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MJT & Associates Financial Advisory Group, Inc.
Form ADV Part 2A – Disclosure Brochure
Effective: February 26, 2026
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of MJT & Associates Financial Advisory Group, Inc., formerly MJT & Associates, LLC (“MJT” or the
“Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at
(320) 269-7889 or by email at mitch@mjtassociates.com.
MJT is a registered investment advisor located with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities
authority. Registration of an investment advisor does not imply any specific level of skill or training. This
Disclosure Brochure provides information about MJT to assist you in determining whether to retain the Advisor.
Additional information about MJT and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 297716.
MJT & Associates Financial Advisory Group, Inc.
1315 Grove Ave, Suite 5, Montevideo, MN 56265 Phone: (320) 269-7889
www.mjtassociates.com
MJT & Associates Financial Advisory Group, Inc.
1315 Grove Ave, Suite 5, Montevideo, MN 56265Phone: (320) 269-7889
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http://www.mjtassociates.com
Item 2 – Material Changes
MJT believes that communication and transparency are the foundation of its relationship with clients and will
continually strive to provide you with complete and accurate information at all times. MJT encourages all current
and prospective clients to read this Disclosure Brochure and discuss any questions you may have with us.
Material Changes
The following material changes has been made to this Disclosure Brochure since the last annual amendment
filing on 01/30/2025:
Item 1: We have updated our principal office address.
Item 5: We have updated our fees for financial planning and portfolio management services.
●
●
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in our business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete
Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material
change occurs.
You may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 297716. You may also
request a copy of this Disclosure Brochure at any time by contacting the Advisor at (320) 269-7889 or by email at
mitch@mjtassociates.com.
MJT & Associates Financial Advisory Group, Inc.
1315 Grove Ave, Suite 5, Montevideo, MN 56265Phone: (320) 269-7889
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http://www.mjtassociates.com
Item 3 – Table of Contents
Item 1 – Cover Page………..……………………………………………………………………………………………….1
Item 2 – Material Changes ................................................................................................................................ 2
Item 3 – Table of Contents ............................................................................................................................... 3
Item 4 – Advisory Services............................................................................................................................... 4
Item 5 – Fees and Compensation..................................................................................................................... 6
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 ...................................................... 10
Item 9 – Disciplinary Information ................................................................................................................... 12
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 ....................................................................................................................... 13
Item 13 – Review of Accounts ........................................................................................................................ 14
Item 14 – Client Referrals and Other Compensation ..................................................................................... 14
Item 15 – Custody ........................................................................................................................................... 15
Item 16 – Investment Discretion .................................................................................................................... 16
Item 17 – Voting Client Securities .................................................................................................................. 16
Item 18 – Financial Information ...................................................................................................................... 16
MJT & Associates Financial Advisory Group, Inc.
1315 Grove Ave, Suite 5, Montevideo, MN 56265Phone: (320) 269-7889
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http://www.mjtassociates.com
Item 4 – Advisory Services
A. Firm Information
MJT & Associates Financial Advisory Group, Inc. formerly MJT & Associates, LLC (“MJT” or the “Advisor”) is a
registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is
organized as a Corporation under the laws of Minnesota. MJT was founded in October 2014, and is owned and
operated by Mitchell J. Thompson (President and Chief Compliance Officer. This Disclosure Brochure provides
information regarding the qualifications, business practices, and the advisory services provided by MJT.
B. Advisory Services Offered
MJT offers investment advisory services to individuals, high net worth individuals, trusts and retirement plans
(each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. MJT’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more
information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
Wealth Management Services
MJT may provide Clients with wealth management services, which generally includes discretionary management
of investment portfolios in connection with a broad range of comprehensive financial planning services.
Investment Management Services - MJT provides customized investment advisory solutions for its Clients. This
is achieved through continuous personal Client contact and interaction while providing discretionary investment
management and related advisory services. MJT works closely with each Client to identify their investment goals
and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. MJT will then
construct an investment portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds
(“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds or
options contracts to meet the needs of its Clients. The Advisor may retain certain legacy investments based on
portfolio fit and/or tax considerations.
