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Item 1: Cover Sheet
M OR G AN - A L Y
WEALTH MANAGEMENT GROUP LLC
CRD # 328483
N4W22370 Bluemound Rd., Ste 204
Waukesha, WI 53186-1683
262.691.0100 Jim Hayett, CCO
FORM ADV PART 2A
V. April 2, 2026
This brochure provides information about the qualifications and business practices of Morgan-Aly Wealth
Management LLC. If you have any questions about the contents of this brochure, please contact us at 262.691.0100 or
via email at info@morgan-aly.com. The information in this brochure has not been approved or verified by the United
States Securities and Exchange Commission or by any state securities authority.
Morgan-Aly Wealth Management is a registered investment adviser. Our registration does not imply a certain level of
skill or training. Additional information about Morgan-Aly Wealth Management is also available on the SEC’s website
at www.adviserinfo.sec.gov.
Item 2:
Statement of Material Changes
Investment advisers are required to report material changes to the Form ADV Part 2A in this Item 2. As of March
2026, Morgan-Aly Wealth Management LLC has switched from state to U.S. Securities and Exchange Commission
(“SEC”) registration.
Item 3: Table of Contents
Item 1: Cover Sheet
1
Item 2: Statement of Material Changes
2
Item 3: Table of Contents
3
Item 4: Advisory Business
4
Item 5: Fees and Compensation
4
Item 6: Performance-based fees
6
Item 7: Types Of Clients
6
Item 8: Methods of Analysis, Investment Strategies and Risk Of Loss
6
Item 9: Disciplinary Information
8
Item 10: Other Financial Industry Activities and Affiliations
8
Item 11: Code of Ethics, Participation and Interest in Client Transactions and Personal Trading
9
Item 12: Brokerage practices
9
Item 13: Review of Accounts
11
Item 14: Client Referrals and Other Compensation
11
Item 15: Custody
12
Item 16: Investment Discretion
12
Item 17: Voting Client Securities
12
Item 18: Financial Information
12
Item 4: Advisory Business
Morgan-Aly Wealth Management, LLC (“MAWM”) is a registered investment adviser based in Wisconsin. Jim Hayett
and Jason Behr are the owners of the firm. MAWM has been in business as an investment adviser in Wisconsin since
December of 2023.
A. Asset Management Services
MAWM provides asset management services. Our approach is based on model investment strategies to tailor asset
portfolios that align with our clients’ retirement and financial goals. When we meet a new client, we develop a
personalized investment policy statement (new account forms). The statement outlines their risk tolerance and
investment objectives. We achieve this through personal conversations and data collection. During this process, we
capture vital information such as the client’s time horizons, risk tolerance, liquidity requirements as well as their prior
investment history. Our next step is to match them with the appropriate asset allocation.
All of our accounts will be managed on a “discretionary” basis. This means when a client engages us, we will monitor
their accounts to ensure that they align with their financial objectives and asset allocation. If adjustments are necessary
to their investments, we will implement them. These modifications may entail the sale of a security or group of
investments and the purchase of others. While MAWM presently tends to suggest investments through a
combination of stocks and bond's along with in very limited cases insurance annuities, MAWM may at any moment
recommend any type of asset that its advisors deem in the best interest of that particular client. Clients may provide
MAWM with restrictions in the management of accounts. However, in the event MAWM believes those restrictions
to be unreasonable, or that such restrictions are likely to compromise account performance or MAWM’s ability to
manage the accounts, MAWM reserves the right to refuse such restrictions.
MAWM provides a broad range of services to employers sponsoring self-directed retirement plans. Most frequently,
MAWM works with these highly specific clients to select and monitor the investment alternatives (generally open-
end mutual funds) from which plan participants shall choose in self-directing the investments for their individual
plan retirement accounts. In addition, MAWM also will consult with management regarding plan structure, develop
an investment policy statement, assist with employee education and communication, and periodically review costs
and fees.
MAWM does not offer a wrap fee program.
As of January 27, 2026, MAWM had $105,268,201 in 390 client accounts. All assets are managed on a discretionary
basis.
