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Mosaic FI LLC
Firm Brochure - Form ADV Part 2A
This brochure provides information about the qualifications and business practices of Mosaic FI LLC. If you have
any questions about the contents of this brochure, please contact us at (847)371-5203 or by email at:
tammy@mosaicfi.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.
Additional information about Mosaic FI LLC is also available on the SEC’s website at www.adviserinfo.sec.gov.
Mosaic FI LLC’s CRD number is: 169670.
475 Half Day Rd, Suite 100
Lincolnshire, Illinois, 60069
(847) 371-5203
mosaicfi.com
tammy@mosaicfi.com
Registration does not imply a certain level of skill or training.
Version Date: 04/20/2026
Item 2: Material Changes
The material changes in this brochure will be updated annually or when material changes occur since
the previous release of the Firm Brochure. The last annual updating amendment of Mosaic FI LLC was
on 01/28/2025. Material changes relate to Mosaic FI LLC policies, practices, or conflicts of interest.
• Mosaic FI LLC has transitioned to registration with the United States Securities and Exchange
Commission from its current registration at the state level.
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Item 3: Table of Contents
Item 1: Cover Page
Item 2: Material Changes ........................................................................................................................................................................................... i
Item 3: Table of Contents .......................................................................................................................................................................................... ii
Item 4: Advisory Business ......................................................................................................................................................................................... 5
A. Description of the Advisory Firm................................................................................................................................................................... 5
B. Types of Advisory Services.............................................................................................................................................................................. 5
Portfolio Management Services ...................................................................................................................................................................... 5
Pension Consulting Services ........................................................................................................................................................................... 6
Financial Planning ............................................................................................................................................................................................ 6
Services Limited to Specific Types of Investments ...................................................................................................................................... 6
C. Client Tailored Services and Client Imposed Restrictions .......................................................................................................................... 6
Portfolio Management Services ...................................................................................................................................................................... 6
Financial Planning Services ............................................................................................................................................................................. 7
D. Wrap Fee Programs .......................................................................................................................................................................................... 9
E. Assets Under Management .............................................................................................................................................................................. 9
Item 5: Fees and Compensation ................................................................................................................................................................................ 9
A. Fee Schedule ...................................................................................................................................................................................................... 9
Portfolio Management Services Fees ............................................................................................................................................................. 9
Pension Consulting Services Fees ................................................................................................................................................................ 10
Stand-Alone Financial Planning Fees .......................................................................................................................................................... 10
Fixed Fees ........................................................................................................................................................................................................ 10
Ongoing Financial Planning Fees ................................................................................................................................................................. 11
Hourly Fees ..................................................................................................................................................................................................... 11
B. Payment of Fees............................................................................................................................................................................................... 11
Payment of Portfolio Management Fees ...................................................................................................................................................... 11
Payment of Pension Consulting Services Fees ............................................................................................................................................ 11
Payment of Financial Planning Fees ............................................................................................................................................................ 11
C. Client Responsibility for Third Party Fees .................................................................................................................................................. 12
D. Prepayment of Fees ........................................................................................................................................................................................ 12
E. Outside Compensation for the Sale of Securities to Clients ...................................................................................................................... 12
Item 6: Performance-Based Fees and Side-By-Side Management ...................................................................................................................... 12
Item 7: Types of Clients ........................................................................................................................................................................................... 12
Minimum Account Size ................................................................................................................................................................................. 13
Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss ......................................................................................... 13
A.
Methods of Analysis and Investment Strategies ................................................................................................................................ 13
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Methods of Analysis ...................................................................................................................................................................................... 13
Fundamental analysis .................................................................................................................................................................................... 13
Technical analysis ........................................................................................................................................................................................... 13
Cyclical analysis ............................................................................................................................................................................................. 13
Investment Strategies ..................................................................................................................................................................................... 13
B.
Material Risks Involved ........................................................................................................................................................................ 14
Methods of Analysis ...................................................................................................................................................................................... 14
Fundamental analysis .................................................................................................................................................................................... 14
Technical analysis ........................................................................................................................................................................................... 14
Cyclical analysis ............................................................................................................................................................................................. 14
Investment Strategies ..................................................................................................................................................................................... 14
C.
Risks of Specific Securities Utilized ..................................................................................................................................................... 15
Item 9: Disciplinary Information ............................................................................................................................................................................ 16
A.
