Overview
Assets Under Management: $119 million
Headquarters: MEDIA, PA
High-Net-Worth Clients: 67
Average Client Assets: $3 million
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Fee Structure
Primary Fee Schedule (MEMBERS WEALTH, LLC 2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.00% |
| $1,000,001 | $3,000,000 | 0.90% |
| $3,000,001 | $5,000,000 | 0.80% |
| $5,000,001 | $10,000,000 | 0.70% |
| $10,000,001 | and above | 0.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $44,000 | 0.88% |
| $10 million | $79,000 | 0.79% |
| $50 million | $279,000 | 0.56% |
| $100 million | $529,000 | 0.53% |
Clients
Number of High-Net-Worth Clients: 67
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 89.63
Average High-Net-Worth Client Assets: $3 million
Total Client Accounts: 304
Discretionary Accounts: 304
Regulatory Filings
CRD Number: 323778
Last Filing Date: 2024-09-20 00:00:00
Website: https://memberswealthllc.com
Form ADV Documents
Primary Brochure: MEMBERS WEALTH, LLC 2A (2025-04-29)
View Document Text
Members’ Wealth LLC
Form ADV Part 2A – Disclosure Brochure
Effective: April 29, 2025
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of Members’ Wealth LLC (“Members’ Wealth” or the “Advisor”). If you have any questions about the
content of this Disclosure Brochure, please contact the Advisor at (267) 367-5453.
Members’ Wealth is a registered investment advisor with the U.S. Securities and Exchange Commission. The
information in this Disclosure Brochure has not been approved or verified by the U.S. Securities and Exchange
Commission (“SEC”). Registration of an investment advisor does not imply any specific level of skill or training. This
Disclosure Brochure provides information about Members’ Wealth to assist you in determining whether to retain the
Advisor.
Additional information about Members’ Wealth and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 323778.
Members’ Wealth LLC
1 S Olive St., Suite 1C, Media, PA 19063
Phone: (267) 367-5453
https://www.memberswealthllc.com/
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory
Persons of Members’ Wealth.
Members’ Wealth believes that communication and transparency are the foundation of its relationship with clients
and will continually strive to provide you with complete and accurate information at all times. Members’ Wealth
encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may
have with the Advisor.
Material Changes
The following material changes have been made to this Disclosure Brochure since the annual amendment filing on
January 25, 2024:
• The Advisor has updated their primary office address.
• The Advisor has update Item 4 to allow for non-discretionary management of Client assets. Please see
these Items for additional information.
• The Advisor has engaged in a relationship with Charles Schwab & Co., Inc. Please see Items 12 and 14 for
additional information.
• The Advisor has added language that speaks to their institutional relationship with Fidelity. Please see Item
14 for additional information.
• The Advisor had updated Item 10 to disclose an estate planning affiliation. Please see this Item for
additional information.
• The Advisor has redrafted this Disclosure Brochure. Changes are reflected throughout this Brochure,
however, no material changes to the operations of the firm have been made besides those listed in Item 2
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure
Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 323778. You
may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (267) 367-5453.