Item 5: Fees and Compensation
A. Fees Charged
All asset management clients will be required to execute an Investment Management Agreement that will describe
the type of management services to be provided and the fees, among other items. Clients are advised that they may
pay fees that are higher or lower than fees they may pay a different advisor for the same services and may in fact pay
lower fees for comparable services from other sources. At no time are clients required to engage or continue to
engage MAWM for asset management services.
Fees are negotiable and may be higher or lower than this range, based on the nature of the account. MAWM’s
standard advisory fee is based on a percentage of the assets under management and ranges from 1.00- 1.25% based
on the following fee schedule as follows:
Fee Schedule
Total Value
Up to $499,999
Next $500,000 - $999,999
Next $1,000,000 - $1,999,999
Over 2,000,000
Annual Fee
1.25%
1.15%
1.00%
Negotiable
B. Fee Payment
Asset management fees will be debited directly from each client’s account. The fee is paid quarterly, in advance, and
the value used for the fee calculation is the gross market value as of the last market day of the previous quarter. In
calculating the market value of a client’s assets, assets allocated to cash or a cash proxy, such as a money market
account, will be included in the calculation of assets under management. Once the calculation is made, we will instruct
your account custodian to deduct the fee from your account and remit it to MAWM’s.
Clients will provide written authorization to debit advisory fees from their accounts held by a qualified custodian
chosen by the client. The client will receive a statement from their account custodian showing all transactions in their
account, including the fee.
Fee Billing Example
To calculate advanced billing assumes a 360 day year and quarters lasting 90 days. Calculations are as follows: [Quarter
End Value x Advisory Account Fee] / 360 x 90 Days = Advance Billing [$300,000 x 1.25%] / 360 x 90 = $937.5
Quarterly Billing Adjustment Quarterly billing adjustments account for any deposits or withdrawals made during the
quarter. These adjustments ensure the client is only being charged for assets which have resided in their account over
time. In this example, the account had a $100,000 deposit on October 15th, $50,000 withdrawal on November 20th
and a $25,000 deposit on December 25th. To calculate the billing adjustments the number of days each deposit and
withdrawal was in the account must be determined.
The number of days for each deposit and withdrawal in this example are as follows; first deposit: 78 days, second
deposit 7 days, and the withdrawal 42 days. Calculations are as follows: [Deposit or Withdrawal x Advisory Account
Fee] / 360 x Prorated Days = Billing Adjustment 10/15 Deposit: [$100,000 x 1.25%] / 360 x 78 = $270.83 11/20
Withdrawal: [– $50,000 x 1.25%] / 360 x 42 = – $72.91 12/25 Deposit: [$25,000 x 1.25%] / 360 x 7 = $6.07 Total
Billing Adjustments = $270.83 – $72.91 + $6.07 = $203.99 Total Subsequent Billing Advanced Billing + Total Billing
Adjustments = Total Subsequent Billing $937.50 + $203.99= $1,141.49.
C. Other Fees
There are a number of other fees that can be associated with holding and investing in securities. You will be
responsible for fees including transaction fees for the purchase or sale of a mutual fund or Exchange Traded Fund,
or commissions for the purchase or sale of a stock. Expenses of a fund will not be included in management fees, as
they are deducted from the value of the shares by the Exchange Traded Fund or mutual fund manager. For complete
discussion of expenses related to each mutual fund, you should read a copy of the prospectus issued by that fund.
MAWM can provide or direct you to a copy of the prospectus for any fund that we recommend to you.
Please make sure to read Item 12 of this informational brochure, where we discuss broker-dealer and custodial issues.
D. Pro-rata Fees
If you become a client during a quarter, you will pay a management fee for the number of days left in that quarter.
If you terminate our relationship during a quarter, you will be entitled to a refund of any management fees for the
remainder of the quarter. Once your notice of termination is received, we will assess pro-rated fees for the number
of days between the end of the prior billing period and the date of termination to be paid in whatever way you direct
(check, wire).
E. Compensation for the Sale of Securities.
Professionals of MAWM’s do not receive commissions for the sales of securities or other investment products.
Item 6: Performance-based fees
MAWM will not charge performance- based fees.
