Overview
Assets Under Management: $880 million
High-Net-Worth Clients: 797
Average Client Assets: $848,489
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Clients
Number of High-Net-Worth Clients: 797
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 76.82
Average High-Net-Worth Client Assets: $848,489
Total Client Accounts: 2,454
Discretionary Accounts: 2,454
Regulatory Filings
CRD Number: 122320
Filing ID: 1995873
Last Filing Date: 2025-06-12 10:23:00
Website: https://tmg-llc.net
Form ADV Documents
Additional Brochure: ADV 2A (2025-06-12)
View Document Text
Registered as
Maryland Financial Group Inc.
Registered Investment Adviser
806 Twin Oaks Drive
Rockville, MD 20854
Telephone: (301) 251 - 8550
Fax: (301) 251-8554
June 12, 2025
FORM ADV PART 2A
BROCHURE
NOTICE TO PROSPECTIVE CLIENTS: READ THIS DISCLOSURE BROCHURE IN ITS ENTIRETY
All the material within this Brochure must be reviewed by those who are considering becoming a client
of our firm. This Brochure provides information about the qualifications and business practices of
Maryland Financial Group, Inc.
If you have any questions about the contents of this Brochure, please contact us at (301) 251-8550.
In accordance with federal and state regulations, this Brochure is on file with the appropriate securities
regulatory authorities as required. The information provided within this Brochure is not to be construed
as an endorsement or recommendation by state securities authorities in any jurisdiction within the
United States, or by the United States Securities and Exchange Commission. 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. Registration of a registered investment adviser does
not imply any level of skill or training.
Additional information about Maryland Financial Group, Inc. is also available on the SEC's website at
www.adviserinfo.sec.gov.
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Item 2 Summary of Material Changes
Since its last annual update of February 26, 2024, Maryland Financial Group, Inc. ("Maryland
Financial, MFG, we, us, our, our") below are the material changes to this Disclosure Brochure.
Please note that our address has changed from 2600 Tower Oaks Boulevard, Suite 220,
Rockville, MD 20852.
Our new address, effective immediately, is 806 Twin Oaks Drive, Rockville, MD 20854.
We will ensure that you receive a summary of any material changes to this and subsequent Brochures
within 120 days of the close of our business' fiscal year. We may further provide other ongoing
disclosure information about material changes as necessary. We will further provide you with a new
Brochure as necessary based on changes or new information, at any time, without charge.
Currently, our brochure maybe requested by contacting Amy F. Cox, Chief Compliance Officer at (301)
251-8550 or amycox@tmg-llc.net. We will provide you with a new brochure at any time without
charge.
Additional information about Maryland Financial Group is also available via the SEC's website
www.adviserinfo.sec.gov. The SEC's website also provides information about any persons affiliated
with Maryland Financial Group, Inc. who are registered or are required to be registered, as investment
adviser representatives of Maryland Financial Group, Inc.
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Item 3 Table of Contents
Item 1 Cover Page
Item 2 Summary of Material Changes
Item 3 Table of Contents
Item 4 Advisory Business
Item 5 Fees and Compensation
Item 6 Performance-Based Fees and Side-By-Side Management
Item 7 Types of Clients
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Item 9 Disciplinary Information
Item 10 Other Financial Industry Activities and Affiliations
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 12 Brokerage Practices
Item 13 Review of Accounts
Item 14 Client Referrals and Other Compensation
Item 15 Custody
Item 16 Investment Discretion
Item 17 Voting Client Securities
Item 18 Financial Information
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Item 4 Advisory Business
Maryland Financial Group, Inc. ("MFG") is a corporation organized under the laws of Maryland. The
Monitor Group, LLC acquired the Rockville, MD based investment advisory firm in 2005 and is the
principal owner. Christopher Cox and Amy Cox are the Managing Members and owners of The Monitor
Group, LLC.
Maryland Financial Group is registered as an investment advisory firm with the Securities and
Exchange Commission ("SEC").
Maryland Financial Group, Inc. provides fee based investment advisory services primarily to individual
clients and high-net worth individuals as well as charitable organizations and corporations.
As of December 31, 2024, we managed approximately $880,267,065 million in client assets on a
discretionary basis. Information about our asset management services is available upon request.
This brochure describes our financial planning services and asset management services on a fee
basis.
Advisor representatives are restricted to providing services and charging fees based in accordance
with the descriptions detailed in this document and the account agreement. However, the exact service
and fees charged to a particular client are dependent upon the representative that is working with the
client. Advisors are instructed to consider the individual needs of each client when recommending an
advisory platform. Investment strategies and recommendations are tailored to the individual needs of
each client.
Individuals associated with Maryland Financial Group, Inc. are also registered representatives of LPL
Financial, an SEC registered broker/dealer, a member of the Financial Regulatory Authority ("FINRA")
and the Securities Investors Protection Corporation ("SIPC"). Securities transactions are generally
directed to LPL Financial for execution unless otherwise another custodian is selected for best
execution. Maryland Financial Group, Inc. and LPL Financial are not affiliated legal entities.
Asset Management
Maryland Financial Group, Inc. through its investment advisor representatives provides ongoing
investment advice and management on assets in the client's custodial Strategic Wealth Management
(SWM) account held at LPL Financial. Strategic Wealth Management is the name of the custodial
account offered through LPL to support investment advisory services provided by Maryland Financial
Group, Inc. to our clients. More specific account information and acknowledgements are further
detailed on the account application.
Investment advisor representatives provide advice on the purchase and sale of various types of
investments, such as mutual funds, exchange-traded funds ("ETFs"), variable annuity subaccounts,
real estate investment trusts ("REITs"), equities, and fixed income securities. The advice is tailored to
the individual needs of the client based on the investment objective chosen by the client in order to
help assist clients in attempting to meet their financial goals. Accounts are reviewed on a regular basis
and rebalanced as necessary.
A minimum account value of $25,000 is generally required for the program. In certain instances,
Maryland Financial Group, Inc. will permit a lower minimum account size.
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Assets managed in a wrap fee account are not managed differently from a non-wrap fee account.
However, Maryland Financial Group, Inc. may charge a higher fee, up to 2.35%, and receive a portion
of the wrap fee for services provided.
Optimum Market Portfolios Program (OMP)
OMP offers clients the ability to participate in a professionally managed asset allocation program using
Optimum Funds Class I shares. Under OMP, client will authorize LPL on a discretionary basis to
purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. Advisor will
assist the client in determining the suitability of OMP for the client and assist the client in setting an
appropriate investment objective. Advisor will have discretion to select a mutual fund asset allocation
portfolio designed by LPL consistent with the client's investment objective. LPL will have discretion to
purchase and sell Optimum Funds pursuant to the portfolio selected for the client. LPL will also have
authority to rebalance the account.
A minimum account value of $15,000 is required for OMP.
Personal Wealth Portfolios Program (PWP)
PWP offers clients an asset management account using asset allocation model portfolios designed by
LPL. Advisor will have discretion for selecting the asset allocation model portfolio based on client's
investment objective. Advisor will also have discretion for selecting third party money managers (PWP
Advisors) or mutual funds within each asset class of the model portfolio. LPL will act as the over lay
portfolio manager on all PWP accounts and will be authorized to purchase and sell on a discretionary
basis mutual funds and equity and fixed income securities.
A minimum account value of $250,000 is required for PWP.
Model Wealth Portfolios Program (MWP)
MWP offers clients a professionally managed mutual fund asset allocation program. Maryland
Financial Group, Inc. investment advisor representatives will obtain the necessary financial data from
the client, assist the client in determining the suitability of the MWP program and assist the client in
setting an appropriate investment objective. The Advisor will initiate the steps necessary to open an
MWP account and have discretion to select a model portfolio designed by LPL's Research Department
consistent with the client's stated investment objective. LPL's Research Department is responsible for
selecting the mutual funds within a model portfolio and for making changes to the mutual funds
selected.
The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds
(including in certain circumstances exchange traded funds) and to liquidate previously purchased
securities. The client will also authorize LPL to effect rebalancing for MWP accounts.
In the future, the MWP program may make available model portfolios designed by strategists other
than LPL's Research Department. If such models are made available, Advisor will have discretion to
choose among the available models designed by LPL and outside strategists.
A minimum account value of $25,000 is required for MWP.
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Manager Access Select Program
Manager Access Select provides clients access to the investment advisory services of professional
portfolio management firms for the individual management of client accounts. Advisor will assist client
in identifying a third-party portfolio manager (Portfolio Manager) from a list of Portfolio Managers made
available by LPL. The Portfolio Manager manages client's assets on a discretionary basis. Advisor will
provide initial and ongoing assistance regarding the Portfolio Manager selection process.
A minimum account value of $100,000 is required for Manager Access Select, however, in certain
instances, the minimum account size may be lower or higher.
The account fee charged to the client for each advisory program is negotiable, subject to the following
maximum account fees:
Annual Percentage of Assets Charge
Advisory Program
Asset Management
2.25% ($0 to $249,999)
1.90% ($250,000 to $499,999)
1.65% ($500,000 to $999,999)
1.40% ($1,000,000 +)
OMP
PWP
MWP
Manager Access Select
2.5%
2.5%
2.5%
3.0%
Account fees are payable quarterly in advance.
