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Cover Page - Item 1
Millennial Wealth Advisors, LLC
April 16, 2026
Primary Office:
906 Bond Way
Delray Beach, FL 33483
Branch Office:
231 South LaSalle Street
Suite 2100
Chicago, IL 60604
Telephone: (312) 637-1850
Fax: (312) 690-3926
Email : cheekin@millennialwa.com
Website : www.millennialwealthadvisors.com
Millennial Wealth Advisors, LLC is an investment adviser registered with the Securities and Exchange
Commission ("SEC"). An "investment adviser" means any person who, for compensation, engages in the
business of advising others, either directly or through publications or writings, as to the value of securities
or as to the advisability of investing in, purchasing, or selling securities, or who, for compensation and as
part of a regular business, issues or promulgates analyses or reports concerning securities. Registration
with the SEC or any state securities authority does not imply a certain level of skill or training.
This brochure provides information about the qualifications and business practices of Millennial Wealth
Advisors, LLC If you have any questions about the contents of this brochure, please contact us at (312)
637-1850. 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.
Additional information about Millennial Wealth Advisors, LLC is available on the SEC’s website at
www.adviserinfo.sec.gov. The firm's CRD/IARD number is 174201.
Millennial Wealth Advisors, LLC
Form ADV Part 2A Brochure
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Material Changes - Item 2
The purpose of this page is to inform you of any material changes since the previous version of this brochure.
On March 12, 2026, we submitted our annual updating amendment filing for fiscal year 2025. We have updated
Item 4 of our Form ADV Part 2A Brochure to disclose discretionary assets under management of approximately
$0, and non-discretionary assets under management of approximately $146,048,654.
In preparation for the transition of our registration to the SEC, we completed a rewrite of our Form ADV Part 2A
Brochure. Clients are encouraged to review the document in full to better understand our services, fees, business
practices, and conflicts of interest and how we address them.
In addition, we amended the Methods of Analysis, Investment Strategies and Risk of Loss section (Item 8) of the
document to disclose additional material investment risks (Item 8) pertaining to Direct Indexing, Securities Backed
Lines of Credit (SBLOCs), Political Risk and Artificial Intelligence ("AI") Risk.
If you would like to receive a complete copy of our current brochure free of charge at any time, please contact us
at (312) 637-1850 or at cheekin@millennialwa.com.
Millennial Wealth Advisors, LLC
Form ADV Part 2A Brochure
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Table of Contents - Item 3
Contents
Cover Page - Item 1 ................................................................................................................................... 1
Material Changes - Item 2 ......................................................................................................................... 2
Table of Contents - Item 3 ........................................................................................................................ 3
Advisory Business - Item 4 ........................................................................................................................ 4
Fees and Compensation - Item 5 .............................................................................................................. 5
Performance-Based Fees and Side-By-Side Management - Item 6 .......................................................... 7
Types of Clients - Item 7............................................................................................................................ 7
Methods of Analysis, Investment Strategies and Risk of Loss - Item 8 ..................................................... 7
Disciplinary Information - Item 9 ............................................................................................................ 15
Other Financial Industry Activities or Affiliations - Item 10 .................................................................... 15
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11 ........... 15
Brokerage Practices - Item 12 ................................................................................................................. 16
Review of Accounts - Item 13 ................................................................................................................. 18
Client Referrals and Other Compensation - Item 14 .............................................................................. 18
Custody - Item 15 .................................................................................................................................... 18
Investment Discretion - Item 16 ............................................................................................................. 19
Voting Client Securities - Item 17 ........................................................................................................... 19
Financial Information - Item 18 .............................................................................................................. 19
Requirements of State-Registered Advisers - Item 19 ............................................................................ 20
Millennial Wealth Advisors, LLC Privacy Policy Notice ........................................................................... 20
Millennial Wealth Advisors, LLC
Form ADV Part 2A Brochure
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Advisory Business - Item 4
Millennial Wealth Advisors, LLC (“Millennial Wealth” and/or “the firm”) is a limited liability company formed
under the laws of the State of Florida. Charles L. Heekin II is the firm’s Sole Owner, Managing Partner, President
and Chief Compliance Officer. Millennial Wealth has been offering investment advisory services since 2015.
The following paragraphs describe our services and fees. You may see the term Associated Person throughout
this Brochure. As used in this Brochure, this term refers to anyone from our firm who is an officer, employee, and
all individuals providing investment advice on behalf of our firm. Where required, such persons are properly
licensed or registered as investment adviser representatives.
Portfolio Management Services
Our firm offers portfolio management services to its clients with a limited discretionary authority. Our investment
advice is tailored to meet our clients’ needs and investment objectives. If you decide to hire our firm to assist you
with the management of your portfolio, an Associated Person of our firm will meet with you and gather
information about your financial situation, investment objectives, and any reasonable restrictions you would like
to impose on the management of the account. The information we gather will help us implement an asset
allocation strategy that will be specific to your needs and goals.
Millennial Wealth takes on limited discretionary authority when providing you with portfolio management
services. The Associated Person assigned to your account must contact you to discuss recommendations for
changes within your account and no changes will be made to the allocation of your account without prior
consultation with you. We will periodically, without your prior consent, rebalance your account in accordance
with your previously stipulated goals, objectives, or needs to maintain the initial agreed upon asset allocation.
We require client approval prior to the implementation of a new asset allocation. You may further limit our
discretionary authority by setting a limit on the type of securities that can be purchased for your account. Simply
provide us with your restrictions or guidelines in writing.
We primarily use mutual funds, exchange traded funds, equities, options, debt securities, variable life, and
variable annuity sub-accounts (certain restrictions may apply). However, managed accounts are not exclusively
limited to these investments and we reserve the right to recommend any other type of investment that we deem
appropriate for the client’s investment profile.
Currently our asset allocation and advisory services are offered directly by our firm or in conjunction with a sub
adviser. Where we use the services of a sub adviser, the sub adviser assists our firm with back-office support, and
trading. We use model portfolios developed by our firm, the sub adviser and/or other registered investment
advisers. Where third party models are used, these other investment advisers are responsible for the research
and security selection within model portfolios, day-to-day trading, and other back-office operations. Millennial
Wealth is responsible for the supervision of the account, portfolio reallocations and rebalancing, and ongoing
client interaction and servicing.
All accounts are managed in accordance with the client’s investment needs. Investments may include various
types of securities such as equities, Exchange Traded Funds (ETFs), mutual funds, private placements, corporate
debt securities, commercial paper, certificates of deposit, municipal securities, and U.S. Government securities.
Other types of investments may also be recommended where such investments are appropriate based on the
client’s stated goals and objectives.
Investments and allocations are determined and based upon the client’s predefined objectives, risk tolerance,
time horizon, financial horizon, financial information, and other various suitability factors. Further restrictions and
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guidelines imposed by the client may affect the composition and performance of a client’s portfolio. For these
reasons, performance of the portfolio may not be identical to other clients of Millennial Wealth. On an ongoing
basis, Millennial Wealth reviews the client’s financial circumstances and investment objectives, and instructs the
sub adviser to make the necessary adjustments to the client’s portfolio.
Clients are advised to provide the firm with prompt notice of any changes in their personal financial
circumstances, investment objectives, goals, and tolerance for risk. However, Millennial Wealth will contact the
client at least annually to determine whether there have been any changes in the client's personal financial
circumstances, investment objectives, and tolerance for risk.
Wrap Fee Programs
A wrap fee program combines asset management, advisory services, and trade execution for a single fee. We do
not sponsor or manage, or participate in any wrap fee programs. Our portfolio management fees are exclusive of,
and in addition to brokerage commissions, transaction fees, and other related costs and expenses, which will be
incurred by the client. However, we will not receive any portion of the commissions, fees, and costs. Please see
Item 5 below for information regarding additional fees and Item 12 below for further information on brokerage
practices, fees, and transaction costs.