Criminal or Civil Actions ...................................................................................................................................................................... 16
B.
Administrative Proceedings ................................................................................................................................................................. 16
C.
Self-regulatory Organization (SRO) Proceedings .............................................................................................................................. 16
Item 10: Other Financial Industry Activities and Affiliations ............................................................................................................................. 16
A.
Registration as a Broker/Dealer or Broker/Dealer Representative ................................................................................................ 17
B.
Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor ................. 17
C.
Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests ............................................ 17
D.
Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections .................................. 17
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................................................................... 18
A.
Code of Ethics ......................................................................................................................................................................................... 18
B.
Recommendations Involving Material Financial Interests ............................................................................................................... 18
C.
Investing Personal Money in the Same Securities as Clients ............................................................................................................ 18
D.
Trading Securities At/Around the Same Time as Clients’ Securities ............................................................................................. 18
Item 12: Brokerage Practices.................................................................................................................................................................................... 19
A.
Factors Used to Select Custodians and/or Broker/Dealers ............................................................................................................. 19
1.
Research and Other Soft-Dollar Benefits ........................................................................................................................................ 19
2.
Brokerage for Client Referrals ......................................................................................................................................................... 19
3.
Clients Directing Which Broker/Dealer/Custodian to Use ........................................................................................................ 19
B.
Aggregating (Block) Trading for Multiple Client Accounts ............................................................................................................. 20
Item 13: Reviews of Accounts ................................................................................................................................................................................. 20
A.
Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ............................................................................... 20
B.
Factors That Will Trigger a Non-Periodic Review of Client Accounts ............................................................................................ 20
C.
Content and Frequency of Regular Reports Provided to Clients ..................................................................................................... 20
Item 14: Client Referrals and Other Compensation ............................................................................................................................................. 21
A.
Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) ...... 21
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B.
Compensation to Non – Advisory Personnel for Client Referrals ................................................................................................... 22
Item 15: Custody ....................................................................................................................................................................................................... 22
Item 16: Investment Discretion ............................................................................................................................................................................... 22
Item 17: Voting Client Securities (Proxy Voting) .................................................................................................................................................. 22
Item 18: Financial Information ................................................................................................................................................................................ 22
A.
Balance Sheet .......................................................................................................................................................................................... 22
B.
Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ............................... 23
C.
Bankruptcy Petitions in Previous Ten Years ...................................................................................................................................... 23
Artificial Intelligence ................................................................................................................................................................................................ 24
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Item 4: Advisory Business
A. Description of the Advisory Firm
Mosaic FI LLC (hereinafter “Mosaicfi”) is a Limited Liability Company organized
in the State of Illinois. The firm was formed and registered in November 2013, and
the principal owners are Jenifer Ann Aronson and Tamra R. Wener.
B. Types of Advisory Services
Mosaicfi offers the following services to advisory clients:
Portfolio Management Services
Mosaicfi offers ongoing portfolio management services based on the individual
goals, objectives, time horizon, and risk tolerance of each client. Mosaicfi creates
an Investment Policy Statement for each client, which outlines the client’s current
situation (income, tax levels, and risk tolerance levels) and then constructs a plan
to aid in the selection of a portfolio that matches each client’s specific situation.
Portfolio management services include, but are not limited to, the following:
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Investment strategy •
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Asset allocation
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Risk tolerance
Personal investment policy
Asset selection
Regular portfolio monitoring
Mosaicfi evaluates the current investments of each client with respect to their risk
tolerance levels and time horizon. Risk tolerance levels are documented in the
Investment Policy Statement, which is given to each client.
Mosaicfi seeks to provide that investment decisions are made in accordance with
the fiduciary duties owed to its clients and without consideration of Mosaicfi’s
economic, investment or other financial interests. To meet its fiduciary obligations,
Mosaicfi attempts to avoid, among other things, investment, or trading practices
that systematically advantage or disadvantage certain client portfolios, and,
accordingly, Mosaicfi’s policy is to seek fair and equitable allocation of investment
opportunities/transactions among its clients to avoid favoring one client over
another over time. It is Mosaicfi’s policy to allocate investment opportunities and
transactions it identifies as being appropriate and prudent, that might have a
limited supply, among its clients on a fair and equitable basis over time.