See Item 5 for further information about fees.
Transactions in LPL advisory program accounts are generally effected through LPL as the executing
broker/dealer. Assets held at another custodian will generally be executed by a different broker/dealer.
Neither the firm nor any investment advisor representative are registered or have an application
pending to register, as a futures commission merchant, commodity pool operator, a commodity trading
advisor, or a representative of the foregoing.
Financial Planning Services
Maryland Financial Group, Inc., through its investment advisor representatives, may provide personal
financial planning services to clients tailored to the individual needs of the client. These services may
include information and recommendations regarding tax planning, investment planning, retirement
planning, estate needs, business needs, education planning, life and disability insurance needs, long-
term care needs, and cash flow/budget planning. The services take into account information collected
from the client such as financial information and history from you including, but not limited to,
retirement and financial goals, investment objectives, investment horizon, financial needs, cash flow
analysis, cost of living needs, education needs, savings tendencies, and other applicable financial
information.
We may prepare a written financial plan and/or asset allocation addressing your needs. Financial
plans are based on the information that you disclose relative to your financial situation at the time. You
are advised that certain assumptions may be made with respect to interest and inflation rates and use
of past trends and performance of the market and economy. However, past performance is in no way
an indication of future performance.
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We cannot offer any guarantees or promises that your financial goals and objectives will be met.
Further, you must continue to review any plan and update the plan based upon changes in your
financial situation, goals, or objectives or changes in the economy. The advice we offer maybe limited
and is not meant to be comprehensive. Therefore, you may need to seek the services of other
professionals such as an insurance adviser, attorney and/or accountant.
Fees for such services are negotiable and detailed in the client agreement.
Optional Portfolio Review of Financial Plans
In addition to providing a financial plan, we offer an optional portfolio review service. We will
periodically review the portfolio of your repositionable investment assets. These reviews will evaluate
your holdings with regard to changes necessary to keep the portfolio consistent with your investment
objectives and risk tolerance. We will promptly notify you should any investment changes are deemed
necessary.
We will not cause any transactions to be effected in the reviewed account. You are responsible for
acting on our recommendations at your sole discretion. You are responsible for notifying your adviser
representative if any transactions are executed in the reviewed account, or if your investment
objectives for the account change.
Hourly Consulting Services
We may provide consulting services on an hourly basis. These services may include advice regarding
tax planning, investment planning, retirement planning, estate planning, cash flow/budget planning,
business planning, education planning, and personal financial planning.
The services take into account information collected from the client such as financial status, investment
objectives and tax status, among other data. The investment advisor representatives may or may not
deliver to the client a written analysis or report as part of the services. The investment advisor
representatives tailor the hourly consulting services to the individual needs of the client based on the
investment objective chosen by the client. The engagement terminates upon final consultation with the
client.
Fees for such services are negotiable and detailed in the client agreement.
Third Party Advisory Services
Maryland Financial Group, Inc. has entered into agreements with various third-party advisers. Under
these agreements, Maryland Financial Group, Inc. offers clients various types of programs sponsored
by these advisers. All third-party investment advisers to whom Maryland Financial Group, Inc. will refer
clients will be licensed as investment advisers by their resident state and any applicable jurisdictions or
with the SEC.
Maryland Financial Group, Inc. will assist the client in selecting a particular third-party program.
Maryland Financial Group, Inc. receives compensation pursuant to its agreements with these third-
party advisers for introducing clients to these third-party advisers and for certain ongoing services
provided to clients.
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This compensation is disclosed to the client in a separate disclosure document and is typically equal to
a percentage of the investment advisory fee charged by that third-party adviser or a fixed fee. The
disclosure document provided by Maryland Financial Group, Inc. will clearly state the fees payable to
Maryland Financial Group, Inc. and the impact to the overall fees due to these payments.
The compensation Maryland Financial Group, Inc. receives may differ depending on the agreement
with each third-party adviser. This creates a conflict of interest where Maryland Financial Group, Inc.
has an incentive to recommend a third-party adviser with more favorable compensation arrangements.
Since the independent third-party adviser may pay the fee for the investment advisory services of
Maryland Financial Group, Inc., the fee paid to Maryland Financial Group, Inc. is not negotiable, under
most circumstances.
Fees paid by clients to independent third-parties are established and payable in accordance with the
Form ADV Part 2 of each independent third-party adviser to whom Maryland Financial Group, Inc.
refers its clients, and may or may not be negotiable, as disclosed in the disclosure documents of the
third-party adviser.
Clients who are referred to third-party investment advisers will receive full disclosure, including
services rendered and fee schedules, at the time of the referral, by delivery of a copy of the relevant
third-party adviser's Form ADV Part 2 at the same time as the Form ADV Part 2 of Maryland Financial
Group, Inc.
In addition, if the investment program recommended to a client is a wrap fee program the client will
also receive the wrap fee brochure provided by the sponsor of the program. Maryland Financial Group,
Inc. will provide to each client all appropriate disclosure statements, including disclosure of solicitation
fees to Maryland Financial Group, Inc. and its advisory associates.
General - Advisory Services to Retirement Plans and Plan Participants
We offer various levels of advisory and consulting services to employee benefit plans ("Plan") and to
the participants of such plans ("Participants"). The services are designed to assist plan sponsors in
meeting their management and fiduciary obligations to Participants under the Employee Retirement
Income Securities Act ("ERISA"). Pursuant to adopted regulations of the U.S. Department of Labor, we
are required to provide the Plan's responsible plan fiduciary (the person who has the authority to
engage us as an investment adviser to the Plan) with a written statement of the services we provide to
the Plan, the compensation we receive for providing those services, and our status (which is described
below).
The services we provide to your Plan are described above, and in the service agreement that you have
previously signed. Our compensation for these services is described below, at Item 5, and in the
service agreement. We do not reasonably expect to receive any other compensation, direct or indirect,
for the services we provide to the Plan or Participants, unless the plan sponsor directs us to deduct our
fee from the plan or directs the plan record-keeper to issue payment for our fee out of the plan. If we
receive any other compensation for such services, we will (i) offset the compensation against our
stated fees, and (ii) we will promptly disclose the amount of such compensation, the services rendered
for such compensation and the payer of such compensation to you.
We are registered as an investment adviser with the United States Securities and Exchange
Commission and represent that we are not subject to any disqualification as set forth in Section 411 of
ERISA. In performing Fiduciary Services, we are acting as a fiduciary of the Plan as defined in Section
3(21) under the Employee Retirement Income Security Act ("ERISA").
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Item 5 Fees and Compensation
The specific manner in which fees are charged by the firm is established in a client's written agreement
between the client and Maryland Financial Group, Inc. Clients can determine to engage the services of
Maryland Financial Group, Inc. on a discretionary or non-discretionary basis. The firm's annual
investment advisory fee shall be based upon a percentage (%) of the market value as calculated on the
final day of the quarter and type of assets placed under the firm's management to be charged quarterly
in advance, and Maryland Financial Group, Inc. representatives may at their discretion negotiate a fee
in accordance with the above fee schedule.
The hourly consulting services offered by Maryland Financial Group, Inc. will be based on the type of
services to be provided, experience and expertise, and the sophistication and bargaining power of the
client.
Maryland Financial Group offers financial planning based on an hourly or fixed fee basis. Our hourly
fee is $300. Fixed fees range from $300 to $15,000. Fees are negotiable and are invoiced monthly or
quarterly for all time spent by Maryland Financial Group as agreed upon by you. Generally, you will be
provided a quote on the amount of time Maryland Financial Group anticipates is needed to provide the
services requested. Should additional time be needed, Maryland Financial Group will notify you.
You may terminate hourly advisory services within five (5) business days after entering into the
advisory agreement without penalty upon Maryland Financial Group's receipt of your written
notice to terminate. You will be responsible for time spent by Maryland Financial Group in providing you
advisory services or analyzing your situation. You are advised that fees for financial planning are strictly
for financial planning services. Therefore, you may pay fees and/or commissions for additional services
obtained such as asset management or products purchased such as securities or insurance.
In the event that a client desires, a client can engage certain representatives of the firm, in their
individual capacities as registered representatives of LPL Financial, an SEC registered and
FINRA/SIPC member broker-dealer, to implement investment recommendations on a commission
basis. In the event a client chooses to purchase investment products through LPL Financial, LPL
Financial will charge brokerage commissions to effect securities transactions, a portion of which
commissions LPL Financial shall pay to the firm's representatives, as applicable. The brokerage
commissions charged by LPL Financial may be higher or lower than those charged by other
broker/dealers.
In addition, LPL Financial, as well as the firm's representatives, relative to commission mutual fund
purchases, will receive additional ongoing 12b-1 trailing commission compensation directly from the
mutual fund company during the period that the client maintains the mutual fund investment.
The recommendation that a client purchase a commission product from LPL Financial presents a
conflict of interest, as the receipt of commissions may provide an incentive to recommend investment
products based on commissions received, rather than on a particular client's need. No client is under
any obligation to purchase any commission products from LPL Financial. The firm's Chief Compliance
Officer, Amy Cox, is available to address any questions that a client or prospective client may have
regarding this conflict of interest.
Please note, clients may purchase investment products recommended by our firm through other, non-
affiliated broker dealers or agents.