MJT’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions
that have been held for less than one year to meet the objectives of the Client or due to market conditions. MJT
will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and
risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on
the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
MJT evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. MJT may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. MJT may recommend specific positions to increase sector or asset class weightings. The Advisor may
recommend employing cash positions as a possible hedge against market movement. MJT may recommend
selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or
sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s]
in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed
unacceptable for the Client’s risk tolerance.
At no time will MJT accept or maintain custody of a Client’s funds or securities, except for the limited authority as
outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the
Custodian, pursuant to the terms of the advisory agreement, please see Item 12 – Brokerage Practices.
Use of Independent Managers - MJT will recommend that Clients utilize one or more unaffiliated investment
managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s
investment portfolio, based on the Client’s needs and objectives. In certain instances, the Client may be required
to authorize and enter into an investment management agreement with the Independent Manager[s] that defines
MJT & Associates Financial Advisory Group, Inc.
1315 Grove Ave, Suite 5, Montevideo, MN 56265Phone: (320) 269-7889
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http://www.mjtassociates.com
the terms in which the Independent Manager[s] will provide its services. The Advisor will perform initial and
ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned
with Clients investment objectives and overall best interests. The Advisor will also assist the Client in the
development of the initial policy recommendations and managing the ongoing Client relationship. The Client,
prior to entering into an agreement with an Independent Manager, will be provided with the Independent
Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures).
Financial Planning Services – As part of the wealth management services, MJT will typically provide a variety of
financial planning and consulting services to Clients. MJT also makes available to Clients financial planning and
consulting services as a stand-alone service pursuant to a written financial planning agreement. Services are
offered in several areas of a Client’s financial situation, depending on their goal and objectives.
Generally, such financial planning services involve preparing a formal financial plan or rendering a specific
financial consultation based on the Client’s financial goals and objectives. This planning or consulting may
encompass one or more areas of need, including but not limited to, investment planning, retirement planning,
personal savings, education savings, insurance needs and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
MJT may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s
financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may
not provide a written summary. Plans or consultations are typically completed within six (6) months of contract
date, assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor
for investment management services or to increase the level of investment assets with the Advisor would pose a
conflict, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to
implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If
the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to
implement the transaction through the Advisor.
Retirement Plan Advisory Services
MJT provides 3(21) retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the
company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan
Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized
to the needs of the Plan and Plan Sponsor. Services generally include:
Identifying investment objectives and restrictions
●
● Providing guidance on various asset classes and investment options
● Recommending money managers to manage plan assets in ways designed to achieve objectives
● Monitoring performance of money managers and investment options and making recommendations for
changes
● Recommending other service providers, such as custodians, administrators and broker-dealers
● Creating a written pension consulting plan
● Vendor Analysis
● Plan Participant Enrollment and Education Tracking
These services are provided by MJT serving in the capacity as a fiduciary under the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan
MJT & Associates Financial Advisory Group, Inc.
1315 Grove Ave, Suite 5, Montevideo, MN 56265Phone: (320) 269-7889
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Sponsor is provided with a written description of MJT’s fiduciary status, the specific services to be rendered and
all direct and indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging MJT to provide investment advisory services, each Client is required to enter into one or more
agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and
the Client. These services may include:
● Establishing an Investment Strategy – MJT, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s goals and objectives.
● Asset Allocation – MJT will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
● Portfolio Construction – MJT will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
●
Investment Management and Supervision – MJT will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
MJT does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by MJT.
E. Assets Under Management
As of December 31, 2025, MJT manages $198,946,748in Client assets, $188,970,162of which are managed on
a discretionary basis and $9,976,586on a non-discretionary basis. Clients may request more current information
at any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written
agreement with the Advisor.
A. Fees for Advisory Services
Wealth Management and Investment Management Services
Wealth Management and investment management fees (“advisory fee[s]”) are paid quarterly, in advance of each
calendar quarter, pursuant to the terms of the investment advisory agreement. Advisory fees are based on the
market value of assets under management at the end of the prior calendar quarter. Advisory fees are based on
the following tiered schedule:
Assets Under Management ($)
The First $250,000
The Next $750,000
The Next $1,000,000
The Next $3,000,000
The Next $5,000,000
Over $10,000,000
Annual Rate (%)
1.40%
1.00%
0.85%
0.70%
0.40%
0.25%
Quarterly Rate (%)
0.35%
0.25%
0.2125%
0.175%
0.10%
0.625%
The advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of
the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into
consideration the aggregate assets under management with the Advisor. All securities held in accounts managed
MJT & Associates Financial Advisory Group, Inc.
