View Document Text
Item 1: Cover Page
Milestone Asset Management Group, LLC
302 West Main Street, Suite 206
Avon, CT 06001
Form ADV Part 2A – Firm Brochure
860.259.4800
www.milestoneamg.com
Dated January 15, 2026
This Brochure provides information about the qualifications and business practices of Milestone Asset
Management Group, LLC “Milestone”. If you have any questions about the contents of this Brochure, please
contact us at 860.259.4800. 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.
Milestone Asset Management Group, LLC is registered as an investment adviser with the United States Securities
and Exchange Commission. Registration of an investment adviser does not imply any level of skill or training.
Additional information about Milestone is available on the SEC’s website at www.adviserinfo.sec.gov which can
be found using the firm’s identification number 282896.
1
Since our last filing dated February 11, 2025, the following material changes have occurred:
Item 2: Material Changes
Item 14: We no longer have solicitor/promoter arrangements.
•
Please note, this item only discusses changes we consider material and not all changes made.
Item 3: Table of Contents
Contents
Item 1: Cover Page ............................................................................................................................................... 1
Item 2: Material Changes ..................................................................................................................................... 2
Item 3: Table of Contents .................................................................................................................................... 2
Item 4: Advisory Business .................................................................................................................................... 3
Item 5: Fees and Compensation .......................................................................................................................... 7
Item 6: Performance-Based Fees and Side-By-Side Management ...................................................................... 9
Item 7: Types of Clients ........................................................................................................................................ 9
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................................................ 9
Item 9: Disciplinary Information ........................................................................................................................ 11
Item 10: Other Financial Industry Activities and Affiliations ............................................................................. 12
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...................... 12
Item 12: Brokerage Practices ............................................................................................................................. 14
Item 13: Review of Accounts ............................................................................................................................. 17
Item 14: Client Referrals and Other Compensation .......................................................................................... 17
Item 15: Custody ................................................................................................................................................ 17
Item 16: Investment Discretion ......................................................................................................................... 18
Item 17: Voting Client Securities ....................................................................................................................... 18
Item 18: Financial Information .......................................................................................................................... 18
Form ADV Part 2B – Brochure Supplement ....................................................................................................... 20
2
Description of Advisory Firm
Item 4: Advisory Business
Milestone Asset Management Group, LLC is registered as an investment adviser with the United States
Securities and Exchange Commission. We were founded in February of 2016. Michael Mezheritskiy is the
principal owner of Milestone. As of December 31, 2025, Milestone manages $299,365,271 on a discretionary
basis and $9,600,000 on a non-discretionary basis.
How We Get to Know You
As a new client, we will have a pre-advisory consultation with you to discuss issues such as your current income
and expenses, career, personal goals, investment return expectations and prior investment experience. In
addition, we may have you complete a profile questionnaire to gain greater insight into your financial needs.
Identified areas of greatest distress;
With the complexity of today’s marketplace, it is critical for us to understand who you are and what you want
to accomplish financially. We must have a clear picture of your unique financial composition and risk tolerance
so that we can develop a successful portfolio management strategy. Our meetings with you to discuss your
finances will help to eliminate much of the guesswork in achieving the security and independence you desire
while simplifying your financial alternatives. In return, we will have:
• Defined and narrowed objectives and investment options;
•
• Developed a strategy for addressing future concerns;
• Cultivated peace of mind; and,
• Created a unique picture of your overall economic personality.
Once your financial parameters have been identified, we will prepare an assessment that outlines what asset
mix is most suitable for your unique investment expectations and risk tolerance. This assessment plan will
guide us in the management of your account(s); and, as a standard against which to measure future results
and to make modifications where necessary.
Types of Advisory Services
Investment Management Services
We are in the business of managing individually tailored investment portfolios. Our firm provides continuous
advice to a client regarding the investment of client funds based on the individual needs of the client. Through
personal discussions in which goals and objectives based on a client's particular circumstances are established,
we develop a client's personal investment policy or an investment plan with an asset allocation target and
create and manage a portfolio based on that policy and allocation target. During our data-gathering process,
we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. We may also
review and discuss a client’s prior investment history, as well as family composition and background.
Account supervision is guided by the stated objectives of the client (e.g., maximum capital appreciation,
growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable
3
restrictions on investing in certain securities, types of securities, or industry sectors. Fees pertaining to this
service are outlined in Item 5 of this brochure.
Investment Advisory Services
We also offer investment advisory services through the use of Betterment, LLC (“Betterment”) for portfolio
management services. We assist clients in selecting an appropriate allocation model, completing Betterment’s
investor profile questionnaire, interacting with Betterment and reviewing Betterment. Additionally, we will
meet with the client on a periodic basis to discuss changes in their personal or financial situation, suitability,
and any new or revised restrictions to be applied to the account. Fees pertaining to this service are outlined
in Item 5 of this brochure.