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The firm generally does not receive more than 5% of its revenue from advisory clients as a result of
commissions or other compensation for the sale of investment products the firm recommends to its
clients. When the firm's representatives sell an investment product on a commission basis, the firm
does not charge an advisory fee in addition to the commissions paid by the client for such product.
When providing services on an advisory fee basis, the Maryland Financial Group, Inc. representatives
do not also receive commission compensation for such advisory services (except for any ongoing 12b-
1 trailing commission compensation received as previously discussed). However, a client may engage
the firm to provide investment management services for an advisory fee and also purchase an
investment product from the firm's representatives on a separate commission basis.
LPL with written authorization to deduct fees and pay the advisory fees to the RIA firm. The advisory
fee is paid directly by LPL to the RIA firm (not the individual). The RIA firm will then share the advisory
fee with its advisors/ associated persons. A custom program account may be terminated according to
the client agreement. If the client agreement provides for payment in advance, the agreement will state
how the client can obtain are fund of any pre-paid fee if the agreement is terminated before the end of
the billing period.
In certain cases, LPL may serve as the broker/dealer on transactions in a customized advisory
account. In such case, LPL may charge the client transaction charges in connection with trade
execution through LPL. The transaction charges will be clearly stated in the client agreement executed
by the client at the time the relationship is established. If the custom advisory services apply to variable
annuities for which the investment advisor representative receives trail compensation, such trail fees
generally will be used to off-set the advisory fee. In most cases, however, a third-party broker dealer
will provide trade execution. In such cases, the broker-dealer may charge clients commissions,
markups, mark downs, and/or transaction charges.
Advisor receives compensation as a result of a client's participation in an LPL program. Depending on
specific account circumstances, the amount of this compensation may be more or less than what the
Advisor would receive if the client participated in other programs, whether through LPL or another
sponsor, or paid separately for investment advice, brokerage and other services.
LPL serves as program sponsor, investment advisor and broker/dealer for the LPL advisory programs.
Maryland Financial Group, Inc. and LPL may share in the account fee and other fees associated with
program accounts. Associated persons of Advisor may also be registered representatives of LPL.
Investment advisor representatives may also be licensed insurance agents. In the capacity of an
insurance agent, they may recommend the purchase of certain insurance-related products on a
commission basis.
The purchase a securities and/or insurance commission product presents a conflict of interest, as the
receipt of commissions may provide an incentive to recommend investment products based on
commissions received, rather than on a particular client's need. No client is under any obligation to
purchase any commission products from investment advisor representative of the firm. Clients may
purchase investment products recommended by investment advisory representatives through other,
non-affiliated broker/dealers or insurance agents.
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Additional Fee for Optional Portfolio Review of Financial Plans
MFG offers the additional service of Portfolio Review of financial plans based on a flat fee of $300 per
month, charged quarterly in arrears. Fees are negotiable and are invoiced quarterly. Fees for this
optional Portfolio Review Service are charged only for monitoring the portfolio as described above. You
may pay fees and/or commissions for additional services such as financial planning, asset
management or for securities products.
Changes to Our Fees and Compensation
We have the right to change any or all of our fee schedules with 30 days written notice. A client
agreement may be canceled by either party for any reason upon receipt of 30 days written notice.
Upon termination of an agreement, any prepaid, unearned fees will be refunded.
Any earned unpaid fees will be due and payable. You have the right to terminate an agreement within
five business days after entering into it without owing us any fees. Lower fees for comparable services
maybe available from other sources.
Third Party Advisory Services
We are paid by third party money managers when we refer you to them and you decide to open a
managed account. Third party money managers pay us a portion of the investment advisory fee that
they charge you for managing your account. Fees paid to us by third party money manager are
generally ongoing. All fees we receive from third party money managers and the written separate
disclosures made to you regarding these fees comply with applicable state statutes and rules. The
separate written disclosures you need to be provided include: a copy of the third-party money
manager's Form ADV Part 2, all relevant Brochures, a Solicitation Disclosure Statement detailing the
exact fees we are paid, and a copy of the third-party money manager's privacy policy. The third-
party money managers we recommend will not directly charge you a higher fee than they would
have charged without us introducing you to them.
Third party money managers establish and maintain their own separate billing processes over which
we have no control. In general, they will directly bill you and describe how this works in their separate
written disclosure documents.
Additional Fees and Expenses
We may invest, or recommend that you invest, in mutual funds and exchange traded funds. The fees
that you pay us for investment advisory services are separate and distinct from the fees and expenses
charged by mutual funds or exchange traded funds (described in each fund's prospectus) to their
shareholders. These fees generally include a management fee and other fund expenses. You will also
incur transaction charges and/or brokerage fees when purchasing or selling securities. These charges
and fees are typically imposed by the broker-dealer or custodian through whom your account
transactions are executed. We do not share in any portion of the brokerage fees/transaction charges
imposed by the broker-dealer or custodian. To fully understand the total cost you will incur, you should
review all the fees charged by mutual funds, exchange traded funds, our firm, and others.
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Item 6 Performance-Based Fees and Side-By-Side Management
Neither the firm or any supervised persons accepts performance-based fees, fees based on a share of
capital gains on or capital appreciation of the assets of a client such as a hedge fund or other pooled
investment vehicle.
Item 7 Types of Clients
The advisory services offered by Maryland Financial Group, Inc. are available for individuals, individual
retirement accounts ("IRAs"), banks and thrift institutions, pension and profit sharing plans, including
plans subject to Employee Retirement Income Security Act of 1974 ("ERISA"), trusts, estates,
charitable organizations, state and municipal government entities, corporations
and other business entities.
The firm generally provides investment advice to individuals and high-net-worth individuals. including
their trusts, estates and retirement accounts. We also provide services to corporations or business
entities including their pension and profit-sharing plans. There are no asset size requirements for
entering into a financial planning agreement.
The firm is currently not working with other types of clients or pursuing them as prospects but would
not turn away any opportunities that may arise.
Maryland Financial Group, Inc. may require a minimum asset amount for financial planning, hourly
consulting, participant consulting or research services. For customized advisory services, any required
minimum account value will be set out in the client agreement.
For LPL's Financial Sponsored Advisory Programs account minimums are as follows:
• Asset Management: $25,000
• Optimum Market Portfolios Program (OMP): $15,000
• Personal Wealth Portfolios Program (PWP): $250,000
• Model Wealth Portfolios Program (MWP): $100,000
• Manager Access Select Program (MAS): $100,000 (in certain instances, the minimum account
size may be lower or higher).
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
We prepare a financial plan based on the information you provide. We may use software or other
programs in preparing the plan.
We emphasize regular account supervision. As part of our asset management service, we generally
create a portfolio, consisting of individual stocks or bonds, exchange traded funds ("ETFs"), options,
mutual funds and other public and private securities or investments.
The client's individual investment strategy is tailored to their specific needs. Each portfolio will be
initially designed to meet a particular investment goal, which we determine to be suitable to the client's
circumstances. Once the appropriate portfolio has been determined, we review the portfolio at least
quarterly and if necessary, rebalance the portfolio based upon the client's individual needs, stated
goals and objectives. Each client has the opportunity to place reasonable restrictions on the types of
investments to be held in the portfolio.
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The firm uses a combination of charting, fundamental, and technical analysis in order to formulate
investment advice when managing assets. Depending on the analysis the firm will implement a long or
short-term trading strategy based on the particular objectives and risk tolerance of a particular client.
Please note, investing in securities involves risk of loss that clients should be prepared to bear. There
are different types of investments that involve varying degrees of risk, and it should not be assumed
that future performance of any specific investment or investment strategy will be profitable or equal any
specific performance level(s). Past performance is not indicative of future results.
The firms' methods of analysis and investment strategies do not represent any significant or unusual
risks however all strategies have inherent risks and performance limitations such as:
• Market Risk- the risk that the value of securities may go up or down, sometimes rapidly or
unpredictably, due to factors affecting securities markets generally or particular industries.
•
Interest Rate Risk- the risk that fixed-income securities will decline in value because of an
increase in interest rates; a bond or a fixed-income fund with a longer duration will be more
sensitive to changes in interest rates than a bond or bond fund with a shorter duration.
• Credit Risk- the risk that an investor could lose money if the issuer or guarantor of a
fixed-income security is unable or unwilling to meet its financial obligations.
You should be prepared to bear the risk of loss when you invest in market securities. You must also
be aware that the use of margin, options and short sales are higher-risk strategies. It is possible to
lose all of the principal you invest, and sometimes more. In a cash account, your risk is generally
limited to the amount of money that you have invested. In a margin account, your risk includes the
amount of money invested plus the amount that has been loaned to you. When you short-sell, your
losses can be infinite.
Where appropriate and suitable, we may recommend options. An option is a contract that gives the
buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or
before the expiration date of the option. When an investor sells an option, he or she must deliver to the
buyer a specified number of shares if the buyer exercises the option. The option writer/seller receives a
premium (the market price of the option at a particular time) in exchange for writing the option.
Risk: Options are complex securities that involve risks and are not suitable for everyone. Option
trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that
you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not
the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the
"expiration date"). The two types of options are calls and puts:
A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls
are similar to having a long position on a stock. Buyers of calls hope that the stock will increase
substantially before the option expires.