1315 Grove Ave, Suite 5, Montevideo, MN 56265Phone: (320) 269-7889
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http://www.mjtassociates.com
by MJT will be independently valued by the Custodian. MJT will conduct periodic reviews of the Custodian’s
valuations.
This is a blended fee schedule. As an example, a portfolio with a $1,500,000 account balance would be charged
an overall rate of 1.04%. The first $250,000 would be billed at the rate of 1.40%, the next $750,000 is billed at a
rate of 1.00%, and the next $500,000 would be billed at 0.85%. Also, all accounts within the same household are
aggregated and applied together to reduce the overall fee. MJTa may negotiate other fee arrangements
depending on the size of the account, type of account, services required, etc. The specific annual fee being
charged to the client will be set forth and identified in an agreement between MJTa and that client.
Use of Independent Managers
As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio utilizing one or
more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation
from an Independent Manager. The Advisor will only earn its investment advisory fee as described above. The
Advisor will allocate a portion of the advisory fee collected to the Independent Manager pursuant to the terms of
the executed agreement between the Advisor and the Independent Manager. The total blended fee, including the
Advisor’s fee and the Independent Manager’s fee, will not exceed 2.00% annually.
Retirement Plan Advisory Services
Fees for retirement plan advisory services are charged an annual asset-based fee of up to 0.65% and are billed
in advance of each quarter, pursuant to the terms of the retirement plan advisory agreement. Retirement plan
fees are based on the market value of assets under management at the end of the prior calendar quarter. Fees
may be negotiable depending on the size and complexity of the Plan.
Annual Rate (%)
0.65%
0.45%
0.40%
0.35%
0.30%
Quarterly Rate (%)
0.1625%
0.1125%
0.10%
0.0875%
0.075%
0.25%
0.0625%
Assets Under Management
The First $1,000,000
The Next $1,000,001 - $2,500,000
The Next $2,500,001 - $5,000,000
The Next $5,000,000 - $7,500,000
The Next $7,500,001 - $10,000,000
The Next $10,000,001 -
$15,000,000
Over $15,000,000
0.20%
0.05%
The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and
other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However,
the Advisor shall not receive any portion of these commissions, fees, and costs.
Financial Planning Services
MJT offers financial planning services either on an hourly basis (up to $500 per hour) or a fixed engagement fee.
MJT offers the following tiers for their Financial Planning Services:
DISCOVERY Meeting | $500
45-minute virtual call or office meeting designed to review financial data and overall health, answer 3-5 questions
and concerns, and give generic deliverables on changes that can impact their future. Appropriate topics for
discussion include 401(k) investment choices, college savings strategies, and basic retirement forecasting. No
formal plan is to be completed.
CORE Plan | $2,400
A financial planning engagement intended for those in the beginning stages looking at when and how to start
planning for items such as retirement, education, and home purchases. Includes written recommendations,
retirement and cash flow projections, current portfolio review, and education planning.
MJT & Associates Financial Advisory Group, Inc.
1315 Grove Ave, Suite 5, Montevideo, MN 56265Phone: (320) 269-7889
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COMPREHENSIVE PLAN | $3,500
A detailed financial planning engagement intended for those taking a serious look at when they might retire and
are concerned about their portfolio. Includes written recommendations, retirement and cash flow projections,
Social Security maximization analysis, current portfolio review, asset allocation plan, and proposed portfolio.
Basic review of estate planning and life, disability, and long-term care insurance needs.
COMPLEX PLAN | $4,000
Comprehensive plus: Options/RSUs analysis, Retirement Distribution Strategies
Roth Conversion Analysis, Detailed Estate Planning, including Charitable Giving, Business Entity Selection and
Business Succession analysis
B. Fee Billing
Wealth Management and Investment Management Services
Wealth management and investment management service fees (“advisory fee[s]”) are calculated by the Advisor
or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send a notice of
fees to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the
beginning of the respective quarter. The amount due is calculated by applying the quarterly rate (annual rate
divided by 4) to the total assets under management with MJT at the end of the prior quarter. Clients will be
provided with a statement, at least quarterly, from the Custodian reflecting deduction of the advisory fee. It is the
responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement
as the Custodian does not assume this responsibility. Clients provide written authorization permitting advisory
fees to be deducted by MJT to be paid directly from their account[s] held by the Custodian as part of the
investment advisory agreement and separate account forms provided by the Custodian.
