Overview
Assets Under Management: $166 million
Headquarters: SAINT LOUIS, MO
High-Net-Worth Clients: 60
Average Client Assets: $3 million
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Clients
Number of High-Net-Worth Clients: 60
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 83.67
Average High-Net-Worth Client Assets: $3 million
Total Client Accounts: 390
Discretionary Accounts: 390
Regulatory Filings
CRD Number: 154722
Last Filing Date: 2024-03-29 00:00:00
Website: https://mccwm.com
Form ADV Documents
Primary Brochure: ADV 2 AS OF 12312024 (2025-03-28)
View Document Text
th
7733 Forsyth Blvd, 11
Floor| Saint Louis, MO 63105
314.246.0595 | www.mccwm.com
March 27, 2025
This Brochure provides information about the qualifications and business practices of McCartney Wealth
Management LLC. If you have any questions about the contents of this Brochure, please contact us at 314.246.0595
and/or mike@mccwm.com. The information in this Brochure has not been approved or verified by the United States
Securities and Exchange Commission or by any state securities authority.
SEC
McCartney Wealth Management LLC is an investment adviser registered with the Securities and Exchange
”). Registration of an Investment Adviser does not imply any level of skill or training. The oral and
Commission (“
written communications of an Adviser provide you with information about which you determine to hire or retain an
Adviser.
Additional information about McCartney Wealth Management LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov.
Material Changes
Charles Schwab & Co., Inc. (“Schwab”) has announced that as of October 30, 2025, the Automated Investment
Program known as Institutional Intelligent Portfolios (“IIP”) will no longer be available and accounts under that
program will be converted to regular brokerage accounts at Schwab. We at present have five accounts totaling
approximately $240,000, which is only 0.13% of all assets under management. We are in the process of converting
those accounts from IIP, and once that is completed, the Automated Investing Program section of this ADV with
regard to the Program as defined herein will no longer be applicable.
Table of Contents
Advisory Business ................................................................................................................................................................................................... 1
Fees & Compensation ............................................................................................................................................................................................ 2
Performance-Based Fees & Side-By-Side Management .......................................................................................................................... 2
Types of Clients ........................................................................................................................................................................................................ 2
Methods of Analysis, Investment Strategies & Risk of Loss................................................................................................................... 3
Disciplinary Information ...................................................................................................................................................................................... 3
Other Financial Industry Activities & Affiliations ...................................................................................................................................... 3
Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ................................................................. 3
Brokerage Practices ............................................................................................................................................................................................... 4
Review of Accounts ................................................................................................................................................................................................ 5
Client Referrals & Other Compensation ......................................................................................................................................................... 5
Custody ........................................................................................................................................................................................................................ 6
Investment Discretion ........................................................................................................................................................................................... 6
Voting Client Securities ......................................................................................................................................................................................... 6
Financial Information ............................................................................................................................................................................................ 6
Brochure Supplement(s)
Privacy Notice
Advisory Business
MWM
we
us
investment management services are
authority, our
performed on a discretionary basis.
,” “
” or “
”),
McCartney Wealth Management LLC (“
founded in 2010, is an investment adviser registered with the
SEC. MWM is owned 100% by Michael P. McCartney, an
investment adviser representative and licensed attorney in
the State of Missouri.
MWM is a “fee-only” investment adviser. This means that we
do not accept any commissions, finders’ fees, referral fees or
traditional “soft dollar” items such as software or research
reports in exchange for referring clients’ brokerage to a
particular broker-dealer.
We provide performance reports at least semi-annually and
offer to hold review meetings with clients to discuss these
reports at least annually. Our services also include reviewing
a client’s existing portfolio manager and broker-dealer
for performance and/or cost efficiency,
arrangements
conducting due diligence on particular
investment
opportunities, or providing advice on investments in real
estate or other investment opportunities. Periodically, we
send an electronic newsletter to clients and prospects
summarizing the market and discussing various investment
or planning topics in a general manner, and there is no
additional charge for such newsletter.