Financial Planning
Financial planning is a comprehensive evaluation of a client’s current and future financial state by using
currently known variables to predict future cash flows, asset values and withdrawal plans. The key defining
aspect of financial planning is that through the financial planning process, all questions, information and
analysis will be considered as they impact and are impacted by the entire financial and life situation of the
client. Clients purchasing this service will receive a written or an electronic report, providing the client with a
detailed financial plan designed to achieve his or her stated financial goals and objectives.
The client always has the right to decide whether or not to act upon our recommendations. If the client elects
to act on any of the recommendations, the client always has the right to affect the transactions through
anyone of their choosing.
In general, the financial plan will address any or all of the following areas of concern. The client and advisor
will work together to select the specific areas to cover. These areas may include, but are not limited to, the
following:
• Business Planning: We provide consulting services for clients who currently operate their own
business, are considering starting a business, or are planning for an exit from their current business.
Under this type of engagement, we work with you to assess your current situation, identify your
objectives, and develop a plan aimed at achieving your goals.
• Cash Flow and Debt Management: We will conduct a review of your income and expenses to
determine your current surplus or deficit along with advice on prioritizing how any surplus should be
used or how to reduce expenses if they exceed your income. Advice may also be provided on which
debts to pay off first based on factors such as the interest rate of the debt and any income tax
ramifications. We may also recommend what we believe to be an appropriate cash reserve that should
be considered for emergencies and other financial goals, along with a review of accounts (such as
money market funds) for such reserves, plus strategies to save desired amounts.
• College Savings: Includes projecting the amount that will be needed to achieve college or other post-
secondary education funding goals, along with advice on ways for you to save the desired amount.
Recommendations as to savings strategies are included, and, if needed, we will review your financial
4
picture as it relates to eligibility for financial aid or the best way to contribute to grandchildren (if
appropriate).
• Employee Benefits Optimization: We will provide review and analysis as to whether you, as an
employee, are taking the maximum advantage possible of your employee benefits. If you are a business
owner, we will consider and/or recommend the various benefit programs that can be structured to
meet both business and personal retirement goals.
• Estate Planning: This usually includes an analysis of your exposure to estate taxes and your current
estate plan, which may include whether you have a will, powers of attorney, trusts and other related
documents. Our advice also typically includes ways for you to minimize or avoid future estate taxes by
implementing appropriate estate planning strategies such as the use of applicable trusts.
We always recommend that you consult with a qualified attorney when you initiate, update, or
complete estate planning activities. We may provide you with contact information for attorneys who
specialize in estate planning when you wish to hire an attorney for such purposes. From time-to-time,
we will participate in meetings or phone calls between you and your attorney with your approval or
request.
• Financial Goals: We will help clients identify financial goals and develop a plan to reach them. We will
identify what you plan to accomplish, what resources you will need to make it happen, how much time
you will need to reach the goal, and how much you should budget for your goal.
•
Insurance: Review of existing policies to ensure proper coverage for life, health, disability, long-term
care, liability, home and automobile.
•
Investment Analysis: This may involve developing an asset allocation strategy to meet clients’ financial
goals and risk tolerance, providing information on investment vehicles and strategies, reviewing
employee stock options, as well as assisting you in establishing your own investment account at a
selected broker/dealer or custodian. The strategies and types of investments we may recommend are
further discussed in Item 8 of this brochure.
• Retirement Planning: Our retirement planning services typically include projections of your likelihood
of achieving your financial goals, typically focusing on financial independence as the primary objective.
For situations where projections show less than the desired results, we may make recommendations,
including those that may impact the original projections by adjusting certain variables (e.g., working
longer, saving more, spending less, taking more risk with investments).
If you are near retirement or already retired, advice may be given on appropriate distribution strategies
to minimize the likelihood of running out of money or having to adversely alter spending during your
retirement years.
• Risk Management: A risk management review includes an analysis of your exposure to major risks that
could have a significantly adverse effect on your financial picture, such as premature death, disability,
property and casualty losses, or the need for long-term care planning. Advice may be provided on ways
5
to minimize such risks and about weighing the costs of purchasing insurance versus the benefits of
doing so and, likewise, the potential cost of not purchasing insurance (“self-insuring”).
• Tax Planning Strategies: Advice may include ways to minimize current and future income taxes as a
part of your overall financial planning picture. For example, we may make recommendations on which
type of account(s) or specific investments should be owned based in part on their “tax efficiency,” with
consideration that there is always a possibility of future changes to federal, state or local tax laws and
rates that may affect your situation.
We recommend that you consult with a qualified tax professional before initiating any tax planning
strategy, and we may provide you with contact information for accountants or attorneys who
specialize in this area if you wish to hire someone for such purposes. We will participate in meetings
or phone calls between you and your tax professional with your approval.
Milestone 401(k) Solutions
ERISA Section 3(21) and 3(38) Plan Investment Advisory Services: Milestone can perform non-discretionary
investment advisory services at the Plan level as described below.