Assets Under Management
As of December 31, 2025, we manage approximately $0 in client assets on a discretionary basis and $146,048,654
in client assets on a non-discretionary basis.
Fees and Compensation - Item 5
Portfolio Management Services Fees
For portfolio management services, Millennial Wealth typically charges an annual fee of up to 1.00% of assets
under management. In certain limited cases, a fee of up to 2.00% of assets under management will be charged
for accounts that are invested in complex financial instruments and alternative investments. In some cases, clients
of our firm may need additional assistance with consolidated performance reports covering self-managed
accounts and/or accounts managed by outside managers. In such cases we provide consolidated reporting
services using our portfolio management software for an additional fee of up to 0.15%.
Fees are payable quarterly in arrears, and are based on the value of the assets on the last day of the quarter just
ended. Other fee payment arrangements can be negotiated on a case-by-case basis. All fee payment
arrangements will be listed in the advisory agreement signed by the firm and the client. We may modify the fee
at any time upon 30 days’ written notice. The fee listed above does not include the compensation received by the
sub-adviser. These fees will be disclosed separately by the sub-adviser in its Form ADV or equivalent disclosure
brochure and will be directly deducted by the sub-adviser.
We value accounts in accordance with asset values disclosed on the statement you receive from the custodian of
record for the purpose of verifying the computation of the advisory fee. In the rare absence of a reportable
market value, our firm may seek a third‐party opinion from a recognized industry source (e.g., unaffiliated public
accounting firm), and the client may choose to separately seek such an opinion at their own expense.
The fee is deducted from the client's account held at the custodian. The client authorizes us to debit the fee from
the client’s account. If insufficient cash is available to pay such fees, securities in an amount equal to the balance
of unpaid fees will be liquidated to pay for the unpaid balance. We may deduct the fee from a single, client-
designated account to facilitate billing. We encourage you to carefully review the statements you receive from
the qualified custodian. If you have questions about your statements, or if you did not receive a statement from
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the qualified custodian, please call our office number located on the cover page of this brochure. In limited cases,
we may invoice the client directly for the payment of fees.
Our annual fee is exclusive of and in addition to brokerage commissions, transaction fees, and other related costs
and expenses, which will be incurred by the client. However, we will not receive any portion of the commissions,
fees, and costs. Please see Item 12 – Brokerage Practices for further information on brokerage and transaction
costs.
The portfolio management agreement may be canceled at any time by the client or by Millennial Wealth with 15
days’ prior written notice to the other party. Refunds are not applicable because fees are payable in arrears.
Millennial Wealth cannot warrant or guarantee the achievement of a particular goal or level of account
performance, or that a client account will be profitable over time. Past performance is not necessarily indicative
of future results.
Additional Information About Fees and Expenses
Advisory recommendations are based on financial information and situation that you disclose to us at the time
the services are provided. Certain assumptions may be made with respect to interest and inflation rates and the
use of past trends and performance of the market and economy. Past performance is in no way an indication of
future returns. As your financial situation, goals, objectives, or needs change, you must notify us promptly.
Millennial Wealth’s fees are negotiable based on the complexity of client goals and objectives and level of services
rendered. Fees are charged as described above and are not based on a share of capital gains of the funds of an
advisory client.
Private Placements: As part of our overall portfolio management services, we recommend investments in private
placements and other pooled investment vehicles (“Funds”). These Funds are sponsored and managed by
unaffiliated third parties. In such cases, we are responsible for providing initial research, due diligence, and
evaluation of each Fund, and assisting clients in understanding the risks and rewards of each Fund. We also
provide ongoing updates to clients regarding the progress of the Funds, underlying investments, and various other
communications. In some cases, we have negotiated a fee reduction on the management fee charged by the
investment manager of the Fund(s) to our clients. However, clients should note that the value of investments in
Funds is included in the calculation of our overall portfolio management fees.
Investment Company Fees: All fees paid to Millennial Wealth for investment advisory services are separate and
distinct from the fees and expenses charged by mutual funds, exchange traded funds, or other types of
investment companies to their shareholders. These fees and expenses are described in each fund's prospectus.
These fees generally include management fees, other fund expenses, early redemption fees, and possible
distribution fees. A client could invest in a mutual fund directly, without the services of Millennial Wealth. In that
case, the client would not receive the services provided by Millennial Wealth, which are designed, among other
things, to assist the client in determining which mutual fund or funds are most appropriate to each client's
financial condition and objectives. Accordingly, the client should review both the fees charged by the funds and
the fees charged by Millennial Wealth to understand fully the total amount of fees to be paid by the client and to
evaluate the advisory services being provided.
Further information regarding fees and charges assessed by a mutual fund is available in each mutual fund’s
prospectus. Although the firm uses its best efforts to purchase lower cost mutual fund shares when available,
some mutual fund companies do not offer institutional classes or funds that do not pay 12b-1 distribution fees.
Billing on Cash Positions: The firm treats cash and cash equivalents as an asset class. Accordingly, unless otherwise
agreed in writing, all cash and cash equivalent positions (e.g., money market funds, etc.) are included as part of
assets under management for purposes of calculating the firm’s advisory fee. At any specific point in time,
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depending upon perceived or anticipated market conditions/events (there being no guarantee that such
anticipated market conditions/events will occur), the firm may maintain cash and/or cash equivalent positions for
defensive, liquidity, or other purposes. While assets are maintained in cash or cash equivalents, such amounts
could miss market advances and, depending upon current yields, at any point in time, the firm’s advisory fee could
exceed the interest paid by the client’s cash or cash equivalent positions.
Periods of Portfolio Inactivity: The firm has a fiduciary duty to provide services consistent with the client’s best
interest. As part of its investment advisory services, the firm will review client portfolios on an ongoing basis to
determine if any changes are necessary based upon various factors, including but not limited to investment
performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial
circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may
be extended periods of time when the firm determines that changes to a client’s portfolio are neither necessary
nor prudent. Notwithstanding, unless otherwise agreed in writing, the firm’s annual investment advisory fee will
continue to apply during these periods, and there can be no assurance that investment decisions made by the
firm will be profitable or equal any specific performance level(s).
Performance-Based Fees and Side-By-Side Management - Item 6
Performance-based fees are based on a share of capital gains on or capital appreciation of the client’s assets. Side
by-side management refers to managing accounts that pay performance-based fees alongside those that do not
pay performance-based fees. Our firm and Associated Persons do not accept performance-based fees.
Types of Clients - Item 7
We generally offer investment advisory services to individuals, high-net-worth clients, family offices, pension and
profit-sharing plans and their participants, trusts, estates, charitable organizations, foundations, corporations,
and other business entities.
We require a minimum of $2,000,000 to establish an advisory relationship with us. We reserve the right to waive
or reduce our required minimum based on unique circumstances, special arrangements, or preexisting
relationships. We also reserve the right to decline services to any prospective client for any non‐discriminatory
reason.
Methods of Analysis, Investment Strategies and Risk of Loss - Item 8
Methods of Analysis
Millennial Wealth primarily uses technical analysis. Technical analysis is a technique that relies on the assumption
that current market data (such as charts of price, volume, and open interest) can help predict future market
trends, at least in the short term. It assumes that market psychology influences trading and can predict when
stocks will rise or fall. Technical trading models are mathematically driven based on historical data and trends of
domestic and foreign market trading activity, including various industry and sector trading statistics within such
markets. Technical trading models, through mathematical algorithms, attempt to identify when markets are likely
to increase or decrease and identify appropriate entry and exit points. The primary risk of technical trading models
is that historical trends and past performance cannot predict future trends, and there is no assurance that the
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mathematical algorithms employed are designed properly, updated with new data, and can accurately predict
future market, industry, and sector performance.