Brochure
With Mike McCartney having advised Fortune 50 executives
for over 20 years, we offer clients tools developed in the
financial and legal worlds. Our strategies use a low cost,
academic approach to investing. The result is simplicity,
organization, and discipline for clients in their investment and
planning affairs.
We may provide all personal financial information to clients,
including statements, electronically through access to a web
portal or by email, including clients’ quarterly invoice, notices
and other communications and disclosures, including our
annual delivery of this disclosure brochure (“
”).
Upon request, we will provide any client a paper copy of this
Brochure free of charge.
Client Agreement
fee-only
(no
Client typically engages us for both financial planning and
investment management services, as agreed in the agreement
between the client and us (the “
”). We do
Automated Investment Program
not participate in any wrap-fee programs whatsoever.
Our investment approach is based upon academic research as
opposed to Wall Street. Challenging conventional wisdom that
stock picking and market timing are the way to invest, we
incorporate the academic research to provide superior wealth
management advice in a diversified, cost effective and tax
efficient manner. Our
commission)
compensation structure assures NO conflicts of interest,
allowing us to do what is best for our clients.
Financial Planning
We offer the following investment advisory services:
Program
ETFs
CS&Co
Platform
SPT
Schwab
The centerpiece of our service is the planning process where
we work closely with clients and their other professional
advisors, such as attorneys, accountants, and insurance
providers, to develop detailed strategies in the critical areas
of goals, cash flow, taxes, investments, retirement and estate
planning. We help a client assess the client’s current situation
and set personal and financial goals, help a client develop
strategies and identify the first action steps and then
implement the client’s plan. We then monitor and refine the
client’s plan on a continuous basis to help the client meet new
situations as they arise. MWM is not a law firm and neither
MWM nor Mr. McCartney provide any legal services through
Investment Management
MWM.
System
In addition to our financial planning and investment
management services, we offer an automated investment
program (“
”) through which a small number of
clients (approximately 4) are invested in a range of
investment strategies we have constructed and manage, each
consisting of a portfolio of exchange-traded funds (“
”) or
mutual funds and a cash allocation. The client’s portfolio is
held in a brokerage account opened by the client at Charles
”). We use the Institutional
Schwab & Co., Inc. (“
”), offered by
Intelligent Portfolios® platform (“
Schwab Performance Technologies (“
”), a software
provider to independent investment advisors and an affiliate
of CS&Co., to operate the Program. We are independent of and
not owned by, affiliated with, or sponsored or supervised by
SPT, CS&Co., or their affiliates (together, “
”). We, and
not Schwab, are the client’s investment adviser and primary
point of contact with respect to the Program. We are solely
responsible, and Schwab is not responsible, for determining
the appropriateness of the Program for the client, choosing a
suitable investment strategy and portfolio for the client’s
investment needs and goals, and managing that portfolio on
an ongoing basis. We have contracted with SPT to provide us
with the Platform, which consists of technology and related
trading and account management services for the Program.
The Platform enables us to make the Program available to
clients online and includes a system that automates certain
key parts of our investment process (the “
”). The
System includes an online questionnaire that helps us
investment objectives and risk
determine the client’s
tolerance and select an appropriate investment strategy and
portfolio. Clients should note that we will recommend a
portfolio via the System in response to the client’s answers to
Academic research and financial science lead the way in
understanding risk and return in securities markets. We
utilize this research and science in the development of tax
efficient, diversified portfolios for its clients. We help a client
assess their current situation and set investment goals; help a
client develop greater insight into the capital markets, design
a personalized investment strategy and create plan, and then
help implement, maintain, and refine the client’s plan. As part
of this process, we design a customized client portfolio based
upon an asset allocation strategy that is consistent with the
client’s investment objectives, risk tolerance and investment
time horizon or liquidity needs. On an ongoing basis, we
monitor the performance of a client’s portfolio and may
suggest rebalancing as necessary to conform to the
recommended allocation. Unless a client elects to restrict our
1
“Brokerage Practices”
Under the Program, clients do not pay fees to SPT or
brokerage commissions or other fees to CS&Co. as part of the
Program. Schwab does receive other revenues in connection
with the Program. Brokerage arrangements are further
described under
below. We charge a flat
0.50% or 0.60% annual fee for assets under management in
the Program depending upon the selection, which will be
General Fee Matters
billed as described below.