• Milestone will review and/or prepare the Plan’s Investment Policy Statement ("IPS"), including
assessing the following:
o the criteria for selecting money managers and the due diligence procedures that the Plan
followed in selecting its money managers and/or mutual funds;
o the basis for asset mix and rebalancing limits;
o the performance measurement criteria;
o monitoring procedures of money managers and other investment-related vendors;
o composition and relevancy of quarterly performance reports;
o composition of custodial reports; and
o termination procedures for money managers.
• Milestone will advise Client of appropriate investment categories for Client’s retirement plan
consistent with Client’s adopted policy statement.
• Milestone will advise Client of appropriate assets/investment instruments which are consistent with
the investment categories selected by Client.
• Milestone will monitor performance of the investment choices of Client and provide periodic advice
regarding possible changes to the investment selections.
• Client shall have ultimate authority for selecting the investments for Client's retirement plan for ERISA
Section 3(21) Plan Investment Advisory Services. For ERISA Section 3(38) Plan Investment Advisory
Services, Milestone will main investment discretion on the accounts.
Client Tailored Services and Client Imposed Restrictions
We offer the same suite of services to all of our clients. However, specific client services are dependent upon
a client Investment Plan, which outlines each client’s current situation (income, tax levels, and risk tolerance
levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches
restrictions, needs, and targets.
6
Wrap Fee Programs
We do not participate in wrap fee programs.
Item 5: Fees and Compensation
Please note, unless a client has received the firm’s disclosure brochure at least 48 hours prior to signing the
investment advisory contract, the investment advisory contract may be terminated by the client within five
(5) business days of signing the contract without incurring any advisory fees and without penalty. How we are
paid depends on the type of advisory service we are performing. Please review the fee and compensation
information below.
Investment Management Services
Our standard advisory fee is based on the market value of the assets under management and is calculated as
follows:
Account Value
Annual Advisory Fee
1.20%
$0 - $999,999
1.10%
$1,000,000 - $1,999,999
1.00%
$2,000,000 - $4,999,999
0.90%
$5,000,000 - $9,999,999
Negotiable
$10,000,000 and Above
The annual fees are negotiable and are pro-rated and paid in arrears on a quarterly basis. The fee is calculated
by using the Average Daily Balance of your portfolio on each business day over the last three months in the
previous calendar quarterly, multiplied by the corresponding advisory fee rate. No increase in the annual fee
shall be effective without agreement from the client by signing a new agreement or amendment to their
current advisory agreement.
Advisory fees are directly debited from client accounts, or the client may choose to pay by check. Accounts
initiated or terminated during a calendar quarter will be charged a pro-rated fee based on the amount of time
remaining in the billing period. An account may be terminated with written notice at least 30 calendar days in
advance. Upon termination of any account, any unpaid fees will be due and payable. Such fees are prorated
based on the number of days left in the billing period.
Investment Advisory Services – Betterment
The standard advisory fee is based on the market value of the account and is calculated as follows:
Account Value
Annual Advisory Fee
0.50%
All Accounts
7
The annual fees are negotiable and are pro-rated and paid in arrears on a quarterly basis. The above fee
schedule does not include Betterment’s advisory fee. No increase in the annual fee shall be effective without
agreement from the client by signing a new agreement or amendment to their current advisory agreement.
Accounts initiated or terminated during a calendar quarter will be charged a pro-rated fee based on the
amount of time remaining in the billing period. An account may be terminated with written notice at least 30
calendar days in advance. Upon termination of any account, any unpaid fees will be due and payable. Such
fees are prorated based on the number of days left in the billing period. Betterment will deduct the advisory
fees from the client’s account.
Financial Planning Fixed Fee
Financial Planning will generally be offered on a fixed fee basis. The fixed fee will be agreed upon before the
start of any work. The fixed fee can range between $2,000 and $15,000. The fee is negotiable. If a fixed fee
program is chosen, half of the fee is due at the beginning of process and the remainder is due at completion
of work, however, Milestone will not bill an amount above $500.00 more than 6 months in advance. In the
event of early termination, the client will be billed for the hours worked at a rate of $300 per hour. If the initial
deposit is greater than the amount billed, then the client will be refunded the difference. If the initial deposit
is less, then the client will be billed the difference.
Financial Planning Hourly Fee
Financial Planning fee is an hourly rate that can range between $150.00 and $300.00 per hour, depending on
complexity. The fee may be negotiable in certain cases and is due at the completion of the engagement. In
the event of early termination by client, any fees for the hours already worked will be due.
Other Types of Fees and Expenses
Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses that
may be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, and other
third parties such as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer
and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual
fund and exchange traded funds also charge internal management fees, which are disclosed in a fund’s
prospectus. Such charges, fees and commissions are exclusive of and in addition to our fee, and we shall not
receive any portion of these commissions, fees, and costs.