A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts
are very similar to having a short position on a stock. Buyers of puts hope that the price of the stock
will fall before the option expires.
Selling options is more complicated and can be even riskier.
The option trading risks pertaining to options buyers are:
13
• Risk of losing your entire investment in a relatively short period of time.
• The risk of losing your entire investment increases if, as expiration nears, the stock is
below the strike price of the call (for a call option) or if the stock is higher than the strike
price of the put (for a put option).
• European style options which do not have secondary markets on which to sell the
options prior to expiration can only realize its value upon expiration.
• Specific exercise provisions of a specific option contract may create risks.
• Regulatory agencies may impose exercise restrictions, which stops you from realizing
value.
The option trading risks pertaining to options sellers are:
• Options sold may be exercised at any time before expiration.
• Covered Call traders forgo the right to profit when the underlying stock rises above the
strike price of the call options sold and continues to risk a loss due to a decline in the
underlying stock.
• Writers of Naked Calls risk unlimited losses if the underlying stock rises.
• Writers of Naked Puts risk unlimited losses if the underlying stock drops.
• Writers of naked positions run margin risks if the position goes into significant losses.
Such risks may include liquidation by the custodian of other securities in the account in
order to meet margin obligations pertaining to the option.
• Writers of call options could lose more money than a short seller of that stock could on
the same rise on that underlying stock. This is an example of how the leverage in
options can work against the option trader.
• Writers of Naked Calls are obligated to deliver shares of the underlying stock if those
call options are exercised.
• Call options can be exercised outside of market hours such that effective remedy
actions cannot be performed by the writer of those options.
• Writers of stock options are obligated under the options that they sold even if a
trading market is not available or that they are unable to perform a closing
transaction.
• The value of the underlying stock may surge or fall unexpectedly, leading to automatic
exercises.
14
Other option trading risks are:
• The complexity of some option strategies is a significant risk on its own.
• Option trading exchanges or markets and option contracts themselves are open to
changes at all times.
• Options markets have the right to halt the trading of any options, thus preventing
investors from realizing value.
• Risk of erroneous reporting of exercise value.
•
•
If an options brokerage firm goes insolvent, investors trading through that firm maybe
affected.
Internationally traded options have special risks due to timing across borders.
Risks that are not specific to options trading include market risk, sector risk and individual stock risk.
Option trading risks are closely related to stock risks, as stock options are a derivative of stocks.
Item 9 Disciplinary Information
There are no legal or disciplinary events to disclose.
Item 10 Other Financial Industry Activities and Affiliations
Investment advisor representatives of our firm may also be registered representatives of LPL Financial
LLC ("LPL"), an unaffiliated SEC registered and FINRA/SIPC member broker/dealer. In their capacity
as registered representatives, these persons will receive commission-based compensation in
connection with the purchase and sale of securities, including 12b-1 fees for the sale of investment
company products. Compensation earned by these persons in their capacities as registered
representatives is separate and in addition to our advisory fees. These practices present a conflict of
interest because persons providing investment advice on behalf of our firm who are registered
representatives have a financial incentive to effect securities transactions in accounts held with LPL.
Investment Adviser Representatives of our firm may also be registered as investment adviser
representatives of LPL Financial LLC, an SEC registered investment adviser (and Broker-Dealer as
disclosed above). Any compensation earned in this separate capacity is separate and apart from the
advisory fees charged by our firm.
We are affiliated with ABC Holding of the MidAtlantic and Southeast, LLC through common control and
ownership, an affiliated insurance agency. Persons providing investment advice on behalf of our firm
may be licensed as insurance agents with this affiliate, other non-affiliated insurance agencies, or as
independent insurance agents. These persons will earn commission-based compensation for selling
insurance products to you. Compensation earned by these persons in their capacities as licensed
insurance agents is separate and in addition to our advisory fees. These practices present a conflict of
interest because persons providing investment advice on behalf of our firm who are licensed insurance
agents have a financial incentive to sell you insurance products.
15
You are under no obligation, contractually or otherwise, to purchase securities and/or
insurance products through any person or entity affiliated with our firm.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Maryland Financial Group, Inc. maintains a Code of Ethics, which serves to establish a standard of
business conduct for all employees that are based upon fundamental principles of openness, integrity,
honesty, and trust.
We have adopted a Code of Ethics ("Code") to address the securities-related conduct of our advisory
representatives and employees. The Code includes our policies and procedures developed to protect
your interests in relation to the following:
•
•
•
•
the duty at all times to place your interests ahead of ours;
that all personal securities transactions of our advisory representatives and employees be
conducted in a manner consistent with the Code and avoid any actual or potential conflict of
interest, or any abuse of an advisory representative's or employee's position of trust and
responsibility; that advisory representatives may not take inappropriate advantage of their
positions;
that information concerning the identity of your security holdings and financialcircumstances
are confidential; and,
that independence in the investment decision-making process is paramount.
The code of ethics includes guidelines regarding personal securities transactions of its employees and
investment advisor representatives. The code of ethics permits employees and investment advisor
representatives or related persons to invest for their own personal accounts in the same or different
securities that an investment advisor representative may purchase for clients in program accounts.
This presents a potential conflict of interest because trading by an employee or investment advisor
representatives in a personal securities account in the same or different security on or about the same
time as trading by a client could potentially disadvantage the client. Maryland Financial Group, Inc.
addresses this conflict of interest by requiring in its code of ethics that employees and investment
advisor representatives report certain personal securities transactions and holdings to the Chief
Compliance Officer for review.
Upon employment or affiliation and at least annually thereafter, all supervised persons will sign an
acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our
firm and supervised persons must conduct business in an honest, ethical, and fair manner and avoid
all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all
clients. This disclosure is provided to give all clients a summary of our Code of Ethics. However, if a
client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided
promptly upon request.
16
It is the expressed policy of our firm that no person employed by us may purchase or sell any security
prior to a transaction being implemented for an advisory account, thereby preventing an employee
from benefiting from transactions placed on behalf of advisory accounts.
Item 12 Brokerage Practices
Maryland Financial Group, Inc. receives support services and/or products from LPL Financial, many of
which assist the Maryland Financial Group, Inc. to better monitor and service program accounts
maintained at LPL Financial. These support services and/or products maybe received without cost, at
a discount, and/or at a negotiated rate, and may include the following:
investment-related research
•
• pricing information and market data
• software and other technology that provide access to client account data
• compliance and/or practice management-related publications
• consulting services
• attendance at conferences, meetings, and other educational and/or social events
• marketing support
• computer hardware and/or software
• other products and services used by [Advisor] in furtherance of its investment advisory business
operations
These support services are provided to Maryland Financial Group, Inc. based on the overall
relationship between Maryland Financial Group, Inc. and LPL Financial. It is not the result of soft dollar
arrangements or any other express arrangements with LPL Financial that involves the execution of
client transactions as a condition to the receipt of services. Maryland Financial Group, Inc. will
continue to receive the services regardless of the volume of client transactions executed with LPL
Financial. Clients do not pay more for services as a result of this arrangement. There is no
corresponding commitment made by the Maryland Financial Group, Inc. to LPL Financial or any other
entity to invest any specific amount or percentage of client assets in any specific securities as a result
of the arrangement.
Maryland Financial Group, Inc. has an arrangement with LPL Financial. LPL Financial offers to
independent investment advisers non-soft dollar services which include custody of securities, trade
execution, clearance and settlement of transactions. We receive some non-soft dollar benefits from
LPL Financial through our participation in the program.
LPL Financial may make certain research and brokerage services available at no additional cost to our
firm. These services may be directly from independent research companies, as selected by our firm
(within specific parameters). Research products and services provided by LPL Financial may include
research reports on recommendations or other information about, particular companies or industries;
economic surveys, data and analyses; financial publications; portfolio evaluation services; financial
database software and services; computerized news and pricing services; quotation equipment for use
in running software used in investment decision-making; and other products or services that provide
lawful and appropriate assistance by LPL Financial to our firm in the performance of our investment
decision-making responsibilities.
Although the non-soft dollar investment research products and services that may be obtained by our
firm will generally be used to service all of our clients, a brokerage commission paid by a specific client
may be used to pay for research that is not used in managing that specific client's account.
17
As a result of receiving the services Maryland Financial Group, Inc. may have an incentive to continue
to use or expand the use of LPL Financial services. Our firm examined this potential conflict of interest
when we chose to enter into the relationship with LPL and we have determined that the relationship is
in the best interest of our firm's clients and satisfies our fiduciary obligations, including our duty to seek
best execution.
LPL Financial charges brokerage commissions and transaction fees for effecting certain securities
transactions (i.e., transaction fees are charged for certain no-load mutual funds, commissions are
charged for individual equity and debt securities transactions). LPL enables us to obtain many no-load
mutual funds without transaction charges and other no-load funds at nominal transaction charges. LPL
Financial commission rates are generally discounted from customary retail commission rates.
However, the commission and transaction fees charged by LPL Financial may be higher or lower than
those charged by other custodians and broker/dealers.