the online questionnaire. The client may then indicate an
interest in a portfolio that is one level less or more
conservative or aggressive than the recommended portfolio,
but we then make the final decision and select a portfolio
based on all the information we have about the client. The
System also includes an automated investment engine
through which we manage the client’s portfolio on an ongoing
basis through automatic rebalancing and tax-loss harvesting
if the client is eligible and elects.
“Fees & Compensation.”
We charge clients a fee for our services as described below
under
Our fees are not set or
supervised by Schwab. Clients do not pay brokerage
commissions or any other fees to CS&Co. as part of the
Program. Schwab does receive other revenues in connection
with the Program.
All fees set forth above are billed quarterly in advance. The fee
does not include custodial fees, transaction costs or other
expenses charged by the client’s custodian or broker. Each
mutual fund or ETF in which the client’s assets may be
invested charges its own advisory fee and other expenses.
However, we do not use funds that charge front-end or
ongoing loads or 12(b)-1 fees. Fees do not include travel or
other expenses we incur.
We do not pay SPT fees for the Platform so long as we
maintain $100 million in client assets in accounts at CS&Co.
that are not enrolled in the Program. If we do not meet this
condition, then we pay SPT an annual licensing fee of 0.10%
on the value of our clients’ assets in the Program.
Program
Before enrolling in the Program, you should carefully review
Disclosure Brochure
the Program’s Disclosure Brochure
(the
“
A Client Agreement also may be terminated by either client or
us upon ten days’ prior written notice. Clients who terminate
their Client Agreement will receive a refund of the portion of
any fee paid but not yet earned as of the date such notice is
received, less any expenses we have incurred up to and
including that date.
Fees are negotiable and may be waived
in certain
circumstances (e.g., for family members and friends of
McCartney Wealth Management employees).
”) to understand the limitations and
risks of the Program. Clients should understand that the
Program is operated by Schwab, and its effectiveness for a
particular client will depend significantly on the System’s
capabilities. Any malfunction by the Program could result in
loss outside of MWM’s control.
As of December 31, 2024, we had approximately
$188,452,497 in assets under management, all of which is on
Fees & Compensation
a discretionary basis.
Financial Planning Fees
The specific manner in which our fees are charged is
established in the Client Agreement. We believe that our fees
are reasonable considering the services, but lower fees for
“Brokerage Practices”
comparable services may be available from other sources.
below further describes the factors that
we consider in selecting or recommending broker-dealers for
client transactions and determining the reasonableness of
Performance-Based Fees & Side-By-Side
their compensation (e.g., commissions).
Management
We do not charge performance-based fees (fees based on a
share of capital gains on or capital appreciation of the assets
Types of Clients
of a client).
We normally charge, subject to negotiation, 15-20 basis
points per year of their assets under management with us for
basic financial planning, including preparing a comprehensive
financial plan, and basic estate and tax planning. Fees for
sophisticated and more complex planning will be discussed
and negotiated on a case-by-case basis. A client will pay the
annual financial planning fee in quarterly installments in
Investment Management Fees
advance.
Our investment management fees are a percentage of client
Market Value of Assets Annual Fee
assets we manage as follows:
We presently provide investment management and financial
planning services to
individuals and high net worth
individuals, and in some cases may provide such services to
corporate pension and profit-sharing plans. Except for the
Program, the minimum account size is $500,000, which may
be negotiated on a case-by-case basis.
On the first $1,000,000 1.0%
On the next $1,000,000 0.75%
living
trusts. Clients
On amounts over $2 million 0.50%
When assets reach $3,000,000 or greater, a flat ½ of 1%
Program Fees
(.50%) will be charged on all assets.