Item 12 further describes the factors that we consider in selecting or recommending broker-dealers for client’s
transactions and determining the reasonableness of their compensation (e.g., commissions).
We do not accept compensation for the sale of securities or other investment products including asset-based
sales charges or service fees from the sale of mutual funds.
8
We do not offer performance-based fees.
Item 6: Performance-Based Fees and Side-By-
Side Management
We provide financial planning and portfolio management services to individuals, high net-worth individuals,
pension and profiting sharing plans, charitable organizations, and corporations or other businesses.
Item 7: Types of Clients
Our minimum account size requirement is $500,000.00, which we may waive at our discretion.
Item 8: Methods of Analysis, Investment
Strategies and Risk of Loss
Our portfolio management services are designed to build long-term wealth while maintaining risk tolerance
levels acceptable to you. We combine your financial needs and investment objectives, time horizon, and risk
tolerance to yield an effective investment strategy. Your portfolio is then tailored to these unique investment
parameters using a mix of equity (“stock”) positions and fixed income/debt (“bond”) instruments.
In accordance with the Investment Plan, Milestone will primarily invest client accounts in global common
stocks and ETFs with some use of corporate, government, agency, municipal, international bonds, bond funds
and ETFs. To a very limited extent Milestone may also use mutual funds in order to get access to certain
markets.
Methods of Analysis
The primary investment strategy we use for client accounts is strategic asset allocation. We use passively-
managed index and exchange-traded funds when appropriate for the client. From time to time, we hold
individual stocks or bonds depending on the client circumstance. We do not actively buy individual stocks as
part of our normal investment philosophy, although many clients transfer them into our firm from other
places. Portfolios are generally globally diversified to control the risk associated with the markets.
Passive Investment Management
We primarily practice passive investment management. Passive investing involves building portfolios that are
comprised of various distinct asset classes. The asset classes are weighted in a manner to achieve a desired
relationship between correlation, risk, and return. Funds that passively capture the returns of the desired
asset classes are placed in the portfolio. The funds that are used to build passive portfolios are typically index
mutual funds or exchange traded funds.
9
Passive investment management is characterized by low portfolio expenses (i.e. the funds inside the portfolio
have low internal costs), minimal trading costs (due to infrequent trading activity), and relative tax efficiency
(because the funds inside the portfolio are tax efficient and turnover inside the portfolio is minimal).
In contrast, active management involves a single manager or managers who employ some method, strategy
or technique to construct a portfolio that is intended to generate returns that are greater than the broader
market or a designated benchmark.
Material Risks Involved
All investing strategies we offer involve risk and may result in a loss of your original investment which you
should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities and any other
investment or security. Material risks associated with our investment strategies are listed below.
Market Risk: Market risk involves the possibility that an investment’s current market value will fall because of
a general market decline, reducing the value of the investment regardless of the operational success of the
issuer’s operations or its financial condition.
Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work as intended.
Small and Medium Cap Company Risk: Securities of companies with small and medium market capitalizations
are often more volatile and less liquid than investments in larger companies. Small and medium cap companies
may face a greater risk of business failure, which could increase the volatility of the client’s portfolio.
Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may fall
below par value or the principal investment. The opposite is also generally true: bond prices generally rise
when interest rates fall. In general, fixed income securities with longer maturities are more sensitive to these
price changes. Most other investments are also sensitive to the level and direction of interest rates.
Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or the
securities’ claim on the issuer’s assets and finances.
Inflation: Inflation may erode the buying-power of your investment portfolio, even if the dollar value of your
investments remains the same.
Risks Associated with Securities
Apart from the general risks outlined above which apply to all types of investments, specific securities may
have other risks.
Commercial Paper is, in most cases, an unsecured promissory note that is issued with a maturity of 270 days
or less. Being unsecured the risk to the investor is that the issuer may default.
Common stocks may go up and down in price quite dramatically, and in the event of an issuer’s bankruptcy
or restructuring could lose all value. A slower-growth or recessionary economic environment could have an
adverse effect on the price of all stocks.
Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest and
repay the amount borrowed either periodically during the life of the security and/or at maturity. Alternatively,
investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest,
10
but rather are priced at a discount from their face values and their values accrete over time to face value at
maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit
quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase
when interest rates fall. The longer the time to a bond’s maturity, the greater its interest rate risk.
Bank Obligations including bonds and certificates of deposit may be vulnerable to setbacks or panics in the
banking industry. Banks and other financial institutions are greatly affected by interest rates and may be
adversely affected by downturns in the U.S. and foreign economies or changes in banking regulations.
Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes, including
the construction of public facilities. Municipal bonds pay a lower rate of return than most other types of bonds.
However, because of a municipal bond’s tax-favored status, investors should compare the relative after-tax
return to the after-tax return of other bonds, depending on the investor’s tax bracket. Investing in municipal
bonds carries the same general risks as investing in bonds in general. Those risks include interest rate risk,
reinvestment risk, inflation risk, market risk, call or redemption risk, credit risk, and liquidity and valuation
risk.