Use of Independent Managers
For Client accounts implemented through an Independent Manager, the Advisor and the Independent Manager
will each assume the responsibility for calculating and deducting their respective fees from the Client’s
account[s].
Retirement Plan Advisory Services
Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the
Plan, depending on the terms of the retirement plan advisory agreement.
Financial Planning Services
Financial planning Clients will be invoiced the total planning fee upon execution of the financial planning
agreement.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than MJT, in connection with
investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities
execution fees charged by the Custodian. The Advisor’s recommended Custodian does not charge securities
transaction fees for ETF and equity trades in Client accounts, but typically charges for mutual funds and other
types of investments. The fees charged by MJT are separate and distinct from these custody and execution fees.
In addition, all fees paid to MJT for investment advisory services are separate and distinct from the expenses
charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described
in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the
funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a
possible distribution fee. A Client may be able to invest in these products directly, without the services of MJT,
but would not receive the services provided by MJT which are designed, among other things, to assist the Client
in determining which products or services are most appropriate for each Client’s financial situation and
objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by
MJT & Associates Financial Advisory Group, Inc.
1315 Grove Ave, Suite 5, Montevideo, MN 56265Phone: (320) 269-7889
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MJT to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional
information.
D. Advance Payment of Fees and Termination
Wealth Management and Investment Management Services
MJT may be compensated for its services in advance of the quarter in which wealth management or investment
management services are rendered. Either party may terminate the Advisor’s agreement, at any time, by
providing advance written notice to the other party. The Client may also terminate the Advisor’s agreement within
five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the
Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be
due and payable by the Client. The Advisor will refund any unearned, prepaid investment advisory fees from the
effective date of termination to the end of the quarter. The Client’s advisory agreement with the Advisor is non-
transferable without the Client’s prior consent.
Use of Independent Managers
In the event that the Advisor has determined that an Independent Manager is no longer in the Client’s best
interest, the Advisor will have the discretion to terminate the relationship with the Independent Manager. The
terms for termination are set forth in the respective agreements between the Advisor and the Independent
Managers.
Retirement Plan Advisory Services
MJT is compensated for its services at the beginning of the quarter before advisory services are rendered. Either
party may request to terminate a retirement plan advisory agreement, at any time, by providing advance written
notice to the other party. Upon termination, the Client shall be responsible for investment advisory fees up to and
including the effective date of termination and the Advisor will refund any unearned, prepaid investment advisory
fees from the effective date of termination to the end of the quarter. The Client’s retirement plan advisory
agreement with the Advisor is non-transferable without the Client’s prior consent.
Financial Planning Services
MJT requires advance deposit as described above. Either party may terminate the financial planning agreement
by providing advance written notice to the other party. The Client may also terminate the financial planning
agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-
day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and
such fees will be due and payable by the Client. The Advisor will refund any unearned, prepaid planning fees
from the effective date of termination. The Client’s financial planning agreement with the Advisor is non-
transferable without the Client’s prior consent.
E. Compensation for Sales of Securities
Mitchell Thompson is also licensed as an independent insurance professional. As an independent insurance
professional, Mr. Thompson services and supports a legacy booking business while also providing analysis and
evaluation of all types of insurance to Clients. Mr. Thompson does not actively solicit, sell, or receive commission
from any new clients. This presents a conflict of interest in recommending certain products of the insurance
companies. Clients are under no obligation, contractually or otherwise, to purchase insurance products through
Mr. Thompson.
Item 6 – Performance-Based Fees and Side-By-Side Management
MJT does not charge performance-based fees for its investment advisory services. The fees charged by MJT are
as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by
any Client.
MJT does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a
hedge fund) and has no financial incentive to recommend any particular investment options to its Clients.