Clients may pay a commission to LPL Financial that is higher than another qualified broker-dealer
might charge to effect the same transaction where we determine in good faith that the commission is
reasonable in relation to the value of the brokerage and research services received In seeking best
execution, the determinative factor is not the lowest possible cost, but whether the transaction
represents the best qualitative execution, taking into consideration the full range of a broker-dealer's
services, including the value of research provided, execution capability, commission rates, and
responsiveness. Accordingly, although we will seek competitive rates, to the benefit of all clients, we
may not necessarily obtain the lowest possible commission rates for specific client account
transactions.
Neither we nor any of our firm's related persons have discretionary authority in making the
determination of the brokers with whom orders for the purchase or sale of securities are placed for
execution, and the commission rates at which such securities transactions are effected. We routinely
recommend that a client directs us to execute through a specified broker-dealer. Our firm recommends
the use of LPL Financial. Each client that chooses LPL Financial will be required to establish an
account if not already done. Please note that not all advisers have this requirement.
LPL Financial may provide economic benefits for certain representatives attending industry-related
conferences.
Clients may direct their brokerage transactions at a firm other than LPL Financial. However, we may
be unable to achieve more favorable executions of client transactions. Client directed brokerage may
cost clients more money. For example, in a directed brokerage account, you may pay higher brokerage
commissions because we may not be able to aggregate orders to reduce transaction costs, or you may
receive less favorable prices.
Item 13 Review of Accounts
For those clients to whom Maryland Financial Group, Inc. provides investment supervisory services,
account reviews are conducted at least annually by the Maryland Financial Group, Inc. principals and/or
representatives; our Custodian provides a scoring system to ensure client objectives are aligned with
investments. All investment supervisory clients are advised that it remains their responsibility to advise
Maryland Financial Group, Inc. of any changes in their investment objectives and/or financial situation.
All clients are encouraged to review financial planning issues (to the extent applicable), investment
objectives and account performance with their investment advisor representative on an annual basis.
.
18
Maryland Financial Group, Inc. may also conduct account reviews based on the occurrence of a
triggering event, such as a change in client investment objectives and/or financial situation, market
corrections, and by client request.
Clients are provided, at least quarterly, with written transaction confirmation notices and regular written
summary account statements directly from the broker-dealer/custodian and/or program sponsor for the
client accounts. Maryland Financial Group, Inc. may also provide a written periodic report
summarizing account activity and performance.
Item 14 Client Referrals and Other Compensation
Maryland Financial Group, Inc. receives an economic benefit from LPL Financial in reimbursement for
marketing related expenses. Please see detailed discussion of the categories of marketing related
expenses and potential conflicts of interest in Item 12 Brokerage Practices.
Maryland Financial Group, Inc. and employees may receive additional compensation from product
sponsors. However, such compensation may not be tied to the sales of any products. Compensation
may include such items as gifts valued at less than $100 annually, an occasional dinner or ticket to a
sporting event, or reimbursement in connection with educational meetings with investment advisor
representative, client workshops or events, marketing events or advertising initiatives, including
services for identifying prospective clients. Product sponsors may also pay for, or reimburse Maryland
Financial Group, Inc. for the costs associated with, education or training events that may be attended
by Maryland Financial Group, Inc. employees and investment advisor representatives and for Maryland
Financial Group, Inc. sponsored conferences and events.
Maryland Financial Group, Inc. may enter into agreements to compensate promoters by paying them
a portion of the overall advisory fees up to 40% for client referrals. Clients will not pay a higher fee to
account for the portion paid to a promoter. Promoters are limited solely to the introduction of
prospective clients, they are not permitted to provide investment advice and have no authority or
power to bind or obligate Maryland Financial Group, Inc. in any manner.
Before entering into a Solicitation Agreement, the CCO will confirm that the other party is registered
with the appropriate regulatory authorities where required. Any referral arrangements will comply with
applicable laws that govern:
the nature of the service,
fees to be paid,
•
•
• disclosures to clients; and,
• any necessary client consents.
For those promoters located in the State of California, Maryland Financial Group, Inc. will ensure that
the compensated person(s) is properly registered as a promoter(s) in accordance with CCR
206.236(c) (2).
Item 15 Custody
Fee Deduction
Maryland Financial Group, Inc. does not have physical custody of client funds or securities but we may
have constructive custody based on an ability to deduct advisory fees. A qualified custodian (LPL
Financial or Schwab) maintains custody of client funds and securities in a separate account for each
19
client under the client's name. The custodian sends account statements showing all transactions,
positions, and all deposits and withdrawals of principal and income. Clients should carefully review
those account statements.
Disbursement Authorization
Our clients may establish standing authorization for our firm, through the client's acting custodian(s), to
assist with client requested transfers and/or disbursements. Where we have standing authorization to
transfer and/or disburse client funds, and such arrangements meet the criteria set forth in the SEC
Custody Rule guidance, we are deemed to have custody.
Consequently, we have taken steps to implement controls in efforts to comply with the SEC's Custody
Rule guidance, including, but not limited to: (1) adhering to the seven conditions specific to Standing
Letters of Authorization delineated in the SEC No-Action Letter; and, (2) amending our Form ADV.
Since many of the seven conditions involve the qualified custodian's operations, we will collaborate
closely with our clients' acting custodian(s) in efforts to ensure that the representations are being
satisfied.
We do not have physical custody of client funds or securities. All client assets are maintained with a
qualified custodian.
Miscellaneous
There are certain securities managed as part of the account that may be held at a third party. For
example, variable annuities, hedge funds and managed futures are often held directly with the
investment sponsor. For those outside positions, client will receive confirmations and statements
directly from the investment sponsor.
For outside positions not custodied at LPL, LPL may receive information (e.g., number of shares held
and market value) from the investment sponsor and display that information on statements and reports
prepared by LPL. Such information also may be used to calculate performance in performance reports
prepared by LPL. Clients should refer to the statements and reports received directly from the
investment sponsor and compare them with the information provided in any statements or reports from
LPL. The statements and reports provided by LPL with respect to outside positions should not replace
the statements and reports received directly from the investment sponsor.
Item 16 Investment Discretion
The client can determine to engage the Maryland Financial Group, Inc. to provide investment advisory
services on a discretionary basis. Prior to the Maryland Financial Group, Inc. assuming discretionary
authority over a client's account, the client shall be required to execute an Investment Advisory
Agreement, naming the Maryland Financial Group, Inc. as the client's attorney and agent in fact,
granting the Maryland Financial Group, Inc. full authority to buy, sell, or otherwise effect investment
transactions involving the assets in the client's name found in the discretionary account without
approval prior to each transaction.
Clients who engage Maryland Financial Group, Inc. on a discretionary basis may, at any time,
impose restrictions, in writing, on the Maryland Financial Group, Inc. discretionary authority (i.e. limit
the types/amounts of particular securities purchased for their account, exclude the ability to purchase
securities with an inverse relationship to the market, limit or proscribe the use of margin, etc.).
20
If you enter into non-discretionary arrangements with our firm, we will obtain your approval prior to the
execution of any transactions for your account(s). You have an unrestricted right to decline to
implement any advice provided by our firm on a non-discretionary basis.
Item 17 Voting Client Securities
Maryland Financial Group, Inc. does not vote client proxies but third-party money managers selected
or recommended by our firm may vote proxies for clients. Clients will otherwise receive their proxies or
other solicitations directly from their custodian. Clients may contact Maryland Financial Group, Inc. at
(301) 251-8550 to discuss any questions they may have with a particular solicitation.
Item 18 Financial Information
Our firm has an existing loan with LPL Financial resulting from transition and working capital loans.
This arrangement is a conflict of interest that must be disclosed as there is a financial interest /
obligation with LPL Financial for whom we primarily conduct our firm's trading activity. In efforts to
mitigate this conflict, we provide this disclosure. Our firm and its investment adviser representatives
are fiduciaries and will always act in our client's best interest.
Maryland Financial Group, Inc. does not require or solicit prepayment of more than $1,200 in fees per
client, six months or more in advance.
There are no financial conditions that are reasonably likely to impair the firm's ability to meet
contractual commitments to clients. At no time has Maryland Financial Group, Inc. been the subject of
a bankruptcy petition.
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Primary Brochure: WRAP PROGRAM BROCHURE (2025-06-12)
View Document Text
Maryland Financial Group, Inc.
806 Twin Oaks Drive
Rockville, MD 20854
Telephone: (301) 251 - 8550
Fax: (301) 251-8554
Wrap Program Disclosure Brochure
June 12, 2025
This wrap fee program brochure provides information about the qualifications and business practices
of Maryland Financial Group, Inc. If you have any questions about the contents of this brochure, please
contact us at (301) 251-8550. 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.
Maryland Financial Group, Inc. is a registered investment adviser. Registration of an investment
adviser does not imply any level of skill or training. The oral and written communications of an adviser
provide you with information about which you determine to hire or retain an adviser.
Additional information about Maryland Financial Group, Inc. also is available on the SEC's website at
www.adviserinfo.sec.gov.
1
Item 2 Summary of Material Changes
Since its last annual update of February 24, 2024, Maryland Financial Group, Inc. ("Maryland
Financial, MFG, we, us, our, our") below are the material changes to this Disclosure Brochure.
Please note that our address has changed from 2600 Tower Oaks Boulevard, Suite 220,
Rockville, MD 20852.