Exchange Traded Funds prices may vary significantly from the Net Asset Value due to market conditions.
Certain Exchange Traded Funds may not track underlying benchmarks as expected.
Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the client indirectly
bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the client
will incur higher expenses, many of which may be duplicative. In addition, the client’s overall portfolio may be
affected by losses of an underlying fund and the level of risk arising from the investment practices of an
underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares
may trade at a market price that is above or below their net asset value; (ii) the ETF may employ an investment
strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing
exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the
activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock
trading generally. The Adviser has no control over the risks taken by the underlying funds in which clients
invest.
Criminal or Civil Actions
Item 9: Disciplinary Information
Milestone and its management have not been involved in any criminal or civil action.
Administrative Enforcement Proceedings
Milestone and its management have not been involved in administrative enforcement proceedings.
Self-Regulatory Organization Enforcement Proceedings
Milestone and its management have not been involved in legal or disciplinary events that are material to a
client’s or prospective client’s evaluation of Milestone or the integrity of its management.
11
No Milestone employee is registered, or have an application pending to register, as a broker-dealer or a
registered representative of a broker-dealer.
Item 10: Other Financial Industry Activities
and Affiliations
No Milestone employee is registered, or have an application pending to register, as a futures commission
merchant, commodity pool operator or a commodity trading advisor.
Recommendations or Selections of Other Investment Advisers
Milestone may refer clients to other investment advisers to manage their accounts. This situation creates a
conflict of interest. However, when referring clients to another investment adviser, the client’s best interest
and suitability of the other investment advisers will be the main determining factors of Milestone. This
relationship is disclosed to the client at the commencement of the advisory relationship. These compensation
arrangements present a conflict of interest because Milestone has a financial incentive to recommend the
services of the other investment advisers. You are not obligated, contractually or otherwise, to use the services
of any other investment advisers we recommend. Additionally, Milestone will only recommend another
investment adviser who is properly licensed or registered as an investment adviser.
Item 11: Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading
As a fiduciary, our firm and its associates have a duty of utmost good faith to act solely in the best interests of
each client. Our clients entrust us with their funds and personal information, which in turn places a high
standard on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents
the expected basis of all of our dealings.
Code of Ethics Description
This code does not attempt to identify all possible conflicts of interest, and literal compliance with each of its
specific provisions will not shield associated persons from liability for personal trading or other conduct that
violates a fiduciary duty to advisory clients. A summary of the Code of Ethics' Principles is outlined below.
•
Integrity - Associated persons shall offer and provide professional services with integrity.
•
Objectivity - Associated persons shall be objective in providing professional services to clients.
•
Competence - Associated persons shall provide services to clients competently and maintain the
necessary knowledge and skill to continue to do so in those areas in which they are engaged.
12
•
Fairness - Associated persons shall perform professional services in a manner that is fair and
reasonable to clients, principals, partners, and employers, and shall disclose conflict(s) of interest in
providing such services.
•
Confidentiality - Associated persons shall not disclose confidential client information without the
specific consent of the client unless in response to proper legal process, or as required by law.
•
Professionalism - Associated persons’ conduct in all matter shall reflect credit of the profession.
•
Diligence - Associated persons shall act diligently in providing professional services.
We periodically review and amend our Code of Ethics to ensure that it remains current, and we require all
firm access persons to attest to their understanding of and adherence to the Code of Ethics at least annually.
Our firm will provide of copy of its Code of Ethics to any client or prospective client upon request.
Investment Recommendations Involving a Material Financial Interest and Conflicts
of Interest
Neither our firm, its associates or any related person is authorized to recommend to a client, or effect a
transaction for a client, involving any security in which our firm or a related person has a material financial
interest, such as in the capacity as an underwriter, adviser to the issuer, etc.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts
of Interest
Our firm and its “related persons” may buy or sell securities similar to, or different from, those we recommend
to clients for their accounts. In an effort to reduce or eliminate certain conflicts of interest involving the firm
or personal trading, our policy may require that we restrict or prohibit associates’ transactions in specific
reportable securities transactions. Any exceptions or trading pre-clearance must be approved by the firm
principal in advance of the transaction in an account, and we maintain the required personal securities
transaction records per regulation.
Trading Securities At/Around the Same Time as Client’s Securities
From time to time, our firm or its “related persons” may buy or sell securities for themselves at or around the
same time as clients. We will not trade non-mutual fund securities 5 days prior to the same security for clients.
Investment Advice Relating to Retirement Accounts
When we provide investment advice to you regarding your retirement plan account or individual retirement
account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act
and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we
make money creates some conflicts with your interests, so we operate under a special rule that requires us to
act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice).
• Never put our financial interests ahead of yours when making recommendations (give loyal advice).
