $.05/share. Bell does not charge
a separate “prime broker” or “trade away” fee.
Clients who select the broker to use for executing their transactions may eliminate or reduce
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our ability to negotiate commissions and otherwise obtain the best price and execution.
Products and Services Available to Us from Schwab
Schwab serves many independent investment advisory firms like us. They provide access to
their institutional brokerage, trading, custody, reporting and related services. Many of which are
not typically available to Schwab retail customers. Schwab also makes available various
support services. Some of those services help manage or administer client accounts while
others help us manage and grow our business. Schwab’s support services are generally
available on an unsolicited basis and at no charge if a total of at least $10 million of client’s
assets are held in accounts at Schwab. If the minimum is not met, Marquette may be subject to
a quarterly service fee.
Below is a more detailed description of Schwab’s support services:
Services that Benefit Clients.
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 which we might not otherwise have access to
or that would require significantly higher minimum initial investment by our clients.
Services that May Not Directly Benefit Clients.
Schwab also makes available other products and services that benefit us but may not directly
benefit clients. These products and services assist us in managing and administering our
clients’ accounts. They include investment research, both Schwab’s own and that of third
parties. This research may be used to service all or a substantial number of client accounts,
including accounts not maintained at Schwab.
In addition to investment research, Schwab also makes available software and other
technology that:
• provides access to client account data (such as duplicate trade confirmations and
•
account statements)
facilitates trade execution and allocates aggregated trade orders for multiple client
accounts.
facilitate payment of our fees from our clients’ accounts, and
• provides pricing and other market data.
•
• assists with back-office functions, recordkeeping, and client reporting.
Services that Generally Benefit Us.
Schwab also offers other services intended to help us manage and further develop our
business enterprise. Including:
technology, compliance, legal, and business consulting
• educational conferences and events
•
• publications and conferences on practice management and business succession, and
• access to employee benefits providers, human capital consultants and insurance
providers.
Schwab may provide some of these services itself. In other cases, it will arrange for third-party
vendors to provide the services. Schwab may also discount or waive its fees for some of these
services or pay all or a part of a third party’s fees. Schwab may also provide other benefits
such as occasional business entertainment for our personnel. We use these services
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extensively to enhance our clients’ overall experience.
Our Interest in Schwab’s Services
The availability of these services from Schwab benefits Marquette because the firm does not
have to produce or purchase them. Marquette does not have to pay for Schwab’s services so
long as a total of at least $10 million of client assets is kept in the accounts at Schwab. Beyond
that, these services are not contingent upon us committing any specific amount of business to
Schwab in trading commissions or assets in custody. The $10 million minimum may give us an
incentive to recommend that clients maintain their accounts with Schwab based on our interest
in receiving Schwab’s services that benefit our business rather than based on clients’ interest
in receiving the best value in custody services and the most favorable execution of their
transactions. This is a potential conflict of interest. We believe, however, that our selection of
Schwab as custodian and broker is in the best interests of our clients. It is primarily supported
by the scope, quality, and price of Schwab’s services.
Other Brokerage Costs
Where we use a broker other than Schwab to execute transactions, Schwab charges an
allocation fee of $15. We do not charge a commission for buying or selling fixed income
securities. We use brokers who have expertise in the areas of the fixed income markets in
which we purchase bonds on behalf of our clients. To the extent we participate in newly issued
public fixed income securities, which are offered by one or more brokers, we will participate
with those brokers involved in the transaction. When selling bonds in the secondary market we
use a competitive bidding process, where the broker with the highest price will purchase the
bonds from us. When we purchase bonds in the secondary market, we use dealers who have
expertise in the markets we trade in and/or a cost advantage which allows us to purchase
bonds at a more favorable price.
When we use a broker other than Schwab to execute equity transactions, the broker receives
trading commissions. We do not use part of those commissions to pay for certain research
services, information, advice, or data that meet the safe harbor provisions of Section 28(e) of
the Securities and Exchange Act of 1934, known as "soft dollar," relationships.
In the event we make an error in executing trades in client accounts, clients are reimbursed for
any resulting loss. If the trade error results in a gain, clients retain the gain. Trade errors may
be defined as any trading activity that is inconsistent with contractual, legal, or regulatory
restrictions or is inconsistent with investment management intent.
Examples of trade errors include, but are not limited to, the following:
• Purchasing securities not permissible in client accounts
• Purchasing or selling securities for an account that are different than the portfolio
manager intended to purchase or sell, and
• Purchasing or selling securities for a different account than the account the portfolio
manager intended
Trade errors may be identified through various internal sources that may include, but are not
limited to, direct identification from portfolio management staff, post trade testing, or
identification by oversight groups.