Clients eligible to enroll in the Program include individuals,
that are
IRAs, and revocable
organizations (such as corporations and partnerships) or
government entities, and clients that are subject to the
Employee Retirement Income Security Act of 1974, are not
eligible for the Program. The minimum investment required
to open an account in the Program is $5,000. The minimum
account balance to enroll in the Program’s tax-loss harvesting
feature is $50,000.
2
We also provide advisory services to two small qualified
Methods of Analysis, Investment Strategies &
retirement plans whose trustees are also clients of the firm.
Risk of Loss
Our Philosophy
spreads, thus diluting or negating any upward price
movement of the ETF or enhancing any downward price
movement. Also, ETFs require more frequent portfolio
reporting by regulators and are thereby more susceptible to
actions by hedge funds that could have a negative impact on
the price of the ETF. Certain ETFs may employ leverage, which
creates additional volatility and price risk depending on the
amount of leverage utilized, the collateral and the liquidity of
the supporting collateral.
Further, the use of leverage (i.e., employing the use of margin)
results in additional interest costs to the ETF. Certain ETFs are
highly leveraged and therefore have additional volatility and
liquidity risk. Volatility and liquidity can severely and
negatively impact the price of the ETF’s underlying portfolio
securities, thereby causing significant price fluctuations of the
The Program
ETF. We strive to avoid ETFs that use leverage.
Our investment philosophy is grounded in Modern Portfolio
Theory, which refers to the process of reducing risk in a
portfolio through systematic diversification across asset
classes and within those particular asset classes. In addition,
we utilize factor investing as documented by Nobel Prize
Winner Eugene Fama and Kenneth French in their peer
reviewed academic papers. We adhere to the passive style of
investing and, thus, usually recommend indexed and passive
mutual funds. We typically do not recommend individual
stocks, bonds or actively managed mutual funds in our asset
allocation strategies and portfolio recommendations to
clients. Keeping client’s investment fees, expenses and taxes
under control are normally a top priority of our investment
strategy.
The Program Disclosure Brochure includes a discussion of
various risks associated with the Program, including the risks
of investing in ETFs, as well as risks related to the underlying
securities in which ETFs invest. In addition, the Program
Disclosure Brochure discusses market/systemic risks, asset
allocation/strategy/diversification risks, investment strategy
risks, trading/liquidity risks, and large investment risks.
Prospective Program participants should carefully review the
Program Disclosure Brochure to understand how it operates
Disciplinary Information
and its limitations.
Other Financial Industry Activities &
Not applicable.
Affiliations
For investment management clients, we utilize software to
develop customized client portfolios based on a long-term
asset allocation strategy that is consistent with the client’s
investment objective and risk tolerance. We typically use
academic research in analyzing investment products that we
recommend to clients. We analyze mutual fund and exchange
traded fund shares based on the fund’s total operating
investment objective and
expenses, portfolio turnover,
investment restrictions and
typically
limitations. We
recommend that clients invest in no-load institutional mutual
funds that have low operating expenses, low portfolio
turnover, below-average capital gains distributions and a
fundamental investment objective of investing primarily in a
particular asset class.
Code of Ethics, Participation, or Interest in
Not applicable.
Client Transactions & Personal Trading
Investing in securities, including mutual funds and ETFs,
Specific Types of Securities
involves risk of loss that clients should be prepared to bear.
Code
MWM buys or sells for itself or its personnel securities it also
recommends to clients, since we also believe in the Modern
Portfolio Theory and often purchase the same mutual funds
and ETFs as clients.
the amount of
type and amount of
the
Investing in mutual funds and ETFs carries inherent risk. The
major risks of investing in a mutual fund include the quality
and experience of the portfolio management team and its
ability to create fund value by investing in securities that have
individual company
positive growth,
diversification,
industry
the
diversification, and
type and amount of sector
diversification within specific industries. In addition, certain
mutual funds may be tax inefficient and therefore investors
may pay capital gains taxes on fund investments while not
having yet sold the fund.