Item 7: Types of Clients
We provide services to individuals and in very limited cases, small corporations. When clients seek to engage us for
asset management, we generally require a minimum account value of $250,000. This minimum may be waived at the
discretion of the adviser. In some cases, MAWM may accept smaller accounts of family members of current clients,
in which case the minimum is $50,000.
Item 8: Methods of Analysis, Investment Strategies and Risk of
Loss
It is important for you to know and remember that all investments carry risks. Investing in securities involves risk
of loss that clients should be prepared to bear.
Methods of Analysis and Investment Strategies
MAWM’s method of analysis is based on the Intrinsic Value Formula (IV) with a certain amount of stocks that may
not have an IV (higher risk growth stocks and ETF’s). Intrinsic value is the estimated worth of an asset based on its
fundamentals and internal data. There is more than one way to determine Intrinsic value. MAWM has developed a
proprietary method of calculating IV. With this method, we carefully assess and select individual stocks for our stock
model. MAWM places clients into an asset allocation strategy that divides the portfolio into the stocks model and/or
with bonds based on the risk level. Clients with a higher risk tolerance may be 100% stock invested, and clients with
a lesser risk tolerance may be invested in a blend of assets. The methodology remains unchanged, but the allocation is
tailored to the client. MAWM may employ the use of ETF funds for clients with lower amounts of asset levels.
Material Risks Involved
It is important for clients to know and remember that all investments carry risks. Investing in securities involves
risk and may result in a loss of clients’ original investment which clients should be prepared to bear.
Political Risks. Most investments have a global component, even domestic stocks. Political events anywhere in the
world may have unforeseen consequences to markets around the world.
General Market Risks. Markets can, as a whole, go up or down on various news releases or for no understandable
reason at all. This sometimes means that the price of specific securities could go up or down without real reason and
may take some time to recover any lost value. Adding additional securities does not help to minimize this risk since
all securities may be affected by market fluctuations.
Currency Risk. When investing in another country using another currency, the changes in the value of the currency
can change the value of your security value in your portfolio.
Regulatory Risk. Changes in laws and regulations from any government can change the value of a given company
and its accompanying securities. Certain industries are more susceptible to government regulation. Changes in
zoning, tax structure or laws impact the return on these investments.
Tax Risks Related to Short Term Trading. Clients should note that MAWM may engage in short-term trading
transactions. These transactions may result in short term gains or losses for federal and state tax purposes, which
may be taxed at a higher rate than long term strategies. MAWM endeavors to invest client assets in a tax efficient
manner, but all clients are advised to consult with their tax professionals regarding the transactions in client accounts.
Purchasing Power Risk. Purchasing power risk is the risk that your investment’s value will decline as the price of
goods rises (inflation). The investment’s value itself does not decline, but its relative value does, which is the same
thing. Inflation can happen for a variety of complex reasons, including a growing economy and a rising money supply.
Business Risk. This can be thought of as certainty or uncertainty of income. Management comes under business
risk. Cyclical companies (like automobile companies) have more business risk because of the less steady income
stream. On the other hand, fast food chains tend to have steadier income streams and therefore, less business risk.
Financial Risk. The amount of debt or leverage determines the financial risk of a company.
Default Risk. This risk pertains to the ability of a company to service their debt. Ratings provided by several rating
services help to identify those companies with more risk. Obligations of the U.S. government are said to be free of
default risk.
Strategy Risk. The Adviser’s investment strategies and/or investment techniques may not work as intended.
Small and Medium Cap Company Risk. Securities of companies with small and medium market capitalizations
are often more volatile and less liquid than investments in larger companies. Small and medium-cap companies may
face a greater risk of business failure, which could increase the volatility of the client’s portfolio.
Limited Markets. Certain securities may be less liquid (harder to sell or buy) and their prices may at times be more
volatile than at other times. Under certain market conditions, we may be unable to sell or liquidate investments at
prices we consider reasonable or favorable or find buyers at any price.
Concentration Risk. Certain investment strategies focus on particular asset classes, industries, sectors, or types of
investment. From time to time these strategies may be subject to greater risks of adverse developments in such areas
of focus than a strategy that is more broadly diversified across a wider variety of investments.