Members’ Wealth LLC
1 S Olive St., Suite 1C, Media, PA 19063
Phone: (267) 367-5453
https://www.memberswealthllc.com/
Page 2
Item 3 – Table of Contents
Item 1 – Cover Page ................................................................................................................................................. 1
Item 2 – Material Changes....................................................................................................................................... 2
Item 3 – Table of Contents ...................................................................................................................................... 3
Item 4 – Advisory Services ..................................................................................................................................... 4
A. Firm Information .............................................................................................................................................................. 4
B. Advisory Services Offered ............................................................................................................................................... 4
C. Client Account Management ........................................................................................................................................... 5
D. Wrap Fee Programs ........................................................................................................................................................ 6
E. Assets Under Management ............................................................................................................................................. 6
Item 5 – Fees and Compensation ........................................................................................................................... 6
A. Fees for Advisory Services.............................................................................................................................................. 6
B. Fee Billing........................................................................................................................................................................ 7
C. Other Fees and Expenses .............................................................................................................................................. 7
D. Advance Payment of Fees and Termination ................................................................................................................... 7
E. Compensation for Sales of Securities ............................................................................................................................. 8
Item 6 – Performance-Based Fees and Side-By-Side Management ................................................................... 8
Item 7 – Types of Clients......................................................................................................................................... 8
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 8
A. Methods of Analysis ........................................................................................................................................................ 8
B. Risk of Loss ..................................................................................................................................................................... 9
Item 9 – Disciplinary Information ......................................................................................................................... 10
Item 10 – Other Financial Industry Activities and Affiliations .......................................................................... 10
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 10
A. Code of Ethics ............................................................................................................................................................... 10
B. Personal Trading with Material Interest ......................................................................................................................... 10
C. Personal Trading in Same Securities as Clients ........................................................................................................... 11
D. Personal Trading at Same Time as Client .................................................................................................................... 11
Item 12 – Brokerage Practices ............................................................................................................................. 11
A. Recommendation of Custodian[s] ................................................................................................................................. 11
B. Aggregating and Allocating Trades ............................................................................................................................... 12
Item 13 – Review of Accounts .............................................................................................................................. 12
A. Frequency of Reviews ................................................................................................................................................... 12
B. Causes for Reviews ...................................................................................................................................................... 12
C. Review Reports ............................................................................................................................................................. 12
Item 14 – Client Referrals and Other Compensation ......................................................................................... 12
A. Compensation Received by Members’ Wealth ............................................................................................................. 12
B. Compensation for Client Referrals ................................................................................................................................ 13
Item 15 – Custody .................................................................................................................................................. 13
Item 16 – Investment Discretion ........................................................................................................................... 14
Item 17 – Voting Client Securities ........................................................................................................................ 14
Item 18 – Financial Information ............................................................................................................................ 14
Privacy Policy......................................................................................................................................................... 15
Members’ Wealth LLC
1 S Olive St., Suite 1C, Media, PA 19063
Phone: (267) 367-5453
https://www.memberswealthllc.com/
Page 3
Item 4 – Advisory Services
A. Firm Information
Members’ Wealth LLC (“Members’ Wealth” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission. The Advisor is organized as a Limited Liability Company (LLC) under the
laws of the Commonwealth of Pennsylvania. Members’ Wealth was founded in August 2022 and is owned and
operated by Dane Czaplicki (Founder, Chief Executive Officer, and Chief Investment Officer) and Tim Macarak
(President, and Head of Wealth Management). This Disclosure Brochure provides information regarding the
qualifications, business practices, and the advisory services provided by Members’ Wealth.
B. Advisory Services Offered
Members’ Wealth offers investment advisory services to individuals, high net worth individuals, trusts, estates, and
businesses. (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. Members’ Wealth's fiduciary commitment is further described in the Advisor’s Code of Ethics.
For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading.
Investment Management Services
Members’ Wealth provides customized investment advisory solutions for its Clients. This is achieved through
continuous personal Client contact and interaction while providing discretionary or non-discretionary investment
management and related advisory services. Members’ Wealth works closely with each Client to identify their
investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio
strategy. Members’ Wealth will then construct an investment portfolio, consisting of low-cost, diversified mutual
funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize
individual stocks, bonds or options contracts to meet the needs of its Clients. The Advisor may retain other types of
investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or
other reasons as identified between the Advisor and the Client.
Members’ Wealth’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-
allocate positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. Members’ Wealth will construct, implement and monitor the portfolio to ensure it meets the goals,
objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place
reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by
the Advisor.
Members’ Wealth evaluates and selects investments for inclusion in Client portfolios only after applying its internal
due diligence process. Members’ Wealth may recommend, on occasion, redistributing investment allocations to
diversify the portfolio. Members’ Wealth may recommend specific positions to increase sector or asset class
weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement.