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Pension Consulting Services
Mosaicfi offers consulting services to small businesses to create SIMPLE IRA, SEP
IRA, and Individual 401(k) plans for their owners and employees.
Financial Planning
Mosaicfi provides holistic, objective, financial planning services to individuals,
families, estates, and trusts. Financial planning is included for all clients engaging
Mosaicfi for portfolio management services and is also offered as a stand-alone
service separate from portfolio management.
Mosaicfi focuses not just on numbers and reports but takes the time to get to know
and educate the clients it serves. The topics covered under a financial plan may
include, but are not limited to, one or more of the following, as mutually
determined by the client and Mosaicfi:
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Asset allocation
Cash flow planning and management
Divorce planning
Education funding
Elder-care planning
Estate planning and asset titling
Investment manager selection
Investment portfolio review
Risk/insurance planning
Retirement planning
Social Security planning
Planning for a family member with special needs
Stock option/restricted stock planning
Tax planning
Services Limited to Specific Types of Investments
Mosaicfi generally limits its investment advice to mutual funds, Exchange Traded
Funds (ETFs), fixed income securities, and real estate funds (including REITs).
Mosaicfi may use other securities to help diversify a portfolio when applicable.
C. Client Tailored Services and Client Imposed Restrictions
Portfolio Management Services
Mosaicfi will tailor an investment management program for each individual client.
Mosaicfi focuses not just on standard risk tolerance information but on the goals
and objectives of each client. We evaluate each client situation to determine the
appropriate asset allocation based on their needs and requirements. This will
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include an interview session to identify the client’s specific needs and
requirements as well as an investment plan that will be executed by Mosaicfi on
behalf of the client. Mosaicfi may use “model portfolios” together with a specific
set of recommendations for each client based on their personal restrictions, needs,
and targets. Clients may impose restrictions in investing in certain securities or
types of securities in accordance with their values or beliefs. However, if the
restrictions prevent Mosaicfi from properly servicing the client account, or if the
restrictions would require Mosaicfi to deviate from its standard suite of services,
Mosaicfi reserves the right to end the relationship.
Financial Planning Services
Financial Planning Services provided by Mosaicfi are tailored based on the client’s
goals and objectives and vary by client. Mosaicfi generally follows the process
below when providing customized financial planning services:
1) Defining Concerns, Goals, and Needs – Mosaicfi will provide the client with
a list of documentation and information to gather, review the information,
and engage the client in communication via (in person meetings, video
conference, phone, and/or via e-mail) regarding concerns, goals, and needs.
A material lack of disclosure by the client will impact the advice provided.
It is the client’s responsibility to notify Mosaicfi if there is any significant
change or new information that will impact Mosaicfi’s work in providing
services to the client.
2) Determining the Scope of the Engagement - While Mosaicfi strongly
recommends the client review all relevant financial planning areas to
understand their overall financial situation, Mosaicfi recognizes there are
situations where a client will wish to engage Mosaicfi for assistance with
only limited areas. The client and Mosaicfi will determine the scope of
services to be provided for clients engaging Mosaicfi for stand-alone
financial planning services, and Mosaicfi and the client will enter into a
written agreement identifying those services. The client must understand
that the entire financial situation may not be fully addressed if only limited
areas are to be reviewed within the terms of the agreement.
3) Review of Current Financial Picture – Clients will be provided with a
written report/summary covering the topics reviewed in the financial plan,
when appropriate based on the scope of services. For portfolio management
clients, and clients engaging Mosaicfi for comprehensive financial planning
as a stand-alone service, the financial plan will review the current situation
and may provide alternate scenarios as requested by the client and/or as
determined by Mosaicfi. Clients engaging Mosaicfi for review of limited
areas may receive a report focusing only on the relevant areas and/or a
summary of key findings and recommended next steps. The client is
responsible for reviewing the report, identifying, and reporting to Mosaicfi
any incorrect information, informing Mosaicfi of any inaccurate or changed
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assumptions, and providing any new information that is material to the
financial plan.
4) Developing Observations and Recommendations – Mosaicfi will provide
observations and recommendations based on the information provided by
the client and the work completed by Mosaicfi. The client will review the
observations and recommendations and may choose to accept or reject the
advice provided by Mosaicfi.