Products and Services Available to Us from Other Third Parties
Some of our providers give us opportunities to attend conferences and seminars and offer
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other resources and support services to us. Some of those services help us manage or
administer our clients’ accounts, while others help us manage and grow our business. Such
services are generally available on an unsolicited basis (we do not have to request them) and
at no charge to us if we express an interest in their investment offerings or continue to have an
allocation to their investment products.
Below is a more detailed description of support services:
• Services that Benefit Clients. Some of the investment products we offer our clients
are not available to the public. Since we are viewed as one client to our managers, we
may be able to obtain these products at a lower institutional rate, which will benefit
clients.
• Services that May Not Directly Benefit Clients. These providers may allow us access
to best practice studies and analytics that help us manage and administer our clients’
accounts.
Services that Generally Benefit Us. There are other services that third parties offer
that are intended to help us manage and further develop our business enterprise. Some
of these services include educational conferences and events, business consulting,
publications and conferences on practice management and business succession.
ITEM 12.B – BROKERAGE PRACTICES – AGGREGATED TRADE ORDERS
When Marquette makes firm-wide allocation changes it is done at the same time in an
aggregated trade order with one average price for all clients.
Trades will also be aggregated when cash transactions are disbursed into multiple accounts
from the same family, at the same time and require investment on the same day.
ITEM 13 – REVIEW OF ACCOUNTS
Except where we are engaged to manage a portfolio within a specific mandate, the initial
portfolio review is designed to identify the current and recommended overall asset allocation.
Where appropriate, a transition plan is developed to communicate and manage tax
implications of implementing our recommendations. If the initial portfolio review is not
completed prior to our engagement, it is done as soon as practical after accounts are
transferred. Once we review our recommendations with you and make appropriate
adjustments, we prepare a formal Investment Policy Statement (“IPS”) as outlined in Item 16.
The IPS generally governs how portfolios will be managed. Portfolios and their underlying
securities are reviewed regularly by the account’s portfolio manager and the Investment team.
Portfolios are reviewed formally at least quarterly by the Investment Committee to monitor
adherence to their IPS.
We review third-party managers initially and every three years after to evaluate and monitor
their continued appropriateness for accounts managed on behalf of our clients. We request
certification of our sub-advisors' trading policies, compliance program and adherence to its
Code of Ethics. Where sub-advisors use a portion of trading commissions to pay for certain
research services, information, advice, or data, we seek assurance from each sub-advisor that
it follows safe harbor provisions discussed in Item 12 above.
Our Investment Committee (“IC”) is comprised of the following members:
• President (“IC Chair”)
• Vice President – Trading and Investment Operations (Secretary)
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We offer access to a client investment portal for wealth management portfolios. This portal
provides information on portfolio holdings, transactions, and performance. We provide
performance of relevant benchmarks in the reports for comparison. When appropriate, we also
provide customized reports and summaries. Clients receive income tax information as required
by law from their account custodian.
We manage accounts based on the client’s financial situation and investment objectives.
Relationship managers coordinate an overall relationship and planning review at least
annually; however, we recommend more frequent meetings.
Clients are expected to notify their Relationship Manager of any changes that may impact their
financial goals. Interim reviews are performed as necessary when due to a change in financial
situations or estate plans.
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
Advisers may retain and compensate third parties to refer or endorse potential advisory clients
to them. These third parties are referred to as promoters.
We receive economic benefit from Schwab and other third parties in the form of support,
products, and services. How they benefit us, and the related conflicts of interest are described
above (see Item 12 “Brokerage Practices”). The availability to us of such products and services
is not based on us giving particular investment advice, such as buying certain securities for our
clients.
We receive no other direct or indirect economic benefit, including but not limited to sales
awards or other prizes, for providing investment advice or other advisory services to our clients
from anyone that is not a client.
ITEM 15 – CUSTODY
Accounts Held at Schwab
We use Schwab as our primary qualified custodian. Under government regulations, we are
deemed to have custody of client assets if they authorize us to instruct Schwab to deduct our
advisory fees directly from their account. Schwab maintains actual custody of client assets.
Clients receive monthly account statements directly from Schwab. They are defaulted to
electronic delivery unless requested otherwise. Clients should carefully review those
statements promptly upon receipt. Investment information provided via the client investment
portal may vary from custodial statements based on accounting procedures, reporting dates, or
valuation methodologies for certain securities. Schwab statements will generally exclude non-
publicly tradable securities such as limited partnership interests, closely held stock, private
promissory notes, etc.