Members’ Wealth may recommend selling positions for reasons that include, but are not limited to, harvesting
capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or
overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet
Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
Under certain circumstances, Members’ Wealth may accept or maintain custody of Client’s funds or securities.
Please see Item 15 – Custody for more information.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
Members’ Wealth LLC
1 S Olive St., Suite 1C, Media, PA 19063
Phone: (267) 367-5453
https://www.memberswealthllc.com/
Page 4
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the
assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account
to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or
increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a
retirement account to an account managed by the Advisor.
Financial Planning Services
Members’ Wealth will typically provide a variety of financial planning and consulting services to Clients, pursuant to
a written financial planning agreement. Services are offered in several areas of a Client’s financial situation,
depending on their goals and objectives. Generally, such financial planning services involve preparing a formal
financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This
planning or consulting may encompass one or more areas of need, including but not limited to, investment
planning, retirement planning, personal savings, education savings, insurance needs and other areas of a Client’s
financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
Members’ Wealth may also refer Clients to an accountant, attorney or other specialists, as appropriate for their
unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the
Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the
Advisor may not provide a written summary. In certain circumstances, the Advisor may refer Clients to an affiliated
attorney for estate services. Please see Item 10 for additional information.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for
investment management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to
act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
Employer Benefits Services
Members’ Wealth offer consulting services to employers as a benefit to their employees. These services are based
upon the needs of the employees and the services requested by the employer. In general, these services will
include advice regarding fund selection, investment options, and financial plans. These services will generally be
non-discretionary and advisory in nature. Should any employee of a company to whom we offer these services
decide to become a client, that employee would need to complete an investment management agreement with
Members’ Wealth.
C. Client Account Management
Prior to engaging Members’ Wealth to provide investment advisory services, each Client is required to enter into
one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the
Advisor and the Client. These services may include:
• Establishing an Investment Strategy – Members’ Wealth, in connection with the Client, will develop a
strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Members’ Wealth will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – Members’ Wealth will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
Members’ Wealth LLC
1 S Olive St., Suite 1C, Media, PA 19063
Phone: (267) 367-5453
https://www.memberswealthllc.com/
Page 5
•
Investment Management and Supervision – Members’ Wealth will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Members’ Wealth does not manage or place Client assets into a wrap fee program. Investment management
services are provided directly by Members’ Wealth.
E. Assets Under Management
As of December 31, 2024, Members’ Wealth manages $217,289,348 in Client assets, $211,783,203 of which are
managed on a discretionary basis and $5,506,145 on a non-discretionary basis. Clients may request more current
information at any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more
written agreements with the Advisor.
A. Fees for Advisory Services
Investment Management Services
Investment advisory fees are paid quarterly, in adviance of each calendar quarter, pursuant to the terms of the
investment advisory agreement. Investment advisory fees are based on the market value of assets under
management at the end of the prior calendar quarter. Investment advisory fees are based on the following schedule:
Annual Rate (%)
Assets Under Management ($)
Up to $1,000,000
$1,000,001 to $3,000,000
$3,000,001 to $5,000,000
$5,000,001 to $10,000,000
$10,000,000 and over
1.00%
0.90%
0.80%
0.70%
0.50%
The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the
end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into
consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by
Members’ Wealth will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the
Custodian’s valuation to ensure accurate billing.
The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other
related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor
shall not receive any portion of these commissions, fees, and costs.
Financial Planning Services
Members’ Wealth offers financial planning services for a fixed engagement fee up to $50,000 per engagement. Fees
may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with
the Advisor. An estimate for total costs will be determined prior to engaging for these services.
Employer Benefits Services
Members’ Wealth offers employer benefits services on a fixed fee basis. Our advisory fees will be negotiated in
advance with the employer on a case-by-case basis and are dependent on a variety of factors including the number of
employees, the nature of the services, and the complexity of the services. Fees will be charged at a fixed level
dependent upon the size of the engagement and the number of employees ranging from $1,000-$10,000 per
employee per year.