Our new address, effective immediately, is 806 Twin Oaks Drive, Rockville, MD 20854.
We will ensure that you receive a summary of any material changes to this and subsequent Brochures
within 120 days of the close of our business' fiscal year. We may further provide other ongoing
disclosure information about material changes as necessary. We will further provide you with a new
Brochure as necessary based on changes or new information, at any time, without charge.
Currently, our brochure maybe requested by contacting Amy F. Cox, Chief Compliance Officer at (301)
251-8550 or amycox@tmg-llc.net. We will provide you with a new brochure at any time without
charge.
Additional information about Maryland Financial Group is also available via the SEC's
website www.adviserinfo.sec.gov. The SEC's website also provides information about any persons
affiliated with Maryland Financial Group, Inc. who are registered, or are required to be registered, as
investment adviser representatives of Maryland Financial Group, Inc.
2
Item 3 Table of Contents
Item 1 Cover Page
Item 2 Summary of Material Changes
Item 3 Table of Contents
Item 4 Services, Fees and Compensation
Item 5 Account Requirements and Types of Clients
Item 6 Portfolio Manager Selection and Evaluation
Item 7 Client Information Provided to Portfolio Managers
Item 8 Client Contact with Portfolio Managers
Item 9 Additional Information
Page 1
Page 2
Page 3
Page 4
Page 6
Page 7
Page 10
Page 10
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3
Item 4 Services, Fees and Compensation
Services
Maryland Financial Group, Inc. ("MFG") is a corporation organized under the laws of Maryland. The
Monitor Group, LLC acquired the Rockville, MD-based investment advisory firm in 2005 and is the
principal owner. Christopher Cox and Amy Cox are the Managing Members and owners of The Monitor
Group, LLC. MFG is registered as an investment advisory firm with the Securities and Exchange
Commission ("SEC").
Maryland Financial Group, Inc. ("Advisor") offers asset management services based on the individual
needs of the client. This Brochure provides a description of the advisory services offered under the
Maryland Financial Group wrap program. For more information about Advisor's other investment
advisory services, please contact Advisor for a copy of a similar brochure that describes such services
or go to www.adviserinfo.sec.gov.
In the Maryland Financial Group Wrap program, Advisor provides ongoing investment advice and
management on assets in the client's account. Advisor provides advice on the purchase and sale of
various types of investments, such as mutual funds, exchange-traded funds ("ETFs"), variable annuity
subaccounts, equities, fixed income securities. Advisor provides advice that is tailored to the individual
needs of the client based on the investment objective chosen by the client. Clients may impose
restrictions on investing in certain securities or groups of securities by indicating in the written advisory
agreement with Advisor.
Advisor provides management services on a discretionary basis. The client authorizes the Advisor to
have discretion by signing an advisory agreement.
Assets for program accounts are held at LPL Financial ("LPL") as custodian. LPL also acts as
executing broker/dealer for transactions placed in program accounts, and provides other administrative
services as described throughout this Brochure.
As of December 31, 2024, we managed approximately $880,267,065 million in client assets on a
discretionary basis. Information about our asset management services is available upon request.
Fees
In the Maryland Financial Group Wrap program, clients pay Advisor a single annual advisory fee for
advisory services and execution of transactions. Clients do not pay brokerage commissions, markups
or transaction charges for execution of transactions in addition to the advisory fee. The advisory fee is
negotiable between the client and the Advisor and is set out in the advisory agreement. The advisory
fee is a percentage based on the value of all assets in the account, including cash holdings. The
advisory fee may be higher than the fee charged by other investment advisors for similar services.
The advisory fee is paid to Advisor and is shared between Advisor and its associated persons. Advisor
does not accept performance-based fees for program accounts.
Assets under Management
Maximum Annual Fee
$0 to $249,999
2.35%
Next $250,000 to $499,999
2.00%
Next $500,000 to $999,999
1.75%
4
Next $1,000,000
1.50%
The advisory fee is deducted from the account by LPL as the custodian of assets based on a written
authorization from the client. LPL calculates and deducts the advisory fee quarterly in advance. If the
advisory agreement is terminated before the end of the quarterly period, client is entitled to a pro-rated
refund of any pre-paid quarterly advisory fee based on the number of days remaining in the quarter
after the termination date.
Although clients do not pay a transaction charge for transactions in a program account, clients should
be aware that Advisor pays LPL transaction charges for the transactions. The transaction charges
paid by Advisor vary based on the type of transaction (e.g., mutual fund, equity or fixed income
security) and range from $0 to $50. Because Advisor pays the transaction charges in program
accounts, there is a conflict of interest. Clients should understand that the cost to Advisor of
transaction charges may be a factor that the Advisor considers when deciding which securities to
select and how frequently to place transactions in a program account.
Other Types of Fees and Charges
Program accounts will incur additional fees and charges from parties other than the Advisor as noted
below. These fees and charges are in addition to the advisory fee paid to Advisor. Advisor does not
share in any portion of these third-party fees.
LPL, as the custodian and broker-dealer providing brokerage and execution services on program
accounts, will impose certain fees and charges. LPL notifies clients of these charges at account
opening and makes available a list of these fees and charges on its website at www.lpl.com. LPL will
deduct these fees and charges directly from the client's program account.
There are other fees and charges that are imposed by other third parties that apply to investments in
program accounts. Some of these fees and charges are described below.
•
If a client's assets are invested in mutual funds or other pooled investment products, clients
should be aware that there will be two layers of advisory fees and expenses for those assets.
Client will pay an advisory fee to the fund manager and other expenses as a shareholder of the
fund. Client will also pay Advisor the advisory fee with respect to those assets. Most of the
mutual funds available in the program may be purchased directly. Therefore, clients could
generally avoid the second layer of fees by not using the management services of Advisor and
by making their own investment decisions.
•
• Certain mutual funds impose fees and charges such as contingent deferred sales charges,
early redemption fees and charges for frequent trading. These charges may apply if client
transfers into or purchases such a fund with the applicable charges in a program account.
• Although only no-load and load-waived mutual funds can be purchased in a program account,
client should understand that some mutual funds pay asset based sales charges or service fees
(e.g., 12b-1 fees) to the custodian with respect to account holdings.
If client holds a variable annuity as part of an account, there are mortality, expense and
administrative charges, fees for additional riders on the contract and charges for excessive
transfers within a calendar year imposed by the variable annuity sponsor.
Further information regarding fees assessed by a mutual fund, or variable annuity is available in the
appropriate prospectus, which is available upon request from the Advisor or from the product sponsor
directly.
5
Other Important Considerations
• The advisory fee is an ongoing wrap fee for investment advisory services, the execution of
transactions and other administrative and custodial services. The advisory fee may cost the
client more than purchasing the program services separately, for example, paying an advisory
fee plus commissions for each transaction in the account. Factors that bear upon the cost of
the account in relation to the cost of the same services purchased separately include the type
and size of the account, historical and or expected size or number of trades for the account,
and number and range of supplementary advisory and client-related services provided to the
client.
• The advisory fee also may cost the client more than if assets were held in a traditional
brokerage account. In a brokerage account, a client is charged a commission for each
transaction, and the representative has no duty to provide ongoing advice with respect to the
account. If the client plans to follow a buy and hold strategy for the account or does not wish to
purchase ongoing investment advice or management services, the client should consider
opening a brokerage account rather than a program account.
• The Advisor recommending the program to the client receives compensation as a result of the
client's participation in the program. This compensation includes the advisory fee and also may
include other compensation, such as bonuses, awards or other things of value offered by LPL
to the Advisor or its associated persons. The amount of this compensation may be more or
less than what the Advisor would receive if the client participated in other LPL programs,
programs of other investment advisors or paid separately for investment advice, brokerage and
other client services. Therefore, the Advisor may have a financial incentive to recommend a
program account over other programs and services.
• The investment products available to be purchased in the program can be purchased by clients
outside of a program account, through broker-dealers or other investment firms not affiliated
with Advisor.
Item 5 Account Requirements and Types of Clients
A minimum account value of $25,000 is generally required for the program. We, at our sole discretion,
may accept clients with smaller portfolios based upon certain factors including:
related accounts (including family members), and
• anticipated future earning capacity,
• anticipated future additional assets,
• account composition,
•
• pre-existing client relationships
We provide advisory services primarily to high-net-worth individuals, including their trusts, estates and
retirement accounts. We also provide services to corporations or business entities including their
pension and profit-sharing plans.
6
Item 6 Portfolio Manager Selection and Evaluation
In the Maryland Financial Group Wrap program, Advisor does not select, review or recommend other
investment advisors or portfolio managers. Advisor, through its associated persons, is responsible for
the investment advice and management offered to clients. Advisor generally requires that individuals
involved in determining or giving investment advice have experience with large retail bank and/or
brokerage firms.
For more information about the associated person of Advisor managing the account, client should refer
to the Brochure Supplement for the associated person, which client should have received along with
this Brochure at the time client opened the account.
LPL performs certain administrative services for Advisor, including generation of quarterly performance
reports for program accounts. Client will receive an individual quarterly performance report, which
provides performance information on a time weighted basis. The performance reports are intended to
inform clients as to how their investments have performed for a period, both on an absolute basis and
compared to leading investment indices.