Accounts held at Bell Bank
Bell Bank serves as qualified custodian for accounts where we are named Investment Trust
Advisor. Under government regulations, we are deemed to have custody of trust assets if we
instruct Bell Bank to deduct our fees directly from the trust account. Bell Bank maintains actual
custody of client assets. Co-trustees receive account statements directly from Bell Bank at
least quarterly. Beneficiaries receive account statements directly from Bell Bank at least
annually. Statements are sent to the mailing address provided to Bell Bank or are available
electronically upon request. Co-trustees and beneficiaries should carefully review those
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statements promptly upon receipt. Investment information provided via the client investment
portal may vary from custodial statements based on accounting procedures, reporting dates, or
valuation methodologies for certain securities.
Accounts Held Elsewhere
Clients are not required to use Schwab as their qualified custodian and may negotiate such
services and fees with other custodians. If clients choose a custodian other than Schwab, they
should receive at least quarterly statements from the broker-dealer, bank or other qualified
custodian that holds and maintains the account(s). Clients should carefully review those
statements promptly upon receipt. The investment information provided through our client
portal may vary from custodial statements based on accounting procedures, reporting dates, or
valuation methodologies for certain securities.
ITEM 16 – INVESTMENT DISCRETION
We typically receive discretionary authority from clients at the onset of a wealth management
relationship permitting us to select and identify the amount of securities to be bought or sold. In
all cases, however, we exercise such discretion in a manner consistent with the agreed-upon-
stated investment objectives for client portfolios. Investment objectives, time horizon, cash
requirements, tax status, restrictions and other pertinent facts are reflected in the IPS. Asset
allocation targets are defined based on the above criteria and our assessment of your overall
risk tolerance. The IPS contains detailed information about our investment philosophy and
approach, each party’s duties and responsibilities, and our control procedures. An IPS signed
by the client and by us must be on file before we begin management of the portfolio.
When selecting securities and determining amounts to purchase or sell, we follow client-
communicated investment limitations and restrictions. Such investment limitations and
restrictions must be provided to us in writing and are generally incorporated into the IPS.
The portfolio manager is responsible for ongoing management of the portfolio in accordance
with the IPS.
ITEM 17 – VOTING CLIENT SECURITIES
As a matter of policy and as a fiduciary to our clients, Marquette does not accept the authority
to vote on a client’s securities (i.e. proxies) on their behalf in relation to securities held in their
accounts.
Class Actions. Marquette will file securities class action claims on the clients’ behalf, provided
that all relevant transactions occurred while they were a client of Marquette. We use the
services of Chicago Clearing Corporation (“CCC”) to file claims and collect proceeds. CCC
receives 17.5% of the proceeds collected as compensation. Clients are not required to use this
service and can “opt-out” by informing us in writing if they do not want CCC to file claims on
their behalf.
ITEM 17.B – CLIENT PROXY MATERIAL
Clients whose assets are custodied at Schwab can visit Schwab Alliance to obtain proxy
materials or call 800-515-2157. Those clients can also visit proxydocs.com/SCHW. Aside from
Schwab, clients can also visit proxyvote.com to access proxy information. If a control number
is needed, contact Schwab Client Reporting and Security services department at 800-323-
4332.
For those clients with assets custodied at Bell Bank, clients can visit proxyvote.com.
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Marquette does not research proxy proposals.
ITEM 18 – FINANCIAL INFORMATION
Registered investment advisers are required to provide clients with certain financial information
or disclosures about their financial condition.
Marquette has no financial commitments that impair our ability to meet contractual and
fiduciary commitments to clients, and we have not been the subject of bankruptcy proceeding.
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FORM ADV PART 2B
BROCHURE SUPPLEMENT
March 31, 2026
This Brochure provides information about the qualifications and business practices of
Marquette Asset Management, LLC doing business as Marquette Wealth Management
(“Marquette”). Marquette is a Minneapolis-based investment adviser registered with the
Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940.
The information in this Brochure has not been approved or verified by the SEC or by any state
securities authority. Registration of an investment adviser does not imply any level of skill or
training. Additional information about Marquette is also available on the SEC’s website at
adviserinfo.sec.gov.
Please contact Christopher Vernier, Marquette’s Chief Compliance Officer, at 612-661-3787 or
chris.vernier@marquettewm.com with any questions about the contents of this Brochure.