Interest Rate Risk. Bond (fixed income) prices generally fall when interest rates rise, and the value may fall below
par value or the principal investment. The opposite is also generally true: bond prices generally rise when interest
rates fall. In general, fixed-income securities with longer maturities are more sensitive to these price changes. Most
other investments are also sensitive to the level and direction of interest rates.
Legal or Legislative Risk. Legislative changes or Court rulings may impact the value of investments or the
securities’ claim on the issuer’s assets and finances.
Inflation. Inflation may erode the buying power of your investment portfolio, even if the dollar value of your
investments remains the same.
Risks Related to Investment Term & Liquidity. Securities do not follow a straight line up in value. All securities
will have periods of time when the current price of the security is not an accurate measure of its value. If you require
us to liquidate your portfolio during one of these periods, you will not realize as much value as you would have had
the investment had the opportunity to regain its value. Further, some investments are made with the intention of the
investment appreciating over an extended period of time. Liquidating these investments prior to their intended time
horizon may result in losses.
Funds Available Risk. Clients who have check-writing authority for their accounts are responsible for losses related
to trades not occurring due to a lack of cash within their account.
Excess Cash Balance Risk. Client accounts may have cash balances in excess of $250,000, which is the insurance
limit of the Federal Deposit Insurance Corporation. For cash balances in excess of that amount, there is an enhanced
risk that operation-related counterparty risk related to the account custodian could cause losses in the account. We
mitigate this risk by carrying cash balances in amounts either subject to protection or as limited as you, the client,
directs. You may elect to participate in a “cash sweep” program through your account custodian which automatically
moves excess cash from your investment account into a cash account and then invests that cash into cash-based
investments, such as money market funds. We do not receive compensation of any kind for facilitating your
participation in such cash sweep accounts.
Transition risk. As assets are transitioned from a client’s prior advisers to MAWM there may be securities and other
investments that do not fit within the asset allocation strategy selected for the client. Accordingly, these investments
will need to be sold in order to reposition the portfolio into the asset allocation strategy selected by MAWM.
However, this transition process may take some time to accomplish. Some investments may not be unwound for a
lengthy period of time for a variety of reasons that may include unwarranted low share prices,
restrictions on trading, contractual restrictions on liquidity, or market-related liquidity concerns. In some cases, there
may be securities or investments that are never able to be sold. The inability to transition a client's holdings into
recommendations of MAWM may adversely affect the client's account values, as MAWM’s recommendations may
not be able to be fully implemented.
Information Risk. All investment professionals rely on research in order to make conclusions about investment
options. This research is always a mix of both internal (proprietary) and external (provided by third parties) data and
analyses. Even an adviser who says they rely solely on proprietary research must still collect data from third parties.
This data, or outside research, is chosen for its perceived reliability, but there is no guarantee that the data or research
will be completely accurate. Failure in data accuracy or research will translate to a compromised ability by the adviser
to reach satisfactory investment conclusions.
Risks Associated with Specific Types of Investments
Exchange Traded Funds. Prices may vary significantly from the Net Asset Value due to market conditions. Certain
Exchange Traded Funds may not track underlying benchmarks as expected. ETFs are also subject to the following
risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii) the ETF may
employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if
the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the
activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading
generally. The Adviser has no control over the risks taken by the underlying funds in which the clients invest.
Item 9: Disciplinary Information
Neither the firm nor any of its employees or principals has any disciplinary information to report.
Item 10: Other Financial Industry Activities and Affiliations
A. Broker-dealer
Neither principals of MAWM, nor any related persons are registered with a Broker-dealer.
B. Futures Commission Merchant/Commodity Trading Advisor
Neither principals of MAWM, nor any related persons are registered, or have an application pending to register,
as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated
person of the foregoing entities.
C. Relationship with Related Persons
Certain professionals of MAWM are separately licensed as independent insurance agents for purposes of
servicing existing clients that have insurance products. As such, these professionals may conduct insurance
product transactions for MAWM clients in their capacity as licensed insurance agents and will receive customary
commissions for these transactions in addition to any compensation received from advisory services.
Commissions from the sale of insurance products will not be used to offset or as a credit against advisory fees.