• Avoid misleading statements about conflicts of interest, fees, and investments.
• Follow policies and procedures designed to ensure that we give advice that is in your best interest.
13
• Charge no more than is reasonable for our services.
• Give you basic information about conflicts of interest.
In addition, and as required by this rule, we provide information regarding the services that we provide to you,
and any material conflicts of interest, in this brochure and in your client agreement.
Factors Used to Select Custodians and/or Broker-Dealers
Item 12: Brokerage Practices
Milestone Asset Management Group, LLC does not have any affiliation with Broker-Dealers. Specific custodian
recommendations are made to client based on their need for such services. We recommend custodians based
on the reputation and services provided by the firm.
1. Research and Other Soft-Dollar Benefits
We currently do not receive soft dollar benefits.
2. Brokerage for Client Referrals
We receive no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third
party.
3. Clients Directing Which Broker/Dealer/Custodian to Use
We do recommend a specific custodian for clients to use, however, clients may custody their assets at a
custodian of their choice. Clients may also direct us to use a specific broker-dealer to execute transactions.
By allowing clients to choose a specific custodian, we may be unable to achieve most favorable execution of
client transaction, and this may cost clients’ money over using a lower-cost custodian. Subject to its duty of
best execution, Milestone may decline a client’s request to direct brokerage orders in the event that Milestone
believes the request is not in a client’s best interest, such directed brokerage arrangements would result in
additional operational difficulties.
The Custodian and Brokers We Use
Milestone Asset Management Group, LLC does not maintain custody of your assets that we manage, although
we may be deemed to have custody of your assets if you give us authority to withdraw advisory fees from
your account (see Item 15—Custody, below). Your assets must be maintained in an account at a “qualified
custodian,” generally a broker-dealer or bank. We may recommend that our clients use Fidelity Investments,
a registered broker-dealer, Member SIPC, as the qualified custodian. We are independently owned and
operated and are not affiliated with Fidelity Investments. Fidelity Investments will hold your assets in a
brokerage account and buy and sell securities when we and/or you instruct them to. While we may
recommend that you use Fidelity Investments as custodian/broker, you will decide whether to do so and will
open your account with Fidelity Investments by entering into an account agreement directly with them. We
do not open the account for you, although we may assist you in doing so. If you do not wish to place your
assets with Fidelity Investments, then we cannot manage your account on Fidelity Investments (defined
below). In addition to Fidelity Investments, we do also recommend MTG, LLC dba Betterment Securities
(“Betterment Securities”).
14
Your Brokerage and Custody Costs
For our clients’ accounts that Betterment Securities maintains, Betterment Securities generally does not
charge you separately for custody services but is compensated as part of the Betterment Institutional (defined
below) platform fee, which is a percentage of the dollar amount of assets in the account in lieu of commissions.
We have determined that having Betterment Securities execute trades is consistent with our duty to seek
“best execution” of your trades. Best execution means the most favorable terms for a transaction based on
all relevant factors, including those listed above (see “Factors Used to Select Custodians and/or Broker-
Dealers”).
Services Available to Us via Betterment Institutional
Betterment Securities serves as broker dealer to Betterment Institutional, an investment and advice platform
serving independent investment advisory firms like us (“Betterment Institutional”). Betterment Institutional
also makes available various support services which may not be available to Betterment’s retail customers.
Some of those services help us manage or administer our clients’ accounts, while others help us manage and
grow our business. Betterment Institutional’s support services are generally available on an unsolicited basis
(we don’t have to request them) and at no charge to us. Following is a more detailed description of Betterment
Institutional’s support services:
1. SERVICES THAT BENEFIT YOU. Betterment Institutional includes access to a range of investment
products, execution of securities transactions, and custody of client assets through Betterment
Securities. Betterment Securities’ services described in this paragraph generally benefit you and your
account.
2. SERVICES THAT MAY NOT DIRECTLY BENEFIT YOU. Betterment Institutional 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, such as software
and technology that may:
a. Assist with back-office functions, recordkeeping, and client reporting of our clients’ accounts.
b. Provide access to client account data (such as duplicate trade confirmations and account
statements).
c. Provide pricing and other market data.
3. SERVICES THAT GENERALLY BENEFIT ONLY US. By using Betterment Institutional, we will be offered
other services intended to help us manage and further develop our business enterprise. These services
include:
a. Educational conferences and events.
b. Consulting on technology, compliance, legal, and business needs.
c. Publications and conferences on practice management and business succession.
Our Interest in Betterment Securities’ Services
The availability of these services from Betterment Institutional benefits us because we do not have to produce
or purchase them. In addition, we don’t have to pay for Betterment Securities’ services. These services may
be contingent upon us committing a certain amount of business to Betterment Securities in assets in custody.