Members’ Wealth LLC
1 S Olive St., Suite 1C, Media, PA 19063
Phone: (267) 367-5453
https://www.memberswealthllc.com/
Page 6
B. Fee Billing
Investment Management Services
Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the
Custodian. The Advisor shall send a CSV file to the Custodian indicating the amount of the fees to be deducted from
the Client’s account[s] at the beginning of the respective quarter. The amount due is calculated by applying the
quarterly rate (annual rate divided by 365 * days in the quarter) to the total assets under management with Members’
Wealth at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian
reflecting deduction of the investment advisory fee. Clients are urged to also review and compare the statement
provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a
verification of fees. Clients provide written authorization permitting advisory fees to be deducted by Members’ Wealth
to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and
separate account forms provided by the Custodian.
Financial Planning Services
Financial planning fees are invoiced by the Advisor and are due upon completion of the agreed upon deliverable[s].
Employer Benefits Services
Employer benefit fees are billed in advance or in arrears and paid monthly or quarterly pursuant to the agreement with
the firm.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than Members’ Wealth, in connection with
investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities
execution fees charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge
securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the
terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for
mutual funds and other types of investments. The fees charged by Members’ Wealth are separate and distinct from
these custody and execution fees.
In addition, all fees paid to Members’ Wealth for investment advisory services are separate and distinct from the
expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are
described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for
the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a
possible distribution fee. A Client may be able to invest in these products directly, without the services of Members’
Wealth, but would not receive the services provided by Members’ Wealth which are designed, among other things,
to assist the Client in determining which products or services are most appropriate for each Client’s financial
situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees
charged by Members’ Wealth to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage
Practices for additional information.
D. Advance Payment of Fees and Termination
Investment Management Services
Members’ Wealth may be compensated for its investment management services in advance of the period in which
services are rendered. Either party may terminate the investment advisory agreement, at any time, by providing
advance written notice to the other party. The Client may also terminate the investment advisory agreement within five
(5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will
incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and
payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid investment advisory fees from
the effective date of termination to the end of the quarter. The Client’s investment advisory agreement with the Advisor
is non-transferable without the Client’s prior consent.
Financial Planning Services
Members Wealth is compensated for its financial planning services upon completion of the engagement
deliverable[s]. Either party may terminate the financial planning agreement, at any time, by providing advance written
Members’ Wealth LLC
1 S Olive St., Suite 1C, Media, PA 19063
Phone: (267) 367-5453
https://www.memberswealthllc.com/
Page 7
notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days
of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for
bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client.
Upon termination, the Advisor will refund any unearned, prepaid planning fees from the effective date of termination to
the end of the quarter. The Client’s financial planning agreement with the Advisor is non-transferable without the
Client’s prior consent.
Employment Benefits Services
Members’ Wealth may require an advance deposit as described above. You can terminate services upon written
notice. Either party may terminate the financial planning agreement, at any time, by providing advance written notice
to the other party. The Client may also terminate the financial planning agreement within five (5) business days of
signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona
fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. If the
Client was billed in advance, upon termination the Advisor will refund any unearned, prepaid planning fees from the
effective date of termination to the end of the billing period.
E. Compensation for Sales of Securities
Members’ Wealth does not buy or sell securities to earn commissions and does not receive any compensation for
securities transactions in any Client account, other than the investment advisory fees noted above.
Item 6 – Performance-Based Fees and Side-By-Side Management
Members’ Wealth does not charge performance-based fees for its investment advisory services. The fees charged
by Members’ Wealth are as described in Item 5 above and are not based upon the capital appreciation of the funds
or securities held by any Client.
Members’ Wealth does not manage any proprietary investment funds or limited partnerships (for example, a mutual
fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients.