These certain professionals therefore have an incentive to recommend insurance products based on the
compensation to be received. The receipt of additional fees for insurance commissions is therefore a conflict of
interest, and clients should be aware of this conflict when considering whether to engage MAWM to
implement any insurance recommendations. MAWM attempts to mitigate this conflict of interest by disclosing
the conflict to clients and informing the clients that they are always free to purchase insurance products through
other agents that are not affiliated with MAWM, or to determine not to purchase the insurance product at all.
MAWM also attempts to mitigate the conflict of interest by requiring employees to acknowledge in the firm’s
Code of Ethics, their individual fiduciary duty to the clients of MAWM, which requires that employees put the
interests of clients ahead of their own.
D. Recommendations of other Advisers
MAWM does not utilize nor select other advisers or third-party managers at this time.
Item 11: Code of Ethics, Participation and Interest in Client
Transactions and Personal Trading
A. Code of Ethics
A copy of our Code of Ethics is available upon request. Our Code of Ethics includes discussions of our fiduciary
duty to clients, political contributions, gifts, entertainment, and trading guidelines.
B. Recommendations Involving Material Financial Interests
Not applicable. MAWM does not recommend to clients that they invest in any security in which MAWM, or any
principal thereof, has any financial interest.
C. Investing Personal Money in the Same Securities as Clients
On occasion, an employee of MAWM may purchase for his or her own account securities which are also
recommended for clients. Our Code of Ethics details rules for employees regarding personal trading and avoiding
conflicts of interest related to trading in one’s own account. To avoid placing a trade before a client (in the case of a
purchase) or after a client (in the case of a sale), all employee trades must be reviewed by the Compliance Officer.
All employee trades must either take place in the same block as a client trade or sufficiently apart in time from the
client trade, so the employee receives no added benefit. Employee statements are reviewed to confirm compliance
with the trading procedures.
D. Trading Securities At/Around the Same Time as Clients’ Securities
On occasion, an employee of MAWM may purchase for his or her own account securities which are also
recommended for clients at the same time the clients purchase the securities. Our Code of Ethics details rules for
employees regarding personal trading and avoiding conflicts of interest related to trading in one’s own account. To
avoid placing a trade before a client (in the case of a purchase) or after a client (in the case of a sale), all employee
trades must be reviewed by the Compliance Officer. All employee trades must either take place in the same block as
a client trade or sufficiently apart in time from the client trade, so the employee receives no added benefit. Employee
statements are reviewed to confirm compliance with the trading procedures.
Item 12: Brokerage practices
MAWM requires that clients establish a brokerage account with LPL Financial to maintain custody of clients’ assets
and to effect trades for their accounts. LPL Financial provides brokerage and custodial services to independent
investment advisory firms, including MAWM. For MAWM’s accounts custodied at LPL Financial, LPL Financial
generally is compensated by clients through commissions, trails, or other transaction-based fees for trades that are
executed through LPL Financial or that settle into LPL Financial accounts. For IRA accounts, LPL Financial
generally charges account maintenance fees. In addition, LPL Financial also charges clients miscellaneous fees and
charges, such as account transfer fees. LPL Financial charges MAWM an asset-based administration fee for
administrative services provided by LPL Financial. Such administration fees are not directly borne by clients but may
be taken into account when MAWM negotiates its advisory fee with clients.
Clients should also be aware that for accounts where LPL Financial serves as the custodian, MAWM is limited to
offering services and investment vehicles that are approved by LPL Financial and may be prohibited from offering
services and investment vehicles that may be available through other broker-dealers and custodians, some of which
may be more suitable for a client’s portfolio than the services and investment vehicles offered through LPL Financial.
Clients should understand that not all investment advisers require that clients custody their accounts and trade
through specific broker-dealers.
Best Execution
MAWM seeks to recommend a custodian/broker that will hold client assets and execute transactions on terms that
are, overall, most beneficial when compared with other available providers and their services. MAWM considers a
wide range of factors, including both quantitative (Ex: costs) and qualitative (execution, reputation).
Benefits Received by MAWM Personnel
MAWM receives support services and/or products from LPL Financial, many of which assist MAWM to better
monitor and service program accounts maintained at LPL Financial; however, some of the services and products
benefit MAWM and not client accounts. LPL Financial may provide these services and products directly or may
arrange for third party vendors to provide the services or products to MAWM. In the case of third-party vendors,
LPL Financial may pay for some or all of the third party’s fees.