Third-party model providers develop asset allocation models in accordance with their investment programs. In
such cases Millennial Wealth will not implement its own methods of analysis. Clients should refer to the relevant
third-party model provider’s Form ADV Part 2 Brochures or other disclosure documents for more information
about the methods of analysis used by those firms.
Investment Strategies
Millennial Wealth uses the following investment strategies when advising you on investments:
Long Term Purchases – securities purchased with the expectation that the value of those securities will grow over
a relatively long period of time, generally greater than one year. Using a long-term purchase strategy generally
assumes the financial markets will go up in the long-term which may not be the case. There is also the risk that
the segment of the market that you are invested in or perhaps just your particular investment will go down over
time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity
cost - "locking-up" assets that may be better utilized in the short-term in other investments.
Short Term Purchases – securities purchased with the expectation that they will be sold within a relatively short
period of time, generally less than one year, to take advantage of the securities' short-term price fluctuations.
Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform
in the short-term which may be very difficult and will incur a disproportionately higher amount of transaction
costs compared to long-term trading. There are many factors that can affect financial market performance in the
short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a
smaller impact over longer periods of times.
Trading – Although trading is not used as part of Millennial Wealth’s overall investment strategy, Associated
Persons of the firm may employ this strategy on a limited basis where they determine that this strategy is suitable
given the client’s stated investment objectives and risk tolerance.
Margin Transactions – Margin strategies allow an investor to purchase securities on credit and to borrow on
securities already in their custodial account. Interest is charged on any borrowed funds for the period that the
loan is outstanding. When you purchase securities, you may pay for the securities in full or you may borrow part
of the purchase price from your broker-dealer. If you intend to borrow funds in connection with your account,
you will be required to open a margin account, which will be carried by the broker-dealer of your account. The
securities purchased in such an account are the broker-dealer’s collateral for its loan to you. If the securities in a
margin account decline in value, the value of the collateral supporting this loan also declines, and, as a result, a
brokerage firm is required to take action, such as issue a margin call and/or sell securities or other assets in your
accounts, in order to maintain necessary level of equity in the account. It is important that you fully understand
the risks involved in trading securities on margin, which are applicable to any margin account that you may
maintain, including any margin Account that may be established as a part of our advisory services and held by
your broker-dealer. These risks include the following:
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You can lose more funds than you deposit in your margin account.
The broker-dealer can force the sale of securities or other assets in your account.
The broker-dealer can sell your securities or other assets without contacting you.
You may not be able to choose which securities or other assets in your margin account are liquidated or
sold to meet a margin call.
The broker-dealer may move securities held in your cash account to your margin account and pledge the
transferred securities.
You may not be entitled to an extension of time on a margin call.
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Risk of Loss - Investing in securities involves risk of loss that clients should be prepared to bear.
Clients should fully understand the nature of the contractual relationship(s) into which they are entering and the
extent of their exposure to risk. Certain investing strategies may not be suitable for many members of the public.
You should carefully consider whether the strategies employed would be appropriate for you in light of your
experience, objectives, financial resources, and other relevant circumstances.
Recommendation of Particular Types of Securities: As disclosed under the “Advisory Business” section in this
Brochure, we provide advice on various types of securities and we do not necessarily recommend one particular
type of security over another since each client has different needs and different tolerance for risk. Each type of
security has its own unique set of risks associated with it and it would not be possible to list here all of the specific
risks of every type of investment. Even within the same type of investment, risks can vary widely. However, in
very general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with
it.
General Investment Risk: All investments come with the risk of losing money. Investing involves substantial risks,
including complete possible loss of principal plus other losses and may not be suitable for many members of the
public. Investments, unlike savings and checking accounts at a bank, are not insured by the government to protect
against market losses. Different market instruments carry different types and degrees of risk and you should
familiarize yourself with the risks involved in the particular market instruments in which you intend to invest.
Loss of Value: There can be no assurance that a specific investment will achieve its investment objectives and past
performance should not be seen as a guide to future returns. The value of investments and the income derived
may fall as well as rise and investors may not recoup the original amount invested. Investments may also be
affected by any changes in exchange control regulation, tax laws, withholding taxes, international, political and
economic developments, and governmental economic or monetary policies.
Interest Rate Risk: Fixed income securities and funds that invest in bonds and other fixed income securities may
fall in value if interest rates change. Generally, the prices of debt securities rise when interest rates fall, and their
prices fall when interest rates rise. Longer-term debt securities are usually more sensitive to interest rate changes.
Credit Risk: Investments in bonds and other fixed income securities are subject to the risk that the issuer(s) may
not make required interest payments. An issuer suffering an adverse change in its financial condition could lower
the credit quality of a security, leading to greater price volatility of the security. A lowering of the credit rating of
a security may also offset the security's liquidity, making it more difficult to sell. Funds investing in lower quality
debt securities are more susceptible to these problems and their value may be more volatile.
Foreign Exchange Risk: Foreign investments may be affected favorably or unfavorably by exchange control
regulations or changes in the exchange rates. Changes in currency exchange rates may influence the share value,
the dividends or interest earned and the gains and losses realized. Exchange rates between currencies are
determined by supply and demand in the currency exchange markets, the international balance of payments,
governmental intervention, speculation, and other economic and political conditions. If the currency in which a
security is denominated appreciates against the US Dollar, the value of the security will increase. Conversely, a
decline in the exchange rate of the currency would adversely affect the value of the security.
Risks Associated with Investing in Equities: Investments in equities generally refers to buying shares of stocks by
an individual or firms in return for receiving a future payment of dividends and capital gains if the value of the
stock increases. There is an innate risk involved when purchasing a stock that it may decrease in value and the
investment may incur a loss.
Risks Associated with Investing in Mutual Funds and Exchange Traded Funds (ETFs): Mutual funds and ETFs are
professionally managed collective investment systems that pool money from many investors and invest in stocks,
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bonds, short-term money market instruments, other funds, other securities, or any combination thereof. The
fund will have a manager that trades the fund's investments in accordance with the fund's investment objective.
While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is
concentrated in a particular sector of the market, primarily invests in small cap or speculative companies, uses
leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e.,
equities) rather than balancing the fund with different types of securities. The returns on mutual funds and ETFs
can be reduced by the costs to manage the funds. In addition, while some mutual funds are “no load” and charge
no fee to buy into, or sell out of, other types of mutual funds do charge such fees which can also reduce
returns. Investing in mutual funds and ETFs carries the risk of capital loss (sometimes up to a 100% loss in the
case of a stock holding bankruptcy). Investments in mutual funds and ETFs are not guaranteed or insured by the
FDIC or any other government agency.
Risks Associated with Investing in Inverse and Leveraged Funds: Leveraged mutual funds and ETFs generally seek
to deliver multiples of the daily performance of the index or benchmark that they track. Inverse mutual funds and
ETFs generally seek to deliver the opposite of the daily performance of the index or benchmark that they track.
Inverse funds often are marketed as a way for investors to profit from, or at least hedge their exposure to,
downward-moving markets. Some Inverse funds are both inverse and leveraged, meaning that they seek a return
that is a multiple of the inverse performance of the underlying index. To accomplish their objectives, leveraged
and inverse funds use a range of investment strategies, including swaps, futures contracts, and other derivative
instruments. Leveraged, inverse, and leveraged inverse funds are more volatile and riskier than traditional funds
due to their exposure to leverage and derivatives, particularly total return swaps and futures. At times, we will
recommend leveraged and/or inversed funds, which may amplify gains and losses.