Item 7 – Types of Clients
MJT & Associates Financial Advisory Group, Inc.
1315 Grove Ave, Suite 5, Montevideo, MN 56265Phone: (320) 269-7889
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http://www.mjtassociates.com
MJT offers investment advisory services to individuals, high net worth individuals, trusts and retirement plans.
The amount of each type of Client is available on MJT’s Form ADV Part 1A. These amounts may change over
time and are updated at least annually by the Advisor. MJT generally does not impose a minimum relationship
size.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
MJT primarily employs Modern Portfolio Theory and technical analysis methods in developing investment
strategies for its Clients. Research and analysis from MJT are derived from numerous sources, including
financial media companies, third-party research materials, Internet sources, and review of company activities,
including annual reports, prospectuses, press releases and research prepared by others.
Modern Portfolio Theory is a theory of investment that attempts to maximize portfolio expected return for a given
amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully
choosing the proportions of various asset classes.
Technical analysis involves the analysis of past market data rather than specific company data in determining the
recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns
and trends, which may be based on investor sentiment rather than the fundamentals of the company. The
primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the
future. Even if the trend will eventually reoccur, there is no guarantee that MJT will be able to accurately predict
such a reoccurrence.
As noted above, MJT generally employs a long-term investment strategy for its Clients, as consistent with their
financial goals. MJT will typically hold all or a portion of a security for more than a year, but may hold for shorter
periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, MJT may also
buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the
fundamentals of the security, sector or asset class.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. MJT will assist Clients in determining an appropriate
strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a
Client will meet their investment goals.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that
the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis
may lose value and may have negative investment performance. The Advisor monitors these economic
indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s
review process are included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the
Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals
or other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client
accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio
construction process. Following are some of the risks associated with the Advisor’s investment approach:
MJT & Associates Financial Advisory Group, Inc.
1315 Grove Ave, Suite 5, Montevideo, MN 56265Phone: (320) 269-7889
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Modern Portfolio Theory
Modern Portfolio Theory assumes that investors are risk averse, meaning that given two portfolios that offer the
same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if
compensated by higher expected returns. Conversely, an investor who wants higher expected returns must
accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the
trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will
not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for
that level of risk an alternative portfolio exists which has better expected returns.
Technical analysis
Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is
that the market follows discernible patterns and if these patterns can be identified then a prediction can be made.
The risk is that markets do not always follow patterns and relying solely on this method may not take into account
new patterns that emerge over time.
Long term trading
Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term
investment strategy can expose clients to various types of risk that will typically surface at various intervals
during the time the client owns the investments. These risks include but are not limited to inflation (purchasing
power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk.
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs
will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading
risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large
bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and
may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF
purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a
short time later.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of
the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a
mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the
same price as a mutual fund purchased later that same day.
Equity Investment
Equity investments generally refers to buying shares of stocks in return for receiving a future payment of dividends
and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to
specific situations for each company, industry conditions and the general economic environments.
Fixed income
Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can
vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield,
and investment grade debt and structured products, such as mortgage and other asset-backed securities, although
individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile
and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa.
This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk,
liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury
inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely);
MJT & Associates Financial Advisory Group, Inc.
1315 Grove Ave, Suite 5, Montevideo, MN 56265Phone: (320) 269-7889
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however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign
fixed income securities also include the general risk of non-U.S. investing described below.
Real Estate Investment Trusts (“REITs”)
Investing in Real Estate Investment Trusts (“REITs”) involves certain distinct risks in addition to those risks
associated with investing in the real estate industry in general. For Example, equity REITs may be affected by
changes in the value of the underlying property owned by the REITs, while mortgage REITs may be affected by
the quality of credit extended. REITs are subject to heavy cash flow dependency, default by borrowers and self-
liquidation. REITs, especially mortgage REITs, are also subject to interest rate risk (i.e., as interest rates rise, the
value of the REIT may decline).
Past performance is not a guarantee of future returns. Investing in securities and other investments
involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to
discuss these risks with the Advisor.
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving MJT or its owner. MJT values the trust you
place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or
service provider that the Client engages. The backgrounds of the Advisor and Advisory Persons are available on
the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s
firm name or CRD# 297716.