Item 7 – Types of Clients
Members’ Wealth offers investment advisory services to individuals, high net worth individuals, trusts, estates, and
businesses. Members’ Wealth generally requires a minimum relationship size of $1,000,000 to effectively
implement its investment process. This minimum can be waived at the discretion of the Advisor.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
Members’ Wealth primarily employs a fundamental analysis method in developing investment strategies for its
Clients. Research and analysis from Members’ Wealth are derived from numerous sources, including financial
media companies, third-party research materials, Internet sources, and review of company activities, including
annual reports, prospectuses, press releases and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria
consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being
analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with
a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment,
it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in
the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors
these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the
Advisor’s review process are included below in Item 13 – Review of Accounts.
As noted above, Members’ Wealth generally employs a long-term investment strategy for its Clients, as consistent
with their financial goals. Members’ Wealth will typically hold all or a portion of a security for more than a year, but
may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At
Members’ Wealth LLC
1 S Olive St., Suite 1C, Media, PA 19063
Phone: (267) 367-5453
https://www.memberswealthllc.com/
Page 8
times, Members’ Wealth may also buy and sell positions that are more short-term in nature, depending on the goals
of the Client and/or the fundamentals of the security, sector or asset class.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. Members’ Wealth will assist Clients in determining an
appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no
guarantee that a Client will meet their investment goals. Please see Item 8.B. for risks associated with the Advisor’s
investment strategies as well as general risks of investing.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the
investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may
lose value and may have negative investment performance. The Advisor monitors these economic indicators to
determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are
included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client
or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or
other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts.
The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction
process. Following are some of the risks associated with the Advisor’s investment strategies:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs
will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk
based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-
ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may
dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased
or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later.
Bond Risks
Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall
if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon
rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than
was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that
exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk
associated with purchasing a debt instrument which includes the possibility of the company defaulting on its
repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the
company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity
Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the
mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual
Members’ Wealth LLC
1 S Olive St., Suite 1C, Media, PA 19063
Phone: (267) 367-5453
https://www.memberswealthllc.com/
Page 9
fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same
price as a mutual fund purchased later that same day.
Options Contracts
Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts
are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock.
This leverage can compound gains or losses.
Alternative Investments (Limited Partnerships)
The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An
investor could lose all or a portion of their investment. Such investments often have concentrated positions and
investments that may carry higher risks. Client should only have a portion of their assets in these investments.
Past performance is not a guarantee of future returns. Investing in securities and other investments involve
a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss
these risks with the Advisor.
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving Members’ Wealth or its owner [OR]
management persons. Members’ Wealth values the trust Clients place in the Advisor. The Advisor encourages
Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The
backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 323778.
Item 10 – Other Financial Industry Activities and Affiliations
Estate Planning Services
Marie Feindt is a licensed estate attorney in her individual capacity. The Advisor may recommend that Clients
engage Ms. Feindt for the creation of legal documents, which are provided as a separate service and fee. These
services are separate and distinct from investment advisory services provided by the Advisor. Clients are under no
obligation to utilize the services provided by Ms. Feindt.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
Members’ Wealth has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment
to each Client. This Code applies to all persons associated with Members’ Wealth (“Supervised Persons”). The
Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to
each Client. Members’ Wealth and its Supervised Persons owe a duty of loyalty, fairness and good faith towards
each Client. It is the obligation of Members’ Wealth’s Supervised Persons to adhere not only to the specific
provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics
that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at
(267) 367-5453.
B. Personal Trading with Material Interest
Members’ Wealth allows Supervised Persons to purchase or sell the same securities that may be recommended to
and purchased on behalf of Clients. Members’ Wealth does not act as principal in any transactions. In addition, the
Advisor does not act as the general partner of a fund, or advise an investment company. Members’ Wealth does
not have a material interest in any securities traded in Client accounts.