Most leveraged funds are typically designed to achieve their desired exposure on a daily (in a few cases, monthly)
basis, and reset their leverage daily. A "single day" is measured from the time the leveraged fund calculates its
net asset value ("NAV") to the time of the leveraged fund's next NAV calculation. The return of the leveraged fund
for periods longer than a single day will be the result of each day's returns compounded over the period. Because
of this mathematical compounding, their performance over longer periods of time can differ significantly from
the performance (or inverse performance) of their underlying index or benchmark during the same period of time.
For periods longer than a single day, the leveraged fund will lose money when the level of the Index is flat, and
the leveraged fund may lose money even if the level of the Index rises. Longer holding periods, higher index
volatility, and greater leverage all exacerbate the impact of compounding on an investor's returns. During periods
of higher Index volatility, the volatility of the Index may affect the leveraged fund's return as much as or more
than the return of the Index itself. Therefore, holding leveraged, inverse, and leveraged inverse funds for longer
periods of time increases their risk because of compounding and the inherent difficulty in market timing.
Leveraged funds are riskier than similarly benchmarked funds that do not use leverage. Non-traditional funds are
highly volatile and not suitable for all investors. They provide the potential for significant losses.
Risks Associated with Investing in Buffer ETFs: Buffer ETFs are also known as defined-outcome ETFs since the ETF
is designed to offer downside protection for a specified period of time. These ETFs are modeled after options-
based structured notes, but are generally cheaper, and offer more liquidity. Buffer ETFs are designed to safeguard
against market downturns by employing complex options strategies. Buffer ETFs typically charge higher
management fees that are considerably more than the index funds whose performance they attempt to track.
Additionally, because buffer funds own options, they do not receive dividends from their equity holdings. Both
factors result in the underperformance of the Buffer ETF compared to the index they attempt to track. Clients
should carefully read the prospectus for a buffer ETF to fully understand the cost structures, risks, and features
of these complex products.
Risks Associated with Investing in Inverse and Leveraged Funds: Leveraged mutual funds and ETFs generally seek
to deliver multiples of the daily performance of the index or benchmark that they track. Inverse mutual funds and
ETFs generally seek to deliver the opposite of the daily performance of the index or benchmark that they track.
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Inverse funds often are marketed as a way for investors to profit from, or at least hedge their exposure to,
downward-moving markets. Some Inverse funds are both inverse and leveraged, meaning that they seek a return
that is a multiple of the inverse performance of the underlying index. To accomplish their objectives, leveraged
and inverse funds use a range of investment strategies, including swaps, futures contracts, and other derivative
instruments. Leveraged, inverse, and leveraged inverse funds are more volatile and riskier than traditional funds
due to their exposure to leverage and derivatives, particularly total return swaps and futures. At times, we will
recommend leveraged and/or inversed funds, which may amplify gains and losses.
Most leveraged funds are typically designed to achieve their desired exposure on a daily (in a few cases, monthly)
basis, and reset their leverage daily. A "single day" is measured from the time the leveraged fund calculates its
net asset value ("NAV") to the time of the leveraged fund's next NAV calculation. The return of the leveraged fund
for periods longer than a single day will be the result of each day's returns compounded over the period. Due to
the effect of this mathematical compounding, their performance over longer periods of time can differ
significantly from the performance (or inverse performance) of their underlying index or benchmark during the
same period of time. For periods longer than a single day, the leveraged fund will lose money when the level of
the Index is flat, and the leveraged fund may lose money even if the level of the Index rises. Longer holding
periods, higher index volatility, and greater leverage all exacerbate the impact of compounding on an investor's
returns. During periods of higher Index volatility, the volatility of the Index may affect the leveraged fund's return
as much as or more than the return of the Index itself. Therefore, holding leveraged, inverse, and leveraged
inverse funds for longer periods of time increases their risk due to the effects of compounding and the inherent
difficulty in market timing. Leveraged funds are riskier than similarly benchmarked funds that do not use leverage.
Non-traditional funds are highly volatile and not suitable for all investors. They provide the potential for significant
losses.
Concentrated Position Risk: Certain Associated Persons may recommend that Clients concentrate account assets
in an industry or economic sector. In addition to the potential concentration of accounts in one or more sectors,
certain accounts may, or may be advised to, hold concentrated positions in specific securities. Therefore, at times,
an account may, or may be advised to, hold a relatively small number of securities positions, each representing a
relatively large portion of assets in the account. As a result, the account will be subject to greater volatility than a
more sector diversified portfolio. Investments in issuers within an industry or economic sector that experiences
adverse economic, business, political conditions or other concerns will impact the value of such a portfolio more
than it would if the portfolio’s investments were not so concentrated. A change in the value of a single investment
within the portfolio will affect the overall value of the portfolio and will cause greater losses than it would in a
portfolio that holds more diversified investments.
Risks Associated with Investing in Private Funds: Private investment funds are not registered with the Securities
and Exchange Commission and may not be registered with any other regulatory authority. Accordingly, they are
not subject to certain regulatory restrictions and oversight to which other issuers are subject. There may be little
public information available about their investments and performance. Moreover, as sales of shares of private
investment companies are generally restricted to certain qualified purchasers, it could be difficult for a client to
sell shares of a private investment company at an advantageous price and time. Since shares of private investment
companies are not publicly traded, from time to time it may be difficult to establish a fair value for the client’s
investment in these companies.
Risks Associated with Investing in Alternative Investments: Non-traded REITs, business development companies,
limited partnerships, and direct alternatives are subject to various risks such as liquidity and property devaluation
based on adverse economic and real estate market conditions and are not be suitable for all investors. A
prospectus that discloses all risks, fees, and expenses may be obtained from your advisor. Read the prospectus
carefully before investing. This disclosure is not a solicitation or offering which can only be made in conjunction
with the delivery of a copy of the prospectus. Investors considering an investment strategy utilizing alternative
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investments should understand that alternative investments are generally considered speculative in nature and
involve a high degree of risk, particularly if concentrating investments in one or few alternative investments.
Alternative investments are generally illiquid. Illiquid investments involve the risk that investments may not be
readily sold at the desired time or price. Securities that are illiquid, that are not publicly traded, and/or for which
no market is currently available may be difficult to purchase or sell, which may impact the price or timing of a
transaction. The inability to sell securities can adversely affect an account's value or prevent an account from
taking advantage of other investment opportunities. Lack of liquidity may cause the value of investments to
decline and illiquid investments may also be difficult to value. A client may not be able to liquidate investment in
the event of an emergency or any other reason. In addition, investments in an illiquid asset vehicle will be subject
to the terms and conditions of the illiquid asset vehicle’s investment policy and governing documents that often
include provisions that may involve investor lock-in periods, mandatory capital calls, redemption restrictions,
infrequent valuation of assets, etc. In addition, investments in illiquid securities or vehicle may normally involve
investment in non-marketable securities where there is limited transparency. Investments in illiquid securities or
vehicles may also include restrictions on withdrawal rights and shares may not be freely transferable.
Risks Associated with Investing in Master Limited Partnerships (“MLPs”): Investing in MLPs involve certain risks
related to investing in their underlying assets, as well as the risks associated with pooled investment vehicles
(certain pooled investments may be less regulated than others). In addition, MLPs that concentrate in a particular
industry or a particular geographic region are subject to risks associated with the specific industry or region. A
potential benefit derived from a MLP is also dependent on the holding being treated as a partnership for federal
income tax purposes; if part or all of the MLP is not, it may have potential adverse tax effects on a portfolio.
Risks Associated with Investing in Private Equity: Investments in private equity often involve investment of capital
into or the acquisition of an operating business enterprise; capital frequently coming from institutional investors.
There are a broad range of private equity types and they generally fall into categories such as: (i) leveraged
buyouts, (ii) growth capital, (iii) distressed debt or turnaround strategies, (iv) mezzanine capital, (v) secondaries,
and (vi) venture capital. In general, private equity investing is often offered directly to qualified investors as well
as through fund‐of-funds structures. While such holdings may generate above average returns for an investor,
they typically are less transparent, less liquid, more concentrated, and may involve greater risk, and they typically
have a higher fee structure than traditional investments.