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I T E M 1 – G E N E R A L I N F O R M A T I O N
Christopher M. Vernier
Marquette Wealth Management
150 South Fifth Street, Suite 2800
Minneapolis, MN 55402
March 10, 2026
Direct 612-661-3787
Office 612-331-3770
I T E M 2 - E D U C A T I O N A L B A C K G R O U N D A N D B U S I N E S S E X P E R I E N C E
Christopher M. Vernier - Born 1972
CRD #2617017
Education:
University of St. Thomas: BBA, Accounting & Finance 1994
Business:
Marquette Wealth Management
President & Chief Compliance Officer 1/2023 - Present
Marquette Wealth Management
President 2/2016 – 1/2023
Marquette Asset Management, LLC
Managing Director Investments - 5/2014 – 5/2016
Marquette Asset Management
Senior Vice President – Trading and Investments 5/2010 – 5/2014
Marquette Asset Management
Vice President – Trading and Investments 1/2009 – 5/2010
Marquette Asset Management
Vice President – Operations – 12/2004 – 1/2009
Knelman Asset Management
Trader/Operations Manager 12/2000 – 12/2004
I T E M 3 - D I S C I P L I N A R Y I N F O R M A T I O N
Registered investment advisers are required to disclose all material facts regarding any legal
or disciplinary events that would be material to clients’ evaluation of each supervised person
providing investment advice. No information is applicable to this Item.
I T E M 4 - O T H E R B U S I N E S S A C T I V I T I E S
Mr. Vernier is not engaged in any investment-related business activities other than his
employment by us.
I T E M 5 - A D D I T I O N A L C O M P E N S A T I O N
Mr. Vernier receives no economic benefit for providing advisory services from anyone that is
not a client. As an owner, he is compensated through guaranteed payments and his share of
the firm’s profits.
I T E M 6 - S U P E R V I S I O N
As the President and Chief Compliance Officer of Marquette Wealth Management, Mr. Vernier
is not supervised by another individual. Mr. Vernier is responsible for all supervision,
compliance, and oversight of the firm’s investment advisory activities.
21
I T E M 1 – G E N E R A L I N F O R M A T I O N
Valerie A. Thomas
Wealth Management
150 South Fifth Street, Suite 2800
Minneapolis, MN 55402
March 10, 2026
Direct 612-661-3727
Office 612-331-3770
I T E M 2 - E D U C A T I O N A L B A C K G R O U N D A N D B U S I N E S S E X P E R I E N C E
Valerie A. Thomas, CTFA®* - Born 1970
CRD #5500991
Education:
University of Northwestern – St. Paul, MN: BS, Business Administration
Business:
Marquette Wealth Management
Managing Director & Chief Experience Officer 6/2022-Present
Marquette Wealth Management
Senior Vice President 7/2021 – 6/2022
Carlson Capital Management, LLC
Senior Integrated Wealth Advisor 10/2018 - 7/2021
CliftonLarsonAllen Wealth Advisors, LLC
Director and Senior Wealth Advisor -12/2015 -10/2018
Marquette Asset Management
Senior Vice President – 2/2005 – 11/2015
The Certified Trust and Fiduciary Advisor (CTFA) designation is awarded by the American
Bankers Association (ABA). The CTFA validates a professional's knowledge and skills in the
field of trusts and financial planning.
1. Minimum Qualifications:
a. Experience/Education: Candidates must meet specific experience and
education requirements (e.g., 3 years of wealth management experience with a
training program, or 5 years with a bachelor’s degree).
b. Examination: Candidates must pass a comprehensive exam covering Fiduciary
and Trust Activities, Financial Planning, Tax Law and Planning, Investment
Management, and Ethics.
c. Ethics: Holders must abide by the ADA’s Professional Code of Ethics.
d. Continuing Education: Candidates must complete 45 credits of continuing
education every three years.
Series 65 – Uniform Investment Adviser Law Examination – 5/2016
I T E M 3 - D I S C I P L I N A R Y I N F O R M A T I O N
Registered investment advisers are required to disclose all material facts regarding any legal
or disciplinary events that would be material to clients’ evaluation of each supervised person
providing investment advice. No information is applicable to this Item.
I T E M 4 - O T H E R B U S I N E S S A C T I V I T I E S
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Ms. Thomas is not engaged in any investment-related business activities other than her
employment by us.
I T E M 5 - A D D I T I O N A L C O M P E N S A T I O N
Ms. Thomas receives no economic benefit for providing advisory services from anyone that is
not a client. She is compensated by us primarily through salary. She receives a referral fee for
new clients referred to the firm. In addition, she receives incentive compensation based on our
revenues and individual performance of defined objectives for her job responsibilities.
I T E M 6 - S U P E R V I S I O N
Ms. Thomas reports to Christopher Vernier, our President. She is subject to our firm’s
compliance policies and procedures and is monitored through normal ongoing compliance
reviews. Mr. Vernier can be reached on 612-661-3787.