These support services are provided to MAWM based on the overall relationship between MAWM and LPL
Financial. It is not the result of soft dollar arrangements or any other express arrangements with LPL Financial that
involve the execution of client transactions as a condition of the receipt of services. MAWM will continue to receive
the services regardless of the volume of client transactions executed with LPL Financial. Clients do not pay more
for services as a result of this arrangement. There is no corresponding commitment made by MAWM to LPL or any
other entity to invest any specific amount or percentage of client assets in any specific securities as a result of the
arrangement. However, because MAWM receives these benefits from LPL Financial, there is a potential conflict of
interest. The receipt of these products and services presents a financial incentive for MAWM to recommend that its
clients use LPL Financials’ custodial platform rather than another custodian’s platform.
LPL Financial makes available to MAWM various products and services designed to assist MAWM in managing and
administering client accounts. Many of these products and services may be used to service all or a substantial number
of MAWM’s accounts, including accounts not held with LPL Financial. These include software and other technology
that provide access to client account data (such as trade confirmation and account statements); facilitate trade
execution (and aggregation and allocation of trade orders for multiple client accounts); provide research, pricing
information and other market data; facilitate payment of MAWM’s fees from its clients’ accounts; and assist with
back-office functions; recordkeeping and client reporting.
While as a fiduciary MAWM endeavors to act in its clients’ best interests, the receipt of these benefits creates a
conflict of interest because MAWM’s recommendation that clients custody their assets at LPL Financial is based in
part on the benefit to MAWM of the availability of the foregoing products and services and not solely on the nature,
cost or quality of custody or brokerage services provided by LPL Financial.
Item 13: Review of Accounts
All client profiles will be reviewed on at least an annual basis by one of MAWM’s licensed professionals. However,
changes in a particular client’s account, or changes to a client’s circumstances will trigger a review of accounts.
Item 14: Client Referrals and Other Compensation
A.
Economic Benefit Provided by Third Parties for Advice Rendered to Client
Please refer to Item 12, where we discuss our recommendation of Broker-Dealers.
B.
Compensation to Non-Advisory Personnel for Client Referrals.
MAWM does not directly or indirectly compensate any person who is not advisory personnel for client referrals.
Item 15: Custody
MAWM deducts fees from client accounts but would not have custody of client funds otherwise. Clients will
receive statements and copies of all trade confirmations directly from LPL, the qualified custodian.
Clients whose fees are directly debited will provide written authorization to debit advisory fees from their accounts
held by a qualified custodian, LPL. The client will receive a statement from their account custodian showing all
transactions in their account, including the fee.
We encourage clients to carefully review the statements and confirmations sent to them by their custodian, and to
compare the information in your quarterly reports and billing statements prepared by MAWM against the
information in the statements provided directly from LPL. Please alert us of any discrepancies.
Item 16: Investment Discretion
When MAWM is engaged to provide asset management services on a discretionary basis, we will monitor your
accounts to ensure that they are meeting your asset allocation requirements. If any changes are needed to your
investments, we will make the changes. These changes may involve selling a security or group of investments and
buying others or keeping the proceeds in cash. Since we carefully select the securities used in our models, we do not
permit restrictions. You will receive quarterly statements from your account custodian. Clients engaging us on a
discretionary basis will be asked to execute a Limited Power of Attorney (granting us the discretionary authority over
the client accounts) as well as an Investment Management Agreement that outlines the responsibilities of both the
client and MAWM.
Item 17: Voting Client Securities
As a matter of firm policy, our firm does not vote proxies on behalf of clients. Clients will receive their proxies
and other solicitations directly from their custodian or transfer agent and retain sole responsibility for voting. We
do not offer clients advice on how to vote their proxies.
Item 18: Financial Information
MAWM does not require the prepayment of fees more than six (6) months or more in advance and therefore has
not provided a balance sheet with this brochure.
There are no material financial circumstances or conditions that would reasonably be expected to impair our ability
to meet our contractual obligations to our clients.
MAWM has not been the subject of a bankruptcy petition at any time during the past ten years.