We may have an incentive to recommend that you maintain your account with Betterment Securities, based
15
on our interest in receiving Betterment Institutional and Betterment Securities’ services that benefit our
business rather than based on your interest in receiving the best value in custody services and the most
favorable execution of your transactions. This is a potential conflict of interest. We believe, however, that our
selection of Betterment Securities as custodian and broker is in the best interests of our clients. Our selection
is primarily supported by the scope, quality, and price of Betterment Securities’ services and not Betterment
Institutional and Betterment Securities’ services that benefit only us.
Aggregating (Block) Trading for Multiple Client Accounts
Transactions for each client generally will be affected independently, unless Milestone decides to purchase or
sell the same securities for several or more clients at approximately the same time. Milestone may (but is not
obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable
commission rates, or to allocate equitably among Milestone’s client’s differences in prices and commissions
or other transaction costs that might have been obtained had such orders been placed independently. Under
this procedure, transactions will generally be averaged as to price and allocated among Milestone’s clients pro
rata to the purchase and sale orders placed for each client on any given day. To the extent that Milestone
determines to aggregate client orders for the purchase or sale of securities, including securities in which
Milestone’s Supervised Persons may invest, Milestone shall generally do so in accordance with applicable rules
promulgated under the Advisers Act and no-action guidance provided by the staff of the U.S. Securities and
Exchange Commission. Milestone shall not receive any additional compensation or remuneration as a result
of the aggregation. In the event that Milestone determines that a prorated allocation is not appropriate under
the particular circumstances, the allocation will be made based upon other relevant factors, which may
include:
• When only a small percentage of the order is executed, shares may be allocated to the account with
the smallest order or the smallest position or to an account that is out of line with respect to security
or sector weightings relative to other portfolios, with similar mandates.
•
• Allocations may be given to one account when one account has limitations in its investment guidelines
which prohibit it from purchasing other securities which are expected to produce similar investment
results and can be purchased by other accounts.
If an account reaches an investment guideline limit and cannot participate in an allocation, shares may
be reallocated to other accounts (this may be due to unforeseen changes in an account’s assets after
an order is placed).
•
• With respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a
pro rata allocation of a potential execution would result in a de-minimis allocation in one or more
accounts, Milestone may exclude the account(s) from the allocation; the transactions may be executed
on a pro rata basis among the remaining accounts.
In cases where a small proportion of an order is executed in all accounts, shares may be allocated to
one or more accounts on a random basis.
16
Item 13: Review of Accounts
Client accounts with the Investment Management Service will be reviewed regularly on a quarterly basis by
Michael Mezheritskiy, Managing Member and CCO. The account is reviewed with regards to the client’s
investment policies and risk tolerance levels. Events that may trigger a special review would be unusual
performance, addition or deletions of client-imposed restrictions, excessive draw-down, volatility in
performance, or buy and sell decisions from the firm or per client's needs.
Clients will receive trade confirmations from the broker(s) for each transaction in their accounts as well as
monthly or quarterly statements and annual tax reporting statements from their custodian showing all activity
in the accounts, such as receipt of dividends and interest.
Most commonly, reporting is provided quarterly, but the client may request reports more frequently
(monthly) or less frequently but no less frequently than annually. You are also encouraged to review with us
investment strategies and account performance on an annual basis. Material changes in your personal
circumstances, the general economy, or tax law changes can trigger more frequent reviews. However, it is
your responsibility to communicate these changes to us so that the appropriate adjustments can be made.
We do not receive any economic benefit, directly or indirectly from any third party for advice rendered to our
clients.
Item 14: Client Referrals and Other
Compensation
We receive a non-economic benefit from Betterment Institutional and Betterment Securities in the form of
the support products and services it makes available to us and other independent investment advisors whose
clients maintain their accounts at Betterment Securities. These products and services, how they benefit us,
and the related conflicts of interest are described above (see Item 12—Brokerage Practices). The availability
to us of Betterment Institutional and Betterment Securities’ products and services is not based on us giving
particular investment advice, such as buying particular securities for our clients.
Item 15: Custody
Milestone does not accept custody of client funds. Clients should receive at least quarterly statements from
the broker dealer, bank or other qualified custodian that holds and maintains client's investment assets. We
urge you to carefully review such statements and compare such official custodial records to the account
statements or reports that we may provide to you. Our statements or reports may vary from custodial
statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities.
17
Item 16: Investment Discretion
For those client accounts where we provide investment management services, we maintain discretion over
client accounts with respect to securities to be bought and sold and the amount of securities to be bought and
sold. Investment discretion is explained to clients in detail when an advisory relationship has commenced. At
the start of the advisory relationship, the client will execute a Limited Power of Attorney, which will grant our
firm discretion over the account. Additionally, the discretionary relationship will be outlined in the advisory
contract and signed by the client. Clients may impose reasonable restrictions on investing in certain securities,
types of securities, or industry sectors.