”) for all
We have adopted a Code of Ethics (the “
supervised persons of the firm describing our high standard
of business conduct, and fiduciary duty to our clients. The
Code includes provisions relating to the confidentiality of
client information, a prohibition on insider trading, a
prohibition of rumor mongering, restrictions on
the
acceptance of significant gifts and the reporting of certain gifts
and business entertainment items, and personal securities
trading procedures, among other things. All supervised
persons at MWM must acknowledge the terms of the Code
annually, or when amended.
ETFs are investment companies whose shares are bought and
sold on a securities exchange. An ETF holds a portfolio of
securities designed to track a particular market segment or
index. A client, as a shareholder of an ETF, will bear its pro-
rata portion of the ETF’s advisory fee and other expenses, in
addition to their own expenses.
Investing in ETFs involves risk. Depending on the underlying
portfolio and its size, an ETF can have wide price (bid and ask)
We anticipate that, in appropriate circumstances, consistent
with clients’ investment objectives, we will cause accounts
over which we have discretionary management authority to
effect, and will recommend to investment advisory clients or
prospective clients, the purchase or sale of securities in which
3
to clients, while we believe the commissions and fees charged
by the broker-dealers referenced above are competitive,
transactions may not always be executed at the lowest
available commission rate.
We seek to select a custodian/broker who will hold your
assets and execute transactions on terms that are, overall,
most advantageous when compared to other available
providers and their services. We consider a wide range of
factors, including, among others:
• Combination of transaction execution services and asset
custody services (generally without a separate fee for
custody)
• Capability to execute, clear, and settle trades (buy and sell
we, our affiliates and/or clients, directly or indirectly, have a
Such securities are only broadly
position of interest.
diversified mutual funds or ETFs that contain in many cases
hundreds of individual companies within each mutual fund or
ETF. Our employees and associated persons are required to
follow the Code. Subject to satisfying this policy and
applicable laws, officers, directors, and employees of MWM
and its affiliates may trade for their own accounts in securities
which are recommended to and/or purchased for our clients.
The Code is designed to assure that the personal securities
transactions, activities and interests of our employees will not
interfere with (i) making decisions in the best interest of
advisory clients and (ii) implementing such decisions while,
at the same time, allowing employees to invest for their own
accounts.
securities or your account)
Clients or prospective clients may request a copy of the Code
by contacting Michael McCartney.
• Capability to facilitate transfers and payments to and
from accounts (wire transfers, check requests, bill
payment, etc.)
• Breadth of available investment products (stocks, bonds,
mutual funds, ETFs, etc.)
• Availability of investment research and tools that assist
us in making investment decisions
• Quality of services
• Competitiveness of
the price of
those services
(commission rates, margin interest rates, other fees, etc.)
and willingness to negotiate the prices
• Reputation, financial strength, and stability
• Prior service to us and our other clients
• Availability of other products and services that benefit us,
as discussed below
It is our policy that we will not affect any principal or agency
cross securities transactions for client accounts. Similarly, we
will not cross trades between client accounts. Principal
transactions are generally defined as transactions where an
adviser, acting as principal for its own account or the account
of an affiliated broker-dealer, buys from or sells any security
to any advisory client. A principal transaction may also be
deemed to have occurred if a security is crossed between an
affiliated hedge fund and another client account. An agency
cross transaction is defined as a transaction where a person
acts as an investment adviser in relation to a transaction in
which the investment adviser, or any person controlled by or
under common control with the investment adviser, acts as
broker for both the advisory client and for another person on
the other side of the transaction. Agency cross transactions
may arise where an adviser is dually registered as a broker-
dealer or has an affiliated broker-dealer.
We take our fiduciary duties seriously and disclose that we
will act as a fiduciary to all its clients. We avoid conflicts of
interests, and to the extent we ever have a conflict, we will
diligently seek to disclose such conflict to clients and
Brokerage Practices
prospects.