Item 10 – Other Financial Industry Activities and Affiliations
CDFA Bridge Consulting Group LLC
Mitchell Thompson provides consulting focused on assisting married couples with the financial aspects of
divorce. This service is not offered to Clients of MJT. Mr. Thompson spends 10% of his time involved during
trading hours.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
MJT has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each
Client. This Code applies to all persons associated with MJT (“Supervised Persons”). The Code was developed
to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the Client. MJT
and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation
of MJT’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general
principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of
interest. To request a copy of the Code, please contact the Advisor at (320) 269-7889 or via email at
mitch@mjtassociates.com.
B. Personal Trading with Material Interest
MJT allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. MJT does not act as principal in any transactions. In addition, the Advisor does
not act as the general partner of a fund, or advise an investment company. MJT does not have a material interest
in any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
MJT allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients
presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and
procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public
information controls); gifts and entertainment; outside business activities and personal securities reporting. When
MJT & Associates Financial Advisory Group, Inc.
1315 Grove Ave, Suite 5, Montevideo, MN 56265Phone: (320) 269-7889
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trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities.
The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more
advantageous terms than Client trades, or by trading based on material non-public information. This risk is
mitigated by MJT requiring reporting of personal securities trades by its Supervised Persons for review by the
Chief Compliance Officer (“CCO”). The Advisor has also adopted written policies and procedures to detect the
misuse of material, non-public information.
D. Personal Trading at Same Time as Client
While MJT allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At
no time will MJT, or any Supervised Person of MJT, transact in any security to the detriment of any
Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
MJT does not have discretionary authority to select the broker-dealer/custodian for custody and execution
services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets
and authorize MJT to direct trades to the Custodian as agreed upon in the investment advisory agreement.
Further, MJT does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-
by-trade basis.
Where MJT does not exercise discretion over the selection of the Custodian, it may recommend the Custodian[s]
to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by
the Advisor and will not incur any extra fee or cost associated with using a custodian not recommended by MJT.
However, the Advisor may be limited in the services it can provide if the recommended Custodian is not
engaged. MJT may recommend the Custodian based on criteria such as, but not limited to, reasonableness of
commissions charged to the Client, services made available to the Client, and its reputation and/or the location of
the Custodian’s offices.
MJT will generally recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”) or
Altruist, FINRA-registered broker-dealers and members SIPC. Schwab/Altruist will serve as the Client’s “qualified
custodian”. MJT maintains an institutional relationship with Schwab/Altruist, whereby the Advisor receives
economic benefits from Schwab/Altruist (Please see Item 14 below.)
Following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor
enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and
other services. MJT does not participate in soft dollar programs sponsored or offered by any broker-
dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please
see Item 14 below.
2. Brokerage Referrals - MJT does not receive any compensation from any third party in connection with the
recommendation for establishing an account.
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where MJT will place trades
within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are
traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of
any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase
of a security into one Client account from another Client’s account[s]). MJT will not be obligated to select
competitive bids on securities transactions and does not have an obligation to seek the lowest available
transaction costs. These costs are determined by the Custodian.
MJT & Associates Financial Advisory Group, Inc.
1315 Grove Ave, Suite 5, Montevideo, MN 56265Phone: (320) 269-7889
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B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of
execution, 4) confidentiality and 5) skill required of the Custodian. MJT will execute its transactions through the
Custodian as authorized by the Client. MJT may aggregate orders in a block trade or trades when securities are
purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block
trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close
of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other
written statement. This must be done in a way that does not consistently advantage or disadvantage any
particular Clients’ accounts.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Mitchell Thompson, Chief
Compliance Officer of MJT. Formal reviews are generally conducted at least annually or more frequently
depending on the needs of the Client.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least
annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a
result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large
deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify MJT if changes occur in the
Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews
may be triggered by material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage
statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to
the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage
statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may
also provide Clients with periodic reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by MJT
Participation in Institutional Advisor Platform
MJT has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a
division of Schwab dedicated to serving independent advisory firms like MJT. As a registered investment advisor
participating on the Schwab Advisor Services platform, MJT receives access to software and related support
without cost because the Advisor renders investment management services to Clients that maintain assets at
Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services
provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to
put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a
custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this
custodian over one that does not furnish similar software, systems support, or services.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of Client’s funds and securities. Through
Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be
able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds
MJT & Associates Financial Advisory Group, Inc.