Item 17: Voting Client Securities
We do not vote Client proxies. Therefore, Clients maintain exclusive responsibility for: (1) voting proxies, and
(2) acting on corporate actions pertaining to the Client’s investment assets. The Client shall instruct the Client’s
qualified custodian to forward to the Client copies of all proxies and shareholder communications relating to
the Client’s investment assets. If the client would like our opinion on a particular proxy vote, they may contact
us at the number listed on the cover of this brochure.
In most cases, you will receive proxy materials directly from the account custodian. However, in the event we
were to receive any written or electronic proxy materials, we would forward them directly to you by mail,
unless you have authorized our firm to contact you by electronic mail, in which case, we would forward you
any electronic solicitation to vote proxies.
Item 18: Financial Information
Registered investment advisers are required in this Item to provide you with certain financial information or
disclosures about our financial condition. We have no financial commitment that impairs our ability to meet
contractual and fiduciary commitments to clients, and we have not been the subject of a bankruptcy
proceeding.
We do not have custody of client funds or securities or require or solicit prepayment of more than $1,200 in
fees per client six months in advance.
18
WHAT DOES MILESTONE DO WITH YOUR PERSONAL INFORMATION?
Privacy Notice
FACTS
Why?
Registered investment advisers choose how they share your personal information. Federal law
gives clients the right to limit some but not all sharing. Federal law also requires us to tell you
h o w we collect, share, and protect your personal information. Please read this notice carefully
to understand what we do.
What?
The types of personal information we collect, and share depend on the product or service you
have with us. This information can include:
Information you provide in the subscription documents and other forms (including
name, address, social security number, date of birth, income and other financial-
related information); and
Data about your transactions with us (such as the types of investments you have
made and your account status).
How?
All financial companies need to share clients’ personal information to run their everyday
business. In the section below, we list the reasons financial companies can share their clients’
personal information; the reasons Milestone chooses to share; and whether you can limit this
sharing.
Reasons we can share your personal information
For our everyday business purposes— to process your transactions, maintain your accounts (for example we may
share with our third-party service providers that perform services on our behalf or on your behalf, such as accountants,
attorneys, consultants, clearing and custodial firms, and technology companies, respond to court orders and legal
investigations, or report to credit bureaus.
For Marketing purposes— to offer our products and services to you
How do we protect your information?
To safeguard your personal information from unauthorized access and use, we maintain physical, procedural and
electronic safeguards. These include computer safeguards such as passwords, secured files and buildings.
Our employees are advised about Milestone's need to respect the confidentiality of each client’s non-public personal
information. We train our employees on their responsibilities.
We require third parties that assist in providing our services to you to protect the personal information they receive.
This includes contractual language in our third-party agreements.
Other important information
We will send you notice of our Privacy Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise our Privacy 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.
19
Milestone Asset Management Group, LLC
302 West Main Street, Suite 206
Avon, CT 06001
860.259.4800
www.milestoneamg.com
Dated January 15, 2026
For
Form ADV Part 2B – Brochure Supplement
Michael Mezheritskiy
Managing Member, and Chief Compliance Officer
This brochure supplement provides information about Michael Mezheritskiy that supplements the Milestone
Asset Management Group, LLC (“Milestone”) brochure. A copy of that brochure precedes this supplement.
Please contact Michael Mezheritskiy if the Milestone brochure is not included with this supplement or if you
have any questions about the contents of this supplement.
information about Michael Mezheritskiy
is available on
the SEC’s website at
Additional
www.adviserinfo.sec.gov.
20
Item 2: Educational Background and Business
Michael Mezheritskiy
Experience
Born: 1977
Educational Background
• 2001 – Bachelor of Arts in Finance with a Minor in Computer Information Systems, Suffolk University
Business Experience
• 02/2016 – Present, Milestone Asset Management Group, LLC, Managing Member and CCO
• 04/2014 – 02/2016, Visionary Wealth Management Group, LLC, Founding Partner and CCO
• 07/2013 – 05/2014, LPL Financial, Registered Rep and IAR
• 07/2000 – 06/2013, Fidelity Investments, Senior Account Executive, Private Client Group
No management person at Milestone Asset Management Group, LLC has ever been involved in an arbitration
claim of any kind or been found liable in a civil, self-regulatory organization, or administrative proceeding.
Item 3: Disciplinary Information
Mr. Mezheritskiy writes and hosts a podcast called “Fresh Perspective Planning”. He spends about 1 to 2 hours
a month on the podcast. While the podcast may cover certain financial topics, it is designed to be general in
nature and not designed to address the needs of any specific individuals.
Item 4: Other Business Activities
Michael Mezheritskiy does not receive any economic benefit from any person, company, or organization, in
exchange for providing clients advisory services through Milestone.
Item 5: Additional Compensation
Mr. Mezheritskiy, as Managing Member and Chief Compliance Officer of Milestone, is responsible for
supervision. He may be contacted at the phone number on this brochure supplement.
Item 6: Supervision
21