Methods of Analysis and Investment Strategies
• Alternative Strategy Mutual Funds. Certain mutual funds available in the program invest
primarily in alternative investments and/or strategies. Investing in alternative investments and/or
strategies may not be suitable for all investors and involves special risks, such as risks
associated with commodities, real estate, leverage, selling securities short, the use of
derivatives, potential adverse market forces, regulatory changes and potential illiquidity. There
are special risks associated with mutual funds that invest principally in real estate securities,
such as sensitivity to changes in real estate values and interest rates and price volatility
because of the fund's concentration in the real estate industry.
• Closed-End Funds. Client should be aware that closed-end funds available within the program
are not readily marketable. In an effort to provide investor liquidity, the funds may offer to
repurchase a certain percentage of shares at net asset value on a periodic basis. Thus, clients
may be unable to liquidate all or a portion of their shares in these types of funds.
• Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally
classified as open end mutual funds or UITs. However, they differ from traditional mutual funds,
in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and
sold throughout the trading day like shares of other publicly traded companies. ETF shares may
trade at a discount or premium to their net asset value. This difference between the bid price
and the ask price is often referred to as the "spread." The spread varies over time based on the
ETF's trading volume and market liquidity and is generally lower if the ETF has a lot of trading
volume and market liquidity and higher if the ETF has little trading volume and market liquidity.
Although many ETFs are registered as an investment company under the Investment Company
Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in
commodities, are not registered as an investment company.
• Exchange-Traded Notes (ETNs). An ETN is a senior unsecured debt obligation designed to
track the total return of an underlying market index or other benchmark. ETNs may be linked to
a variety of assets, for example, commodity futures, foreign currency and equities. ETNs are
similar to ETFs in that they are listed on an exchange and can typically be bought or sold
throughout the trading day. However, an ETN is not a mutual fund and does not have a net
asset value; the ETN trades at the prevailing market price. Some of the more common risks of
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an ETN are as follows. The repayment of the principal, interest (if any), and the payment of any
returns at maturity or upon redemption are dependent upon the ETN issuer's ability to pay. In
addition, the trading price of the ETN in the secondary market may be adversely impacted if the
issuer's credit rating is downgraded. The index or asset class for performance replication in an
ETN may or may not be concentrated in a specific sector, asset class or country and may
therefore carry specific risks.
• Leveraged and Inverse ETFs, ETNs and Mutual Funds. Leveraged ETFs, ETNs and mutual
funds, sometimes labeled "ultra" or "2x" for example, are designed to provide a multiple of the
underlying index's return, typically on a daily basis. Inverse products are designed to provide
the opposite of the return of the underlying index, typically on a daily basis. These products are
different from and can be riskier than traditional ETFs, ETNs and mutual funds. Although these
products are designed to provide returns that generally correspond to the underlying index, they
may not be able to exactly replicate the performance of the index because of fund expenses
and other factors. This is referred to as tracking error. Continual re-setting of returns within the
product may add to the underlying costs and increase the tracking error. As a result, this may
prevent these products from achieving their investment objective. In addition, compounding of
the returns can produce a divergence from the underlying index over time, in particular for
leveraged products. In highly volatile markets with large positive and negative swings, return
distortions are magnified over time. Because of these distortions, these products should be
actively monitored, as frequently as daily, and are generally not appropriate as an intermediate
or long-term holding. To accomplish their objectives, these products use a range of strategies,
including swaps, futures contracts and other derivatives. These products may not be diversified
and can be based on commodities or currencies. These products may have higher expense
ratios and be less tax-efficient than more traditional ETFs, ETNs and mutual funds.
• Options. Certain types of option trading are permitted in order to generate income or hedge a
security held in the program account; namely, the selling (writing) of covered call options or the
purchasing of put options on a security held in the program account. Client should be aware
that the use of options involves additional risks. The risks of covered call writing include the
potential for the market to rise sharply. In such case, the security may be called away and the
program account will no longer hold the security. The risk of buying long puts is limited to the
loss of the premium paid for the purchase of the put if the option is not exercised or otherwise
sold by the program account.
• Structured Products. Structured products are securities derived from another asset, such as a
security or a basket of securities, an index, a commodity, a debt issuance, or a foreign
currency. Structured products frequently limit the upside participation in the reference asset.
Structured products are senior unsecured debt of the issuing bank and subject to the credit risk
associated with that issuer. This credit risk exists whether or not the investment held in the
account offers principal protection. The creditworthiness of the issuer does not affect or
enhance the likely performance of the investment other than the ability of the issuer to meet its
obligations. Any payments due at maturity are dependent on the issuer's ability to pay. In
addition, the trading price of the security in the secondary market, if there is one, may be
adversely impacted if the issuer's credit rating is downgraded. Some structured products offer
full protection of the principal invested, others offer only partial or no protection. Investors may
be sacrificing a higher yield to obtain the principal guarantee. In addition, the principal
guarantee relates to nominal principal and does not offer inflation protection. An investor in a
structured product never has a claim on the underlying investment, whether a security, zero
coupon bond, or option. There may be little or no secondary market for the securities and
information regarding independent market pricing for the securities may be limited. This is true
even if the product has a ticker symbol or has been approved for listing on an exchange. Tax
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treatment of structured products may be different from other investments held in the account
(e.g., income may be taxed as ordinary income even though payment is not received until
maturity). Structured CDs that are insured by the FDIC are subject to applicable FDIC limits.
• Hedge Funds and Managed Futures. Hedge and managed futures funds are available for
purchase in the program by clients meeting certain qualification standards. Investing in these
funds involves additional risks including, but not limited to, the risk of investment loss due to the
use of leveraging and other speculative investment practices and the lack of liquidity and
performance volatility. In addition, these funds are not required to provide periodic pricing or
valuation information to investors and may involve complex tax structures and delays in
distributing important tax information. Client should be aware that these funds are not liquid as
there is no secondary trading market available. At the absolute discretion of the issuer of the
fund, there may be certain repurchase offers made from time to time. However, there is no
guarantee that client will be able to redeem the fund during the repurchase offer.
• Variable Annuities. If client purchases a variable annuity that is part of the program, client will
receive a prospectus and should rely solely on the disclosure contained in the prospectus with
respect to the terms and conditions of the variable annuity. Client should also be aware that
certain riders purchased with a variable annuity may limit the investment options and the ability
to manage the subaccounts.
• Margin Accounts. Client should be aware that margin borrowing involves additional risks.
Margin borrowing will result in increased gain if the value of the securities in the account go up,
but will result in increased losses if the value of the securities in the account goes down. The
custodian, acting as the client's creditor, will have the authority to liquidate all or part of the
account to repay any portion of the margin loan, even if the timing would be disadvantageous to
the client. For performance illustration purposes, the margin interest charge will be treated as a
withdrawal and will, therefore, not negatively impact the performance figures reflected on the
quarterly advisory reports.
It is important to note that no methodology or investment strategy is guaranteed to be successful or
profitable. All investments involve risks that can result in loss:
loss of principal,
•
• a reduction in earnings (including interest, dividends and other distributions), and
•
the loss of future earnings
Additionally, these risks may include:
interest rate risk,
issuer risk, and
• market risk,
•
•
• general economic risk
Although we manage your portfolio in a manner consistent with your risk tolerances, we cannot
guarantee that our efforts will be successful. You should be prepared to bear the risk of loss.
You must also be aware that the use of margin, options and short sales are higher risk strategies. It is
possible to lose all of the principal you invest, and sometimes more. In a cash account, your risk is
limited to the amount of money that you have invested. In a margin account, your risk includes the
amount of money invested plus the amount that has been loaned to you. When you short sell, your
losses can be infinite.
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Voting Client Securities
Advisor does not accept authority to vote client securities. Clients retain the right to vote all proxies that
are solicited for securities held in the account. Clients will receive proxies or other solicitations from the
custodian of assets. If clients have questions regarding the solicitation, they should contact the Advisor
or the contact person that the issuer identifies in the proxy materials. In addition, Advisor does not
accept authority to take action with respect to legal proceedings relating to securities held in the
account.
Item 7 Client Information Provided to Portfolio Managers
In the Maryland Financial Group Wrap program, the Advisor is responsible for account management;
there is no separate portfolio manager involved. The Advisor obtains the necessary financial data from
the client and assists the client in setting an appropriate investment objective for the account. The
Advisor obtains this information by having the client complete an advisory agreement and other
documentation. Clients are encouraged to contact the Advisor if there have been any changes in the
client's financial situation or investment objectives or if they wish to impose any reasonable restrictions
on the management of the account or reasonably modify existing restrictions. Client should be aware
that the investment objective selected for the program is an overall objective for the entire account and
may be inconsistent with a particular holding and the account's performance at any time. Client should
further be aware that achievement of the stated investment objective is a long-term goal for the
account.
Item 8 Client Contact with Portfolio Managers
Client should contact Advisor at any time with questions regarding program account.
Item 9 Additional Information
Disciplinary Information
We have not been the subject of any legal or disciplinary events that would be material to your
evaluation of our business or the integrity of our management.
Other Financial Industry Activities and Affiliations
Advisor is only in the business of providing investment advice.