Members’ Wealth LLC
1 S Olive St., Suite 1C, Media, PA 19063
Phone: (267) 367-5453
https://www.memberswealthllc.com/
Page 10
C. Personal Trading in Same Securities as Clients
Members’ Wealth allows Supervised Persons to purchase or sell the same securities that may be recommended to
and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients
presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and
procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public
information controls); gifts and entertainment; outside business activities and personal securities reporting. When
trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The
fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more
advantageous terms than Client trades, or by trading based on material non-public information. This risk is
mitigated by Members’ Wealth requiring reporting of personal securities trades by its Supervised Persons for review
by the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures
to detect the misuse of material, non-public information.
D. Personal Trading at Same Time as Client
While Members’ Wealth allows Supervised Persons to purchase or sell the same securities that may be
recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or
traded afterwards. At no time will Members’ Wealth, or any Supervised Person of Members’ Wealth, transact
in any security to the detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
Members’ Wealth does not have discretionary authority to select the broker-dealer/custodian for custody and
execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client
assets and authorize Members’ Wealth to direct trades to the Custodian as agreed upon in the investment advisory
agreement. Further, Members’ Wealth does not have the discretionary authority to negotiate commissions on
behalf of Clients on a trade-by-trade basis.
Where Members’ Wealth does not exercise discretion over the selection of the Custodian, it may recommend the
Custodian to Clients for custody and execution services. Clients are not obligated to use the Custodian
recommended by the Advisor and will not incur any extra fee or cost associated with using a custodian not
recommended by Members’ Wealth. However, the Advisor may be limited in the services it can provide if the
recommended Custodian is not engaged. Members’ Wealth may recommend the Custodian based on criteria such
as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client,
and its reputation and/or the location of the Custodian’s offices.
The Advisor will generally recommend that Clients establish their account[s] at Charles Schwab & Co., Inc.
(“Schwab”), a FINRA-registered broker-dealer and member SIPC, or with Fidelity Clearing & Custody Solutions and
related entities of Fidelity Investments, Inc. (collectively “Fidelity”), a FINRA-registered broker-dealer and member
SIPC. Schwab or Fidelity will serve as the Client’s “qualified custodian”. The Advisor maintains an institutional
relationship with Schwab or Fidelity, whereby the Advisor receives economic benefits. Please see Item 14 – Client
Referrals and Other Compensation below.
Following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor
enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and
other services. Members’ Wealth does not participate in soft dollar programs sponsored or offered by any
broker-dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian.
Please see Item 14 below.
2. Brokerage Referrals - Members’ Wealth does not receive any compensation from any third party in connection
with the recommendation for establishing an account.
Members’ Wealth LLC
1 S Olive St., Suite 1C, Media, PA 19063
Phone: (267) 367-5453
https://www.memberswealthllc.com/
Page 11
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Members’ Wealth will
place trades within the established account[s] at the Custodian designated by the Client. Further, all Client
accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions
(i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts
(i.e., purchase of a security into one Client account from another Client’s account[s]). Members’ Wealth will not be
obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest
available transaction costs. These costs are determined by the Custodian.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution,
4) confidentiality and 5) skill required of the Custodian. Members’ Wealth will execute its transactions through the
Custodian as authorized by the Client. Members’ Wealth may aggregate orders in a block trade or trades when
securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading
day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold
by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or
other written statement. This must be done in a way that does not consistently advantage or disadvantage any
particular Clients’ accounts.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis. Formal reviews are generally
conducted at least annually or more frequently depending on the needs of the Client.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least
annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result
of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or
withdrawals in the Client’s account[s]. The Client is encouraged to notify Members’ Wealth if changes occur in the
Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may
be triggered by material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage
statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the
Custodian’s website so that the Client may view these reports and their account activity. Client brokerage
statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also
provide Clients with periodic reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by Members’ Wealth
Members’ Wealth is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment
product. Members’ Wealth does not receive commissions or other compensation from product sponsors, broker-
dealers or any un-related third party. Members’ Wealth may refer Clients to various affiliated or unaffiliated, non-
advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to
meet the goals of its Clients. Likewise, Members’ Wealth may receive non-compensated referrals of new Clients from
various third-parties.