Risks Associated with Investing in Real Estate Investment Trusts: Risks involved in REIT investing may include (i)
following the sale or distribution of assets an investor may receive less than their principal invested, (ii) a lack of
a public market in certain issues, (iii) limited liquidity and transferability, (iv) fluctuations involving the value of
the assets within the REIT, (v) a reliance on the investment manager to select and manage assets, (vi) changes in
interest rates, laws, operating expenses, and insurance costs, (vii) tenant turnover, and (viii) the impact of current
market conditions.
Direct Indexing: Direct indexing strategies seek to replicate the performance of a market index by directly holding
the individual securities, or a representative sample of the individual securities, that make up the index. Direct
indexing can provide a more tax efficient means of investing, and allows for more customized investment
allocations, than investing in a fund or other commingled product that seeks to replicate the index. The potential
benefits of direct indexing, however, will not necessarily be realized if a client does not take advantage of tax
planning or impose account restrictions, such as account level security or sector-based restrictions or
customizations based on specific tax, Environmental, Social, and Governance or other preferences. Fees and
expenses for the direct indexing strategy in some cases will be higher than the fees and expenses associated with
alternative index products. Higher fees and expenses could adversely impact account performance. The size of
the account and the number of securities in the index the account seeks to replicate also limit the ability of the
account to replicate the index. As a result, the direct indexing strategy introduces the risk of tracking error relative
to the index and can cause a portfolio to underperform the index, including as a result of customization.
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Political Risk: Each administration presents its own set of policy risks that could impact investors. One of the policy
tools that an administration can implement is the imposition of tariffs, or the threats thereof. The scope,
implementation, and duration of tariffs can create uncertainty domestically and globally. Industries that rely on
imported raw material or that have heavily integrated cross-border manufacturing practices may be most
impacted by the imposition of tariffs. However, it is challenging to predict the impact of actual and/or threatened
tariffs and impossible to predict future policy decisions. When tariffs are imposed, there is also a higher probability
that retaliatory tariffs could be imposed, which could further impact industries and products. Tariffs in general
can also permanently alter global supply chains and have far-reaching indirect impacts. Tariffs can hurt economic
growth and add to inflation, which can lead to rising interest rates.
Securities Backed Lines of Credit (SBLOCs): SBLOCs are non-purpose loans where you pledge assets in your
account as collateral in return for a loan. The loan proceeds can be used for purposes other than to purchase or
trade securities. Depending on your objectives, we can help you apply for a SBLOC. This can be a strategic
alternative to liquidating assets to pay for unexpected expenses, a business opportunity, or a personal goal, any
of which could trigger capital gain taxes. While we do not receive a fee for arranging these loans, our assistance
in this process presents a conflict of interest, as we have an incentive for you to maintain these assets in your
account instead of liquidating them, as liquidation could decrease the asset-based fees that we earn for managing
your account. To address this conflict, we only make recommendations to obtain such loans when we believe
obtaining a SBLOC is in the best interests of clients. Clients should note that they retain the ultimate decision to
obtain such loans. The following are some of the primary risks associated with obtaining a SBLOC:
Interest rate payments on the principal balance of the loan are not fixed and may increase;
•
•
•
•
If the value of the securities pledged as collateral decrease, you will be liable for any deficiency;
The lender can force the sale or liquidation of securities held as collateral without contacting you in
advance to meet collateral requirements and you are not entitled to choose which securities are
liquidated or sold;
You are only entitled to draw on the line to the extent there is credit availability; and
There may be additional risks when money funds or similar investments may produce less interest
income or other yield than the interest you are paying on the loan.
We urge our clients to carefully read all disclosures and agreements prior to entering into an SBLOC or non-
purpose loan. While we can assist in the application process, we are not involved in the approval process.
Artificial Intelligence ("AI") Risk: We may rely on programs and systems that utilize AI, machine learning,
probabilistic modeling, and other data science technologies ("AI Tools") when delivering our services. AI Tools are
also used to record and transcribe client meetings. Clients should note that AI Tools are highly complex, and are
known to have been flawed, hallucinate, reflect biases included in the data on which such tools are trained, be of
poor quality, or be otherwise harmful. AI Tools present Cybersecurity Risk. The U.S. and global legal and regulatory
environment relating to the use of AI Tools is uncertain and rapidly evolving, and could require changes in the
firm’s implementation of AI Tools and increase compliance costs and the risk of non-compliance. Further, the firm
may rely on AI Tools developed by third parties, and the firm has limited control over the accuracy and
completeness of such AI Tools. Clients who do not want us to record their meetings have the option to opt out at
the time of the meeting.
Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase morbidity and mortality over a
wide geographic area, crossing international boundaries, and causing significant economic, social, and political
disruption. It is difficult to predict the long-term impact of such events because they are dependent on a variety
of factors including the global response of regulators and governments to address and mitigate the worldwide
effects of such events. Workforce reductions, travel restrictions, governmental responses and policies and
macroeconomic factors will negatively impact investment returns.
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Recommendation of Other Advisers: In the event we recommend a third-party investment adviser to manage all
or a portion of your assets, we will advise you on how to allocate your assets among various classes of securities
or third-party investment managers, programs, or managed model portfolios. As such, we will primarily rely on
investment model portfolios and strategies developed by the third-party investment advisers and their portfolio
managers. If there is a significant deviation in characteristics or performance from the stated strategy and/or
benchmark, we may recommend changing models or replacing a third-party investment adviser. The primary risks
associated with investing with a third party is that while a particular third party may have demonstrated a certain
level of success in the past; it may not be able to replicate that success in future markets. In addition, as we do
not control the underlying investments in third party model portfolios, there is also a risk that a third party may
deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for
our clients. To mitigate this risk, we seek third parties with proven track records that have demonstrated a
consistent level of performance and success over time. A third party’s past performance is not a guarantee of
future results and certain market and economic risks exist that may adversely affect an account’s performance
that could result in capital losses in your account. Please refer to the third-party investment adviser’s advisory
agreements, Form ADV Brochure, and associated disclosure documents for details on their specific investment
strategies, methods of analysis, and associated risks.
Cryptocurrency Risk: Cryptocurrency (e.g., bitcoin and ether), often referred to as “virtual currency”, “digital
currency,” or “digital assets,” is designed to act as a medium of exchange. Cryptocurrency is an emerging asset
class. There are thousands of cryptocurrencies, the most well-known of which is Bitcoin. Certain of the firm’s
clients may have exposure to bitcoin or another cryptocurrency, directly or indirectly through an investment such
as an ETF or other investment vehicles. Cryptocurrency operates without central authority or banks and is not
backed by any government. Cryptocurrencies may experience very high volatility and related investment vehicles
may be affected by such volatility. As a result of holding cryptocurrency, certain of the firm’s clients may also
trade at a significant premium or discount to NAV. Cryptocurrency is also not legal tender. Federal, state, or
foreign governments may restrict the use and exchange of cryptocurrency, and regulation in the U.S. is still
developing. The market price of many cryptocurrencies, including bitcoin, has been subject to extreme
fluctuations. If cryptocurrency markets continue to be subject to sharp fluctuations, investors may experience
losses if the value of the client’s investments declines. Similar to fiat currencies (i.e., a currency that is backed by
a central bank or a national, supra-national, or quasi-national organization), cryptocurrencies are susceptible to
theft, loss, and destruction. Cryptocurrency exchanges and other trading venues on which cryptocurrencies trade
are relatively new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure
than established, regulated exchanges for securities, derivatives, and other currencies. The SEC has issued a public
report stating U.S. federal securities laws require treating some digital assets as securities.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical glitches,
hackers, or malware. Due to relatively recent launches, most cryptocurrencies have a limited trading history,
making it difficult for investors to evaluate investments. Generally, cryptocurrency transactions are irreversible
such that an improper transfer can only be undone by the receiver of the cryptocurrency agreeing to return the
cryptocurrency to the original sender. Digital assets are highly dependent on their developers and there is no
guarantee that development will continue or that developers will not abandon a project with little or no notice.