Investment advisor representatives may also be registered representatives of LPL Financial LLC
("LPL"), an unaffiliated SEC registered and FINRA/SIPC member broker/dealer. In their capacity as
registered representatives, these persons will receive commission-based compensation in connection
with the purchase and sale of securities, including 12b-1 fees for the sale of investment company
products. Compensation earned by these persons in their capacities as registered representatives is
separate and in addition to our advisory fees. These practices present a conflict of interest because
persons providing investment advice on behalf of our firm who are registered representatives have a
financial incentive to effect securities transactions in accounts held with LPL.
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Investment Adviser Representatives of our firm may also be registered as investment adviser
representatives of LPL Financial LLC, an SEC registered investment adviser (and Broker-Dealer as
disclosed above). Any compensation earned in this separate capacity is separate and apart from the
advisory fees charged by our firm.
We are affiliated with ABC Holding of the MidAtlantic and Southeast, LLC through common control and
ownership, an affiliated insurance agency. Persons providing investment advice on behalf of our firm
may be licensed as insurance agents with this affiliate, other non-affiliated insurance agencies, or as
independent insurance agents. These persons will earn commission-based compensation for selling
insurance products to you. Compensation earned by these persons in their capacities as licensed
insurance agents is separate and in addition to our advisory fees. These practices present a conflict of
interest because persons providing investment advice on behalf of our firm who are licensed insurance
agents have a financial incentive to sell you insurance products.
You are under no obligation, contractually or otherwise, to purchase securities and/or
insurance products through any person or entity affiliated with our firm.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A copy of Advisor's code of ethics is available to clients or prospective clients upon request by
contacting Amy Cox at (301) 251-8550 or amycox@tmg-llc.net
We have adopted a Code of Ethics ("Code") to address the securities-related conduct of our advisory
representatives and employees. The Code includes our policies and procedures developed to protect
your interests in relation to the following:
•
•
•
•
•
the duty at all times to place your interests ahead of ours;
that all personal securities transactions of our advisory representatives and employees be
conducted in a manner consistent with the Code and avoid any actual or potential conflict of
interest, or any abuse of an advisory representative's or employee's position of trust and
responsibility;
that advisory representatives may not take inappropriate advantage of their positions;
that information concerning the identity of your security holdings and financial circumstances
are confidential; and,
that independence in the investment decision-making process is paramount
We will provide a copy of the Code to you or any prospective client upon request. We do not buy or sell
securities for our firm that we also recommend to clients. However, our advisory representatives and
employees are permitted to buy or sell the same securities for their personal and family accounts that
are bought or sold for your account(s). The personal securities transactions by advisory
representatives and employees may raise potential conflicts of interest when they trade in a security
that is:
• owned by you or
• considered for purchase or sale for you
We have adopted policies and procedures that are intended to address these conflicts of interest.
These policies and procedures:
require our advisory representatives and employees to act in your best interest;
•
• prohibit favoring one client over another; and,
• provide for the review of transactions to discover and correct any same-day trades that result in
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an advisory representative or employee receiving a better price than a client.
Advisory representatives and employees must follow our procedures when purchasing or selling the
same securities purchased or sold for you.
Review of Accounts
In addition, all program accounts are subjected to a risk based exception reporting system that flags
accounts on a quarterly basis for criteria such as performance, trading activity, and concentration. The
exception reporting identifies accounts where additional scrutiny or analysis by Advisor may be
appropriate.
During any month that there is activity in the program account, client will receive a monthly account
statement from LPL showing account activity as well as positions held in the account at month end.
Additionally, client will receive a confirmation of each transaction that occurs within the program
account unless the transaction is the result of a systematic purchase, redemption or exchange. Client
will also receive a detailed quarterly report showing performance, positions and activity from LPL.
Other Compensation
Advisor and its associated persons may receive additional non-cash compensation from product
sponsors. However, such compensation may not be tied to the sales of any products. Compensation
may include such items as gifts valued at less than $100 annually, an occasional dinner or ticket to a
sporting event, or reimbursement in connection with educational meetings or marketing or advertising
initiatives. Product sponsors may also pay for education or training events that may be attended by
Advisor's employees and associated persons.
We may enter into written compensation agreements ("Solicitation Agreements") with certain
unaffiliated parties. These parties pay Maryland Financial Group a "Solicitor's Fee", which is a
percentage of the fee paid by referred clients. These payments are a portion of the fee customarily
charged and do not result in an increase in the amount of the fee paid by clients. Before entering into a
Solicitation Agreement, the CCO will confirm that the other party is registered with the appropriate
regulatory authorities where required. Any solicitation or referral arrangements will comply with
applicable laws that govern:
the nature of the service;
fees to be paid;
•
•
• disclosures to clients; and,
• any necessary client consents
If we will receive compensation as a Solicitor related to your account, you will receive a written
disclosure identifying the Solicitor and describing the compensation arrangement.
Financial Information
We have no financial commitment that impairs our ability to meet contractual and fiduciary
commitments to you.
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Our firm has an existing loan with LPL Financial resulting from transition and working capital loans.
This arrangement is a conflict of interest that must be disclosed as there is a financial interest /
obligation with LPL Financial for whom we primarily conduct our firm's trading activity. In efforts to
mitigate this conflict, we provide this disclosure. Our firm and its investment adviser representatives
are fiduciaries and will always act in our client's best interest.
Custody
Fee Deduction
Maryland Financial Group, Inc. does not have physical custody of client funds or securities but we may
have constructive custody based on an ability to deduct advisory fees. A qualified custodian (LPL
Financial or Schwab) maintains custody of client funds and securities in a separate account for each
client under the client's name. The custodian sends account statements showing all transactions,
positions, and all deposits and withdrawals of principal and income. Clients should carefully review
those account statements.
Disbursement Authorization
Our clients may establish standing authorization for our firm, through the client's acting custodian(s), to
assist with client requested transfers and/or disbursements. Where we have standing authorization to
transfer and/or disburse client funds, and such arrangements meet the criteria set forth in the SEC
Custody Rule guidance (issued February 2017), we are deemed to have custody.
Consequently, we have taken steps to implement controls in efforts to comply with the SEC's Custody
Rule guidance (SEC No-Action Letter dated February 21, 2017; SEC Custody Rule FAQ II.4; and, IM
Guidance Update No. 2017-01), including, but not limited to: (1) adhering to the seven conditions
specific to Standing Letters of Authorization delineated in the SEC No-Action Letter; and, (2) amending
our Form ADV. Since many of the seven conditions involve the qualified custodian's operations, we will
collaborate closely with our clients' acting custodian(s) in efforts to ensure that the representations are
being satisfied.
We do not have physical custody of client funds or securities. All client assets are maintained with a
qualified custodian.
Miscellaneous
There are certain securities managed as part of the account that may be held at a third party. For
example, variable annuities, hedge funds and managed futures are often held directly with the
investment sponsor. For those outside positions, client will receive confirmations and statements
directly from the investment sponsor.
For outside positions not custodied at LPL, LPL may receive information (e.g., number of shares held
and market value) from the investment sponsor and display that information on statements and reports
prepared by LPL. Such information also may be used to calculate performance in performance reports
prepared by LPL. Although Advisor believes that the information provided by LPL is accurate, Advisor
recommends that clients refer to the statements and reports received directly from the investment
sponsor and compare them with the information provided in any statements or reports from LPL. The
statements and reports provided by LPL with respect to outside positions should not replace the
statements and reports received directly from the investment sponsor.
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Brokerage Practices
In the Maryland Financial Group Wrap program, Advisor requires that clients direct LPL as the sole
and exclusive broker-dealer to execute transactions in the account. LPL is not paid a commission for
executing transactions. Because associated persons of the Advisor are licensed with LPL, this
presents a conflict of interest. Clients should understand that not all advisors require their clients to
direct brokerage. By directing brokerage to LPL, clients may be unable to achieve the most favorable
execution of client transactions. Therefore, directed brokerage may cost clients more money.
Advisor may receive support services and/or products from LPL, which assist the Advisor to better
monitor and service program accounts maintained at LPL. These support services and/or products
may be received without cost, at a discount, and/or at another negotiated rate, and may include the
following:
investment-related research
•
• pricing information and market data
• software and other technology that provide access to client account data
• compliance and/or practice management-related publications
• consulting services
• attendance at conferences, meetings, and other educational and/or social events
• marketing support
• computer hardware and/or software
• other products used by Advisor in furtherance of its investment advisory business operations
Clients do not pay more for services as a result of this arrangement. There is no corresponding
commitment made by the Advisor to LPL or any other entity to invest any specific amount or
percentage of client assets in any specific securities as a result of the arrangement.
Advisor may aggregate transactions in equity and fixed income securities for a client with other clients
to improve the quality of execution. When transactions are so aggregated, the actual prices applicable
to the aggregated transactions will be averaged, and the client account will be deemed to have
purchased or sold its proportionate share of the securities involved at the average price obtained.
Advisor may determine not to aggregate transactions, for example, based on the size of the trades, the
number of client accounts, the timing of the trades, the liquidity of the securities and the discretionary
or non-discretionary nature of the trades. If Advisor does not aggregate orders, some clients
purchasing securities around the same time may receive a less favorable price than other clients. This
means that this practice of not aggregating may cost clients more money.
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