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I T E M 1 – G E N E R A L I N F O R M A T I O N
Jordan M. Elling
Marquette Wealth Management
150 South Fifth Street, Suite 2800
Minneapolis, MN 55402
March 10, 2026
Direct 612-661-3754
Office 612-331-3770
I T E M 2 - E D U C A T I O N A L B A C K G R O U N D A N D B U S I N E S S E X P E R I E N C E
Jordan M. Elling, CFP®* - Born 1993
CRD #6508177
Education:
University of MN Duluth – Duluth, MN: BS, Finance, Financial Planning & Services
Business:
Marquette Wealth Management
Vice President 4/2023 - Present
CliftonLarsonAllen Wealth Advisors, LLC
Associate Wealth Advisor – 5/2015 – 4/2023
* CERTIFIED FINANCIAL PLANNER® professional
I am certified for financial planning services in the United States by Certified Financial Planner
Board of Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED
FINANCIAL PLANNER® professional or a CFP® professional, and I may use these and the
other certification marks (the “CFP Board Certification Marks”) that Certified Financial Planner
Board of Standards Center for Financial Planning, Inc. has licensed to CFP Board in the United
States. The CFP® certification is voluntary. No federal or state law or regulation requires
financial planners to hold the CFP® certification. You may find more information about the
CFP® certification at www.cfp.net.
CFP® professionals have met CFP Board’s high standards for education, examination,
experience, and ethics. To become a CFP® professional, an individual must fulfill the following
requirements:
• Education – Earn a bachelor’s degree or higher from an accredited college or university
and complete CFP Board-approved coursework at a college or university through a CFP
Board Registered Program. The coursework covers the financial planning subject areas
CFP Board has determined are necessary for the competent and professional delivery of
financial planning services, as well as a comprehensive financial plan development
capstone course. A candidate may satisfy some of the coursework requirements through
other qualifying credentials. CFP Board implemented the bachelor’s degree or higher
requirement in 2007 and the financial planning development capstone course
requirement in March 2012. Therefore, a CFP® professional who first became certified
before those dates may not have earned a bachelor’s or higher degree or completed a
financial planning development capstone course.
• Examination – Pass the comprehensive CFP® Certification Examination. The
examination is designed to assess an individual’s ability to integrate and apply a broad
base of financial planning knowledge in the context of real-life financial planning
situations.
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• Experience – Complete 6,000 hours of professional experience related to the personal
financial planning process, or 4,000 hours of apprenticeship experience that meets
additional requirements.
• Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and
Former CFP® Professionals Seeking Reinstatement and agree to be bound by CFP
Board’s Code of Ethics and Standards of Conduct (“Code and Standards”), which sets
forth the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics
requirements to remain certified and maintain the right to continue to use the CFP Board
Certification Marks:
• Ethics – Commit to complying with CFP Board’s Code and Standards. This includes
a commitment to CFP Board, as part of the certification, to act as a fiduciary, and
therefore, act in the best interests of the client, at all times when providing financial
advice and financial planning. CFP Board may sanction a CFP® professional who
does not abide by this commitment, but CFP Board does not guarantee a CFP®
professional’s service. A client who seeks a similar commitment should obtain a
written engagement that includes a fiduciary obligation to the client.
• Continuing Education – Complete 30 hours of continuing education every two
years to maintain competence, demonstrate specified levels of knowledge, skills,
and abilities, and keep up with developments in financial planning. Two of the hours
must address the Code and Standards.
I T E M 3 - D I S C I P L I N A R Y I N F O R M A T I O N
Registered investment advisers are required to disclose all material facts regarding any legal
or disciplinary events that would be material to clients’ evaluation of each supervised person
providing investment advice. No information is applicable to this Item.
I T E M 4 - O T H E R B U S I N E S S A C T I V I T I E S
Ms. Elling is not engaged in any investment-related business activities other than her
employment with us.
I T E M 5 - A D D I T I O N A L C O M P E N S A T I O N
Ms. Elling receives no economic benefit for providing advisory services from anyone that is not
a client. She is compensated by us primarily through salary. She receives a referral fee for new
clients referred to the firm. In addition, she receives incentive compensation based on our
revenues and individual performance of defined objectives for her job responsibilities.
I T E M 6 - S U P E R V I S I O N
Ms. Elling reports to Valerie Thomas, the Managing Director and Chief Client Experience
Officer. She is subject to our firm’s compliance policies and procedures and is monitored
through normal ongoing compliance reviews. Ms. Thomas can be reached on 612-661-3727.
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