1315 Grove Ave, Suite 5, Montevideo, MN 56265Phone: (320) 269-7889
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and other investments without having to adhere to investment minimums that might be required if the Client were
to directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to
technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for
Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its
relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for
its Clients, but may not directly benefit all Clients.
Services that May Only Benefit the Advisor – Schwab also offers other services to MJT that may not benefit the
Client, including: educational conferences and events, financial start-up support, consulting services and
discounts for various service providers. Access to these services creates a financial incentive for the Advisor to
recommend Schwab, which results in a conflict of interest. MJT believes, however, that the selection of Schwab
as Custodian is in the best interests of its Clients.
B. Compensation for Client Referrals
MJT may receive client referrals from Wealthramp. Wealthramp is independent of and unaffiliated with MJT and
there is no employee relationship between them. Wealthramp provides leads to MJT through their Wealthramp
website. Wealthramp does not supervise MJT and has no responsibility for MJT’s management of client
portfolios or MJT’s other advice or services. MJT pays Wealthramp a fee for each new lead as a Solicitation Fee.
MJT will not charge clients referred through Wealthramp any fees or costs higher than its standard fee schedule
offered to its clients.
Item 15 – Custody
MJT does not accept or maintain custody of any Client accounts, except for the authorized deduction of the
Advisor’s fees. All Clients must place their assets with a “qualified custodian”. Clients are required to engage the
Custodian to retain their funds and securities and direct MJT to utilize that Custodian for the Client’s security
transactions. Clients should review statements provided by the Custodian and compare to any reports provided
by MJT to ensure accuracy, as the Custodian does not perform this review. For more information about
custodians and brokerage practices, see Item 12 – Brokerage Practices.
If the Client gives the Advisor authority to move money from one account to another account, the Advisor may
have custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor
have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s
instructions.
In addition, certain clients have established asset transfer authorizations that permit the qualified custodian to
rely upon instructions from the Firm to transfer client funds or securities to third parties. These arrangements are
disclosed at Item 9 of Part 1 of Form ADV. However, in accordance with the guidance provided in the SEC’s
February 21, 2017 Investment Adviser Association No-Action Letter, the affected accounts are not subject to an
annual surprise CPA examination. The letter provided guidance on the Custody Rule as well as clarified that an
adviser who has the power to disburse client funds to a third party under a standing letter of authorization
(“SLOA”) is deemed to have custody. As such, our firm has adopted the following safeguards in conjunction with
our custodians:
• The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature,
the third party’s name, and either the third party’s address or the third party’s account number at a
custodian to which the transfer should be directed.
• The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or
separately, to direct transfers to the third party either on a specified schedule or from time to time.
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• The client’s qualified custodian performs appropriate verification of the instruction, such as a signature
review or other method to verify the client’s authorization, and provides a transfer of funds notice to the
client promptly after each transfer.
• The client has the ability to terminate or change the instruction to the client’s qualified custodian.
• The investment adviser has no authority or ability to designate or change the identity of the third party,
the address, or any other information about the third party contained in the client’s instruction.
• The investment adviser maintains records showing that the third party is not a related party of the
investment adviser or located at the same address as the investment adviser.
• The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and
an annual notice reconfirming the instruction.
Item 16 – Investment Discretion
MJT generally has discretion over the selection and amount of securities to be bought or sold in Client accounts
without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to
specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by MJT.
Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will
be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations
to such authority. All discretionary trades made by MJT will be in accordance with each Client's investment
objectives and goals.
Item 17 – Voting Client Securities
MJT does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from
the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the
sole responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither MJT, nor its management, have any adverse financial situations that would reasonably impair the ability
of MJT to meet all obligations to its Clients. Neither MJT, nor any of its Advisory Persons, have been subject to a
bankruptcy or financial compromise. MJT is not required to deliver a balance sheet along with this Disclosure
Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six
months or more in the future.
MJT & Associates Financial Advisory Group, Inc.
1315 Grove Ave, Suite 5, Montevideo, MN 56265Phone: (320) 269-7889
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