Participation in Institutional Advisor Platform (Fidelity)
Members Wealth has established an institutional relationship with Fidelity to assist the Advisor in managing Client
account[s]. Access to the Fidelity platform is provided at no charge to the Advisor. The Advisor receives access to
software and related support without cost because the Advisor renders investment management services to Clients
Members’ Wealth LLC
1 S Olive St., Suite 1C, Media, PA 19063
Phone: (267) 367-5453
https://www.memberswealthllc.com/
Page 12
that maintain assets at Fidelity. The software and related systems support may benefit the Advisor, but not its
Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its
Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a
potential conflict of interest since these benefits may influence the Advisor's recommendation of this Custodian over
one that does not furnish similar software, systems support, or services.
Participation in Institutional Advisor Platform (Schwab)
Members Wealth has established an institutional relationship with Schwab through its “Schwab Advisor Services”
unit, a division of Schwab dedicated to serving independent advisory firms like Members Wealth. As a registered
investment advisor participating on the Schwab Advisor Services platform, Members Wealth receives access to
software and related support without cost because the Advisor renders investment management services to Clients
that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but
not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at
all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic
benefits from a custodian creates a potential conflict of interest since these benefits may influence the Advisor's
recommendation of this custodian over one that does not furnish similar software, systems support, or services.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of Client’s funds and securities. Through
Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able
to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and
other investments without having to adhere to investment minimums that might be required if the Client were to
directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology,
research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts,
the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with
Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may
not directly benefit all Clients.
Services that May Only Benefit the Advisor – Schwab also offers other services to Members Wealth that may not
benefit the Client, including: educational conferences and events, financial start-up support, consulting services and
discounts for various service providers. Access to these services creates a financial incentive for the Advisor to
recommend Schwab, which results in a potential conflict of interest. Members Wealth believes, however, that the
selection of Schwab as Custodian is in the best interests of its Clients.
B. Compensation for Client Referrals
Certain Clients may be referred to the Advisor by either an affiliated or unaffiliated party (herein "Promoter") and
receive, directly or indirectly, compensation for the Client referral. In such instances, the Advisor will compensate
the Promoter a fee in accordance with Rule 206(4)-1 of the Advisers Act and any corresponding state securities
requirements. Any such compensation shall be paid solely from the investment advisory fees earned by the
Advisor, and shall not result in any additional charge to the Client.
Item 15 – Custody
Members’ Wealth does not accept or maintain custody of any Client accounts, except for the authorized deduction
of the Advisor’s fees. All Clients must place their assets with a “qualified custodian”. Clients are required to engage
the Custodian to retain their funds and securities and direct Members’ Wealth to utilize that Custodian for the
Client’s security transactions. Clients should review statements provided by the Custodian and compare to any
reports provided by Members’ Wealth to ensure accuracy, as the Custodian does not perform this review. For more
information about custodians and brokerage practices, see Item 12 – Brokerage Practices.
If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have
custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have
Members’ Wealth LLC
1 S Olive St., Suite 1C, Media, PA 19063
Phone: (267) 367-5453
https://www.memberswealthllc.com/
Page 13
adopted safeguards to ensure that the money movements are completed in accordance with the Client’s
instructions.
Item 16 – Investment Discretion
Members’ Wealth generally has discretion over the selection and amount of securities to be bought or sold in Client
accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be
subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to
by Members’ Wealth. Discretionary authority will only be authorized upon full disclosure to the Client. The granting
of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all
applicable limitations to such authority. All discretionary trades made by Members’ Wealth will be in accordance
with each Client's investment objectives and goals.