For our clients’ accounts that CS&Co. maintains, CS&Co.
generally does not charge you separately for custody services
but are compensated by charging you commissions or other
fees on trades that they execute or that settle into your CS&Co.
account. We have determined that having such Custodian
execute trades is consistent with our duty to seek “best
execution” of your trades. In seeking best execution, the
determinative factor is not the lowest possible commission
cost but whether the transaction represents the best
qualitative execution, taking into consideration the full range
of a broker-dealer’s services including execution capability,
commission rates, firm integrity, access to markets and
responsiveness. Accordingly, although we will
seek
competitive commission rates, clients may not necessarily
obtain the lowest possible commission rates for client account
Benefits from Custodian
transactions.
We will assist investment management clients who have
selected an asset allocation program in opening an account
with an independent custodian, or broker-dealer or directly
with a mutual fund company. Clients typically grant us with
discretionary authority over the client’s account to determine
the securities to be bought and sold, to place trades, to
negotiate transactions costs on their behalf, where possible,
and periodically to rebalance the client’s account back to the
recommended allocation.
investment advisory
firms
Schwab Advisor Services™ is Schwab’s business serving
Custodian
independent
like us (the
“
”). The Custodian provides us and our clients with
access to its institutional brokerage— trading, custody,
reporting, and related services—many of which are not
typically available to retail customers. The Custodian also
makes available various support services. Some of those
For investment management accounts, we normally request
that clients establish a brokerage account with CS&Co. to
serve as custodian of client’s assets. A client’s independent
broker-dealer will charge each client a commission or fee to
execute transactions in the customer’s account and provide
brokerage account statements to the client. The broker-
dealer, not MWM, determines the commission rate and fees
charged to clients and provides brokerage account requests
4
services help us manage or administer our clients’ accounts,
while others help us manage and grow our business. The
Custodian’s support services generally are available on an
unsolicited basis (we do not have to request them) and at no
charge to us. Following is a more detailed description of the
Services That Benefit You.
Custodian’ support services:
to enroll in the Program, the client decides whether to do so
and opens its account with CS&Co. by entering into a
brokerage account agreement directly with CS&Co. We do not
open an account for the client. If the client does not wish to
place his or her assets with CS&Co., then we cannot manage
the client’s account through the Program. CS&Co. may
aggregate purchase and sale orders for ETFs across accounts
enrolled in the Program, including both accounts for our
clients and accounts for clients of other independent
Recommendations of Professionals
investment advisory firms using the Platform.
The Custodian’s institutional
brokerage services include access to a broad range of
investment products, execution of securities transactions, and
custody of client assets. The investment products available
through the Custodian includes some to which we might not
otherwise have access or that would require a significantly
higher minimum initial investment from our clients. The
Custodian’s services described in this paragraph generally
Services That May Not Benefit You.
benefit you and your account.
The Custodian also makes
available to us other products and services that benefit us but
may not directly benefit you or your account. These products
and services assist us in managing and administering our
clients’ accounts. The Custodian makes available software and
other technology that:
• Provide access to client account data (such as duplicate
trade confirmations and account statements)
We emphasize a “team approach” when providing investment
advisory services to our clients. If requested by a client, or if
we believe legal or accounting services are required and in the
best interests of a client’s financial plan, we will recommend
an independent attorney or accountant. We do not pay for
client
referrals or enter arrangements with other
professionals for client referrals. However, there is a potential
for a conflict of interest in making these recommendations
because we may receive unsolicited referrals
from
professionals that we have recommended to clients. We will
refer other professionals to our clients only when we believe
the services provided by the professional are likely to suit the
Review of Accounts
client's needs.
• Facilitate trade execution and allocate aggregated trade
orders for multiple client accounts
• Provide pricing and other market data
• Facilitate payment of our fees from our clients’ accounts
• Assist with back-office functions, recordkeeping, and
Services That Generally Benefit Only Us.
client reporting
The Custodian also
offer other services intended to help us manage and further
develop our business enterprise, which does not benefit any
client. These services include:
We typically offer to meet with each investment management
client not less frequently than annually to review the
performance of the client’s portfolio and financial plans, if
such planning services are contracted by the client. In
addition, we review accounts at least quarterly. Meetings with
financial planning clients are scheduled as the need arises.