Third parties may assert intellectual property claims relating to the holding and transfer of digital assets, including
cryptocurrencies, and their source code. Any threatened action that reduces confidence in a network’s long-term
ability to hold and transfer cryptocurrency may affect investments in cryptocurrencies.
Many significant aspects of the U.S. federal income tax treatment of investments in cryptocurrency are uncertain
and an investment in cryptocurrency may produce income that is not treated as qualifying income for purposes
of the income test applicable to regulated investment companies. Certain cryptocurrency investments may be
treated as a grantor trust for U.S. federal income tax purposes, and an investment by the firm’s clients in such a
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vehicle will generally be treated as a direct investment in cryptocurrency for tax purposes and “flow-through” to
the underlying investors.
Cybersecurity Risks: Our firm and our service providers are subject to risks associated with a breach in
cybersecurity. Cybersecurity is a generic term used to describe the technology, processes, and practices designed
to protect networks, systems, computers, programs, and data from cyber-attacks and hacking by other computer
users, and to avoid the resulting damage and disruption of hardware and software systems, loss or corruption of
data, and/or misappropriation of confidential information. In general, cyber-attacks are deliberate; however,
unintentional events may have similar effects. Cyber-attacks may cause losses to clients by interfering with the
processing of transactions, affecting the ability to calculate net asset value or impeding or sabotaging trading.
Clients may also incur substantial costs as the result of a cybersecurity breach, including those associated with
forensic analysis of the origin and scope of the breach, increased and upgraded cybersecurity, identity theft,
unauthorized use of proprietary information, litigation, and the dissemination of confidential and proprietary
information. Any such breach could expose our firm to civil liability as well as regulatory inquiry and/or action. In
addition, clients could be exposed to additional losses as a result of unauthorized use of their personal
information. While our firm has established business continuity plans, incident response plans and systems
designed to prevent cyber-attacks, there are inherent limitations in such plans and systems, including the
possibility that certain risks have not been identified. Similar types of cyber security risks also are present for
issuers of securities in which we invest, which could result in material adverse consequences for such issuers and
may cause a client's investment in such securities to lose value.
Disciplinary Information - Item 9
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events
that would be material to your evaluation of us or the integrity of our management. There is no history of
reportable material legal or disciplinary events by our firm or our management persons.
Other Financial Industry Activities or Affiliations - Item 10
Neither Millennial Wealth nor any of our Associated Persons are registered as, or have pending applications to
register as, a broker/dealer, Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading
Advisor or are currently an associated person of any the foregoing types of entities.
Millennial Wealth does not provide legal or accounting related services, but with a client’s prior written consent
we will work with the client’s attorney or accountant to assist with the coordination and implementation of
accepted strategies. Clients should note that these other professionals will charge separately for their services
and these fees will be in addition to our own advisory fees.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11
Description of Our Code of Ethics
Millennial Wealth has adopted a Code of Ethics (the “Code”) to address investment advisory conduct. The Code
focuses primarily on fiduciary duty, personal securities transactions, insider trading, gifts, and conflicts of interest.
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The Code includes Millennial Wealth’s policies and procedures developed to protect clients’ interests in relation
to the following topics:
▪
▪
▪
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The duty at all times to place the interests of clients first;
The requirement that all personal securities transactions be conducted in such a manner as to be
consistent with the code of ethics;
The responsibility to avoid any actual or potential conflict of interest or misuse of an employee’s
position of trust and responsibility;
The fiduciary principle that information concerning the identity of security holdings and financial
circumstances of clients is confidential; and
The principle that independence in the investment decision-making process is paramount.
A copy of Millennial Wealth’s Code of Ethics is available upon request to Charles L. Heekin II, Chief Compliance
Officer, at (312) 637-1850 or at cheekin@millennialwa.com.
Personal Trading Practices
At times, Millennial Wealth and/or its Advisory Representatives may take positions in the same securities as
clients. This is considered a conflict of interest with clients. Millennial Wealth and its Advisory Representatives
will generally be “last in” and “last out” for the trading day when trading occurs in close proximity to client trades,
however, we will uphold our fiduciary responsibilities to our clients. Accounts owned by our firm or persons
associated with our firm may participate in block trading with your accounts; however, they will not be given
preferential treatment. Front running (trading shortly ahead of clients) is prohibited. Should a conflict occur
because of materiality (e.g., a thinly traded stock), disclosure will be made to the client(s) at the time of trading.
Incidental trading not deemed to be a conflict (i.e. a purchase or sale which is minimal in relation to the total
outstanding value, and as such would have negligible effect on the market price), would not be disclosed at the
time of trading. Mutual fund purchases are not subject to these policies because the transactions are executed at
NAV at the end of the trading day.
Brokerage Practices - Item 12
Millennial Wealth has an institutional brokerage and custodial relationship with Charles Schwab & Co., Inc.
(Schwab), a FINRA-registered broker-dealer, member SIPC. Schwab Advisor Services (formerly called Schwab
Institutional) is Schwab’s business serving independent investment advisory firms like us. We are independently
owned and operated and not affiliated with Schwab. Schwab will hold your assets in a brokerage account and will
buy and sell securities in your account(s) upon our instructions. While we recommend that you use Schwab as
custodian/broker, you will decide whether to do so and you will open your account with Schwab by entering into
an account agreement directly with them. We do not open the account for you.
Your Custody and Brokerage Costs
Schwab generally does not charge you separately for custody services, but is compensated by charging
commissions or other fees on trades that it executes or that settle into your Schwab account. In addition to
commissions, Schwab charges a flat dollar amount as a “prime broker” or “trade away” fee for each trade that
we have executed by a different broker-dealer but where the securities bought or the funds from the securities
sold are deposited (settled) into your Schwab account.
Research and Other Soft Dollar Benefits
Although not considered “soft dollar” compensation, Millennial Wealth may receive some economic benefits
from Schwab Advisor Services in the form of access to its institutional brokerage, trading, custody, reporting and
related services, many of which are not typically available to Schwab retail customers. Schwab also makes
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available various support services. Some of those services help us manage or administer our clients’ accounts
while others help us manage and grow our business. Schwab’s support services are generally available on an
unsolicited basis (we don’t have to request them) and at no charge to us as long as we keep a total of at least $10
million of our clients’ assets in accounts at Schwab. If we have less than $10 million in client assets at Schwab,
Schwab may charge us quarterly service fees. Below is a detailed description of Schwab’s support services.
Services that Benefit You: Schwab’s institutional brokerage services include access to a broad range of investment
products, execution of securities transactions, and custody of client assets. The investment products available
through Schwab include some to which we might not otherwise have access or that would require a significantly
higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit
you and your account.
Services that May Not Directly Benefit You: Schwab 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. They include investment research, both Schwab’s own and that of third
parties. We may use this research to service all or some substantial number of our clients’ accounts, including
accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software
and other technology that:
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•
•
•
•
provide access to client account data (such as duplicate trade confirmations and account statements);
facilitate trade execution and allocate aggregated trade orders for multiple client accounts;
provide pricing and other market data;
facilitate payment of our fees from our clients’ accounts; and
assist with back-office functions, recordkeeping, and client reporting.
•
•
•
•
Services that Generally Benefit Only Us: Schwab also offers other services intended to help us manage and further
develop our business enterprise. These services include:
educational conferences and events;
technology, compliance, legal, and business consulting;
publications and conferences on practice management and business succession; and
access to employee benefits providers, human capital consultants, and insurance providers.
Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide
the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a
third party’s fees. Schwab may also provide us with other benefits such as occasional business entertainment of
our personnel.
Brokerage for client Referrals
We do not receive client referrals from broker-dealers and custodians with which we have an institutional
advisory arrangement. Also, we do not receive other benefits from a broker-dealer in exchange for client referrals.
Directed Brokerage
In very limited circumstances, and at our sole discretion, some clients may instruct our firm to use one or more
particular brokers for the transactions in their accounts. In the event that a client directs Millennial Wealth to use
a particular broker/dealer, the firm may not be authorized to negotiate commissions and may not be able to
obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission
charges may exist between the commissions charged to clients who direct the firm to use a particular
broker/dealer and those that do not.
Trade Aggregation/Block Trading
We combine multiple orders for shares of the same securities purchased for advisory accounts we manage on a
discretionary basis whenever possible and where in the clients’ best interests (this practice is commonly referred
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to as “block trading”). We will then distribute a portion of the shares to participating accounts in a fair and
equitable manner. The distribution of the shares purchased is typically proportionate to the size of the account,
but it is not based on account performance or the amount or structure of management fees. In rare instances,
such as partial fills or limited shares of thinly traded or illiquid stocks, it may be necessary to place block trades
for only small groups of clients over a period of time. Subject to our discretion regarding factual and market
conditions, when we combine orders, each participating account pays an average price per share for all
transactions and pays a proportionate share of all transaction costs. Accounts owned by our firm or persons
associated with our firm may participate in block trading with your accounts; however, they will not be given
preferential treatment.
Review of Accounts - Item 13
Accounts are reviewed by the Associated Person named as adviser of record on the account. The frequency of
reviews is determined based on the client’s investment objectives, but reviews are conducted no less frequently
than annually. Additional reviews are usually triggered by a change in the client’s investment objectives, tax
considerations, large deposits or withdrawals, large purchases or sales, loss of confidence in corporate
management, or changes in macro-economic climate.
The client’s independent custodian provides account statements directly to the client no less frequently than
quarterly. Sub-advisers will also provide clients with performance reports on at least a quarterly basis. Millennial
Wealth also provides consolidated performance reports on a quarterly basis. Millennial Wealth’s reports will
provide information about positions invested in Alternatives custodied outside of Schwab.
The custodian’s statement is the official record of the client’s securities account and supersedes any statements
or reports created on behalf of the client by Millennial Wealth.
Client Referrals and Other Compensation - Item 14
Economic Benefit Provided by Third Parties for Advice Rendered to Client.
Please refer to Item 12, where we discuss recommendation of Broker-Dealers.
Compensation for Client Referrals
We do not compensate unaffiliated third parties for client referrals.
Custody - Item 15
We do not have physical custody of any client funds and/or securities. However, where clients grant us written
authorization to deduct advisory fees from their account(s), we are deemed to have custody over client funds or
securities limited to the deduction of advisory fees.
With respect to third party standing letters of authorization (“SLOA”) where a client grants us authority to direct
custodians to disburse funds to one or more third party accounts, we are deemed to have custody pursuant to
Rule 206(4)-2 (the “Custody Rule”). We have taken steps to have controls and oversight in place to comply with
the no-action letter issued by the SEC on February 21, 2017 (the “SEC no-action letter”). We are not required to
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comply with the surprise examination requirements of the Custody Rule if we comply with the representations
noted in the SEC no-action letter. Where our firm acts pursuant to a SLOA, we believe we are making a good faith
effort to comply with the representations noted in the SEC no-action letter. Additionally, since many of the
representations noted in the SEC no-action letter involve the qualified custodian’s operations, we will collaborate
closely with our custodian(s) to ensure that the representations are met.
Your funds and securities will be held with a bank, broker-dealer, or other independent, qualified custodian. You
will receive account statements from the independent, qualified custodian(s) holding your funds and securities at
least quarterly. The account statements from your custodian(s) will indicate the amount of our advisory fees
deducted from your account. You should carefully review account statements for accuracy. If you have questions
regarding your account or if you did not receive a statement from your custodian, please contact us at (312) 637-
1850 or at cheekin@millennialwa.com.
Investment Discretion - Item 16
Millennial Wealth takes on limited discretionary authority when providing you with portfolio management
services. The Associated Person assigned to your account will contact you to discuss recommendations for
changes within your account and no changes will be made to the allocation of your account without prior
consultation with you. We will periodically, without your prior consent, rebalance your account in accordance
with your previously stipulated goals, objectives, or needs to maintain the initial agreed upon asset allocation.
We require client approval prior to the implementation of a new asset allocation. You may further limit our
discretionary authority by setting a limit on the type of securities that can be purchased for your account. Simply
provide us with your restrictions or guidelines in writing.
Please refer to the “Advisory Business” section in this Brochure for more information on our discretionary
management services.
Voting Client Securities - Item 17
Millennial Wealth does not vote proxies. It is the client's responsibility to vote proxies. Clients will receive proxy
materials directly from the custodian. Questions about proxies may be made via the contact information on the
cover page.
Financial Information - Item 18
We are required in this Item to provide you with certain financial information or disclosures about Millennial
Wealth’s, financial condition. Millennial Wealth does not require the prepayment of over $1,200, six or more
months in advance. Additionally, Millennial Wealth has no financial commitment that impairs its ability to meet
contractual and fiduciary commitments to clients, and Millennial Wealth has not been the subject of a bankruptcy
proceeding.
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Requirements of State-Registered Advisers - Item 19
This section is not applicable because our firm is SEC-registered.
Millennial Wealth Advisors, LLC Privacy Policy Notice
This notice is being provided to you in accordance with the Securities and Exchange Commission’s rule regarding
the privacy of consumer financial information (“Regulation S-P”). Please take the time to read and understand
the privacy policies and procedures that we have implemented to safeguard your nonpublic personal information.
INFORMATION WE COLLECT
Millennial Wealth Advisors, LLC (Millennial Wealth) must collect certain personally identifiable financial
information about its customers to provide financial services and products. The personally identifiable financial
information that we gather during the normal course of doing business with you may include:
•
•
•
information we receive from you on applications or other forms;
information about your transactions with us, our affiliates, or others;
information we receive from a consumer reporting agency.
INFORMATION WE DISCLOSE
We do not disclose any nonpublic personal information about our customers or former customers to anyone,
except as permitted or required by law, as necessary to provide services to you or if you have given us permission
in writing. In accordance with Section 248.13 of Regulation S-P, we may disclose all of the information we collect,
as described above, to certain nonaffiliated third parties such as our attorneys, accountants, auditors and persons
or entities that are assessing our compliance with industry standards. We enter into contractual agreements with
all nonaffiliated third parties that prohibit such third parties from disclosing or using the information other than
to carry out the purposes for which we disclose the information.
REGULATION S-AM: Under Regulation S-AM, we are prohibited from using eligibility information that we receive
from an affiliate to make a marketing solicitation unless:
1.
2.
3.
the potential marketing use of that information has been clearly, conspicuously and concisely disclosed
to the consumer;
the consumer has been provided a reasonable opportunity and a simple method to opt out of receiving
the marketing solicitations; and
the consumer has not opted out.
Millennial Wealth does not share eligibility information obtained from clients with third parties to make marketing
solicitations.
REGULATION S-ID: Regulation S-ID requires our firm to have an Identity Theft Protection Program (ITPP) that
controls reasonably foreseeable risks to customers or to the safety and soundness of our firm from identity theft.
We have developed an ITPP to adequately identify and detect potential red-flags to prevent and mitigate identity
theft.