Item 17 – Voting Client Securities
Members’ Wealth does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements
directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client
retains the sole responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither Members’ Wealth, nor its management, have any adverse financial situations that would reasonably impair
the ability of Members’ Wealth to meet all obligations to its Clients. Neither Members’ Wealth, nor any of its
Advisory Persons, have been subject to a bankruptcy or financial compromise. Members’ Wealth is not required to
deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200
or more for services to be performed six months or more in the future.
Members’ Wealth LLC
1 S Olive St., Suite 1C, Media, PA 19063
Phone: (267) 367-5453
https://www.memberswealthllc.com/
Page 14
Privacy Policy
Effective: April 29, 2025
Our Commitment to You
Members’ Wealth LLC (“Members’ Wealth” or the “Advisor”) is committed to safeguarding the use of personal
information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as
described here in our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your private
information, and we do everything that we can to maintain that trust. Members’ Wealth (also referred to as "we",
"our" and "us”) protects the security and confidentiality of the personal information we have and implements
controls to ensure that such information is used for proper business purposes in connection with the management
or servicing of our relationship with you.
Members’ Wealth does not sell your non-public personal information to anyone. Nor do we provide such information
to others except for discrete and reasonable business purposes in connection with the servicing and management
of our relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set forth
in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing
your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose
how we collect, share, and protect your personal information.
What information do we collect from you?
Driver’s license number
Date of birth
Social security or taxpayer identification number Assets and liabilities
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Other advisory agreements and legal documents
Transactional information with us or others
Account applications and forms
Investment questionnaires and suitability
documents
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural and
electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a
secure office environment. Our technology vendors provide security and access control over personal information
and have policies over the transmission of data. Our associates are trained on their responsibilities to protect
Client’s personal information.
We require third parties that assist in providing our services to you to protect the personal information they receive
from us.
Members’ Wealth LLC
1 S Olive St., Suite 1C, Media, PA 19063
Phone: (267) 367-5453
https://www.memberswealthllc.com/
Page 15
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information.
Basis For Sharing
Do we share?
Can you limit?
Yes
No
Servicing our Clients
We may share non-public personal information with non-affiliated third
parties (such as administrators, brokers, custodians, regulators, credit
agencies, other financial institutions) as necessary for us to provide
agreed upon services to you, consistent with applicable law, including but
not limited to: processing transactions; general account maintenance;
responding to regulators or legal investigations; and credit reporting.
No
Not Shared
Yes
Yes
No
Not Shared
Marketing Purposes
Members’ Wealth does not disclose, and does not intend to disclose,
personal information with non-affiliated third parties to offer you services.
Certain laws may give us the right to share your personal information with
financial institutions where you are a customer and where Members’
Wealth or the client has a formal agreement with the financial institution.
We will only share information for purposes of servicing your
accounts, not for marketing purposes.
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent[s] or
representative[s].
Information About Former Clients
Members’ Wealth does not disclose and does not intend to disclose, non-
public personal information to non-affiliated third parties with respect to
persons who are no longer our Clients.
State-specific Regulations
California
In response to a California law, to be conservative, we assume accounts with California addresses do not want us to
disclose personal information about you to non-affiliated third parties, except as permitted by California law. We also limit
the sharing of personal information about you with our affiliates to ensure compliance with California privacy laws.
Massachusetts
In response to Massachusetts law, the Client must “opt-in” to share non-public personal information with non-affiliated third
parties before any personal information is disclosed. Client opt-in is obtained through the Client’s execution of
authorization forms provided by the third parties, by executing an Information Sharing Authorization Form, or by other
written consent by the Client, as appropriate and consistent with applicable laws and regulations.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the
previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal
information other than as described in this notice unless we first notify you and provide you with an opportunity to
prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting
us at (267) 367-5453.
Members’ Wealth LLC
1 S Olive St., Suite 1C, Media, PA 19063
Phone: (267) 367-5453
https://www.memberswealthllc.com/
Page 16