Account reviews will be conducted at a client’s request or may
be requested by us if there has been a broad-based change in
the financial markets, such as a precipitous rise or decline in
the stock market.
• Educational conferences and events
that
summarize
• Consulting on technology, compliance, legal, and business
needs
Investment management clients will receive reports at least
semi-annually
the client’s portfolio
performance results. Financial planning clients will receive a
comprehensive report outlining their financial plan as agreed
Client Referrals & Other Compensation
upon between MWM and the client.
• Publications and conferences on practice management
Our Interest in Custodian Services
and business succession
The availability of these services from Custodian benefits us
because we do not have to produce or purchase them. Further,
other Custodians in the competitive marketplace such as
Fidelity, Pershing, and Interactive Brokers, to name a few,
offer similar services. We believe that our selection of Schwab
as Custodian and executing brokers is in the best interests of
our clients. Our selection is primarily supported by the scope,
quality, and price of their services and the fact that both are
industry leaders.
in
We receive an economic benefit from Schwab in the form of
the support, products and services they make available to us
and other independent investment advisors whose clients
maintain their accounts at Schwab , even though we cannot
necessarily turn off such support that resides on their
platforms, such as research and rebalancing tools. These
products and services and how they benefit us are described
above. The availability to us of these products and services is
not based on us giving particular investment advice, such as
buying securities for our clients. Except for the services
expressly described in this Brochure, which similar services
are offered by other competitive custodians
the
marketplace and which are also part of their overall platforms
that cannot be modified by us, we do not receive an economic
In addition to our portfolio management and other services,
Client accounts enrolled in the Program are maintained at,
and receive the brokerage services of, CS&Co., a broker-dealer
registered with the SEC and a member of FINRA and SIPC.
While clients are required to use CS&Co. as custodian/broker
5
benefit from any third parties for providing investment advice
Custody
to clients.
We are deemed to have constructive custody of your assets if,
for example, you authorize us to instruct Schwab (or any other
custodian) to deduct our advisory fees directly from your
custodial account. Schwab maintains physical custody of your
assets. You will receive account statements directly from
Schwab at least quarterly. They will be sent to the email or
postal mailing address you provide Schwab unless you elect
to receive electronic statements. You should carefully review
those statements promptly when you receive them. We also
urge you to compare Schwab’s ’s account statements to the
Investment Discretion
periodic statements you will receive from us.
Clients typically engage us on a discretionary basis when we
perform investment management services, which means
clients grant us the authority to trade their assets and
securities without consulting the client. When selecting
securities and determining amounts, we observe the
investment policies, limitations, and restrictions of the client.
For registered investment companies, our authority to trade
securities may also be limited by certain federal securities and
tax laws that require diversification of investments and favor
the holding of investments once made.
Investment guidelines and restrictions must be provided to us
Voting Client Securities
in writing.
As a matter of firm policy and practice, we do not have any
authority to and do not vote proxies on behalf of advisory
clients. Clients retain the responsibility for receiving and
voting proxies for all securities maintained in client portfolios.
We may provide advice to clients regarding the clients’ voting
of proxies.
in accordance with
In the Program, as described in the Program Disclosure
Brochure, clients enrolled in the Program designate SWIA to
vote proxies for the ETFs held in their accounts. We have
directed SWIA to process proxy votes and corporate actions
through and
the policies and
recommendations of a third-party proxy voting service
provider retained by SWIA for this purpose. Additional
information about this arrangement is available in the
Program Disclosure Brochure. Clients who do not wish to
designate SWIA to vote proxies may retain the ability to vote
proxies themselves by signing a special CS&Co form available
Financial Information
from us.
Not applicable.
6