CONFIDENTIALITY AND SECURITY
We restrict access to nonpublic personal information about you to those Employees who need to know that
information to provide financial products or services to you. We maintain physical, electronic, and procedural
safeguards that comply with federal standards to guard your nonpublic personal information.
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ACCURACY
Millennial Wealth strives to always maintain accurate personal information in our client files. However, as
personal situations, facts and data change over time; we encourage our clients to provide feedback and updated
information to help us meet our goals.
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Page 22
Form ADV Part 2B
Brochure Supplement
April 16, 2026
Millennial Wealth Advisors, LLC
Registered Investment Advisor
Primary Office:
906 Bond Way
Delray Beach, FL 33483
Branch Office:
231 South LaSalle Street
Suite 2100
Chicago, IL 60604
(312) 637-1850
www.millennialwealthadvisors.com
This brochure provides information about Charles L. Heekin that supplements the Millennial Wealth
Advisors Form ADV Part 2A firm brochure. You should have received a copy of that brochure. Please
contact Mr. Heekin at (312)-637-1850 if you did not receive the full brochure or if you have any questions
about the contents of this supplement. Additional information about Charles L. Heekin is available on the
Securities and Exchange Commission’s (SEC) website at www.adviserinfo.sec.gov.
Item 1 – Cover Page
Millennial Wealth Advisors, LLC
Form ADV Part 2A Brochure
Page 23
Charles L. Heekin II
(CRD # 1737715)
Managing Partner
President
Chief Compliance Officer
Investment Advisor Representative
Item 2 – Educational Background and Business Experience
Mr. Heekin was born in 1966.
Educational Background and Business Experience
Mr. Heekin earned a Bachelors of Arts and Sciences in Philosophy degree from Boston College; Chestnut
Hill, MA.
Business Experience
(11/2014‐Present):Mr. Heekin
is
the
Millennial Wealth Advisors, LLC, Chicago,
firm’s
IL
President/Managing Member, Chief Compliance Officer, and an Investment Advisor Representative
(01/2015‐Present).
Item 3 – Disciplinary Information
Registered investment advisors are required to disclose certain material facts about its associated
personnel regarding any legal or disciplinary events, including criminal or civil action in a domestic, foreign
or military court, or any proceeding before a state, federal or foreign regulatory agency, self‐regulatory
organization, or suspension or sanction by a professional association for violation of its conduct rules, that
would be material to your evaluation of each officer or a supervised person providing investment advice.
Mr. Heekin has not been the subject of any such event.
Millennial Wealth Advisors, LLC
Form ADV Part 2A Brochure
Page 24
Item 4 – Other Business Activities
Investment advisor representatives are required to disclose outside business activities that account for a
significant portion of their time or income, or that may present a conflict of interest with their advisory
activities.
Mr. Charles L. Heekin II maintains a minority ownership interest in Blue Marlin Partners Midwest, LLC
through Heekin LLC. Blue Marlin Partners Midwest, LLC serves as general partner to several Blue Marlin
Vehicles. Mr. Charles L. Heekin II has an incentive to recommend investments in Blue Marlin Vehicles, as
the general partner shares in the receipt of performance-based fees collected from investors.
Item 5 – Additional Compensation
Neither our firm nor Mr. Heekin receives compensation for advisory services involving performance‐based
fees. In addition, firm policy does not allow associated persons to accept or receive additional economic
benefit, such as sales awards or other prizes, for providing advisory services to firm clients.
Item 6 – Supervision
Mr. Heekin serves as our firm’s Chief Compliance Officer. Because supervising one’s self poses a conflict
of interest, the firm has adopted policies and procedures to mitigate this conflict, and may use the services
of unaffiliated professionals to ensure the firm’s oversight obligations are met.
Questions relative to the firm, its services or this Form ADV Part 2B may be made to the attention of
Mr. Heekin at (312) 637-1850. Additional information about the firm, other advisory firms, or an
associated investment advisor representative is available on the Internet at www.adviserinfo.sec.gov. A
search of this site for firms may be accomplished by firm name or a unique firm identifier, known as an
IARD or CRD number. The CRD number for Millennial Wealth Advisors is 174201.
Item 7 ‐ Requirements for State‐Registered Advisers
There have been no arbitration awards or sanctions or other matter where Mr. Heekin or Millennial
Wealth Advisors has been found liable in a self‐regulatory or administrative proceeding. Neither Mr.
Heekin nor Millennial Wealth Advisors has been the subject of a bankruptcy petition.
Millennial Wealth Advisors, LLC
Form ADV Part 2A Brochure
Page 25
Form ADV Part 2B
Brochure Supplement
April 16, 2026
Millennial Wealth Advisors, LLC
Registered Investment Advisor
Primary Office:
906 Bond Way
Delray Beach, FL 33483
Branch Office:
231 South LaSalle Street
Suite 2100
Chicago, IL 60604
(312) 637-1850
www.millennialwealthadvisors.com
This brochure provides information about Mario Tate that supplements the Millennial Wealth Advisors
Form ADV Part 2A firm brochure. You should have received a copy of that brochure. Please contact Mr.
Heekin at ((312)-637-1850 if you did not receive the full brochure or if you have any questions about the
contents of this supplement.
Item 1 – Cover Page
Millennial Wealth Advisors, LLC
Form ADV Part 2A Brochure
Page 26
Mario Leo Tate
(CRD # 4562061)
Investment Advisor Representative
Investment Analyst
Item 2 – Educational Background and Business Experience
Mr. Tate was born in 1980.
Educational Background and Business Experience
Mr. Tate attended the following post-secondary institutions: Babson College.
Business Experience
Millennial Wealth Advisors, LLC, Chicago, IL (2/2018 ‐ Present): Mr. Tate is an investment analyst at the
firm and is an Investment Advisor Representative.
Past business experience includes:
• NEPC, LLC, Chicago, IL – Mr. Tate was a senior research analyst from 03/2011 to 03/2016
• NEPC, LLC, Boston, MA – Mr. Tate was a senior analyst from 09/2006 to 03/2011
• Columbia Management Group, Boston, MA – Mr. Tate was a dealer file representative from
07/2002 to 04/2005
Item 3 – Disciplinary Information
Mr. Tate has not been the subject of any event that this section requires to be reported.
Item 4 – Other Business Activities
Mr. Tate does not have a material relationship with the issuer of a security. He is not registered, nor has
an application pending to register, as a registered representative of a broker/dealer or associated person
of a futures commission merchant, commodity pool operator, or commodity trading advisor. He does not
receive commissions, bonuses, or other compensation based on the sale of securities, including that as a
Millennial Wealth Advisors, LLC
Form ADV Part 2A Brochure
Page 27
registered representative of a broker/dealer or the distribution of service (“trail”) fees from the sale of
mutual funds.
Item 5 – Additional Compensation
Neither our firm nor Mr. Tate receives compensation for advisory services involving performance-based
fees. In addition, firm policy does not allow associated persons to accept or receive additional economic
benefit, such as sales awards or other prizes, for providing advisory services to firm clients.
Item 6 – Supervision
Mr. Heekin serves as the firm’s Chief Compliance Officer; he will supervise Mr. Tate’s advisory activities
and Mr. Tate’s proprietary trading.
Mr. Heekin is available at (312) 637-1850. Additional information about the firm, other advisory firms, or
an associated investment advisor representative is available on the Internet at www.adviserinfo.sec.gov.
A search of this site for firms may be accomplished by firm name or a unique firm identifier, known as an
IARD or CRD number. The CRD number for Millennial Wealth Advisors is 174201.
Item 7 ‐ Requirements for State‐Registered Advisers
There have been no arbitration awards or sanctions or other matters where Mr. Tate or Millennial Wealth
Advisors has been found liable in a self-regulatory or administrative proceeding. Neither Mr. Tate nor
Millennial Wealth Advisors has been the subject of a bankruptcy petition.