5) Implementation of Recommendations – Mosaicfi emphasizes
the
importance of implementation in achieving the client’s financial goals. For
clients who engage Mosaicfi for stand-alone financial planning services, the
client will have sole responsibility for deciding which of Mosaicfi’s
recommendations to implement and for achieving that implementation,
including by engaging accountants, estate planning attorneys, investment
firms, insurance agents and/or other professionals, as necessary. For clients
who engage Mosaicfi for portfolio management services, Mosaicfi will assist
with the implementation of the recommendations the client chooses to
implement, as directed by the client. For clients who engage Mosaicfi for
stand-alone financial planning services, if the client requests Mosaicfi’s
assistance with implementation and Mosaicfi is able and willing to provide
that assistance, Mosaicfi will work together with the client to identify which
tasks Mosaicfi will help implement. Depending on the scope of the
implementation, Mosaicfi may prepare a new financial planning agreement
to cover only the implementation phase of the engagement.
6) Monitoring and Updating – As with implementation, Mosaicfi strongly
encourages its clients to monitor their financial plan, including their
investment holdings and allocation, on a regular basis, and to update the
financial plan periodically to address changing circumstances and goals.
For clients who engage Mosaicfi for portfolio management services,
Mosaicfi will provide regular monitoring and updating of the client’s
financial plan. For clients who engage Mosaicfi for stand-alone financial
planning services, the client will have sole responsibility for monitoring and
updating, and for engaging appropriate professionals to assist them in
doing so. Mosaicfi will not provide monitoring or updating of the client’s
financial plan, including their investments, unless specifically engaged by
the client to do so as identified in the financial planning agreement. It is at
the client’s discretion whether to re-engage Mosaicfi from time to time to
update the client’s financial plan, review the client’s investments, and/or
address any new goals, concerns, or significant changes.
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D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated
fee that includes management fees, transaction costs, fund expenses, and any other
administrative fees. Mosaicfi does not participate in any wrap fee programs.
E. Assets Under Management
Mosaicfi has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$112,808,698.00
$ 0.00
December 2025
Item 5: Fees and Compensation
A. Fee Schedule
Portfolio Management Services Fees
Total Assets Under Advisement
Annual Fee
Up to 1,000,000
1.00%
$1,000,000 to $3,000,000
0.75%
Above $3,000,000
0.50%
Mosaicfi bills based on the balance on the first day of the billing period. The fee
schedule is a blended tier schedule. Financial planning services are included in the
portfolio management fees.
These fees are negotiable, and the final fee schedule is attached as Exhibit II of the
Investment Advisory Contract. Unless a client has received Mosaicfi’s disclosure
brochure (this Form ADV Part 2A) at least 48 hours prior to signing the Investment
Advisory Contract, the client may terminate the advisory relationship within five
business days of signing the contract without penalty, for full refund of Mosaicfi’s
fees. Thereafter, clients may terminate the Investment Advisory Contract with one
day’s written notice.
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Pension Consulting Services Fees
For SIMPLE IRA plans, Mosaicfi charges a minimum of $50 per quarter per
participant fee, and a maximum $125 per quarter per participant fee. For SEP IRA
and Individual 401(k) plans, the Portfolio Management Service Fees apply.
Stand-Alone Financial Planning Fees
Fixed Fees
Fees to develop a comprehensive financial plan start at $4,200. The actual fee will
be determined based on the scope of work and will be documented in the financial
planning agreement presented to the client before work begins. Fixed financial
planning fees require a deposit equal to 50% of the fixed fee to start the
engagement and the remaining 50% balance will be billed upon completion of the
engagement.
Mosaicfi clients commonly fall into one of three financial planning fixed-fee levels
detailed below. All fixed-fee comprehensive financial planning engagements
include a written summary of observations, recommendations, and follow-up
items, unless otherwise noted, and a copy of relevant financial planning reports.
Level 1 Financial Plan ($4,200 - $6,500)
This level of financial plan represents a modest to moderate level of
complexity. A financial plan at this level would likely include cash flow
projections, basic education planning, retirement projections, investment
review, simple tax planning strategies, review of basic insurance coverage,
and review of asset ownership and beneficiary designations (when provided
by the clients).
Level 2 Financial Plan ($6,500 - $10,000)
This level of financial plan represents a higher level of complexity
and may include more complicated tax planning, numerous retirement and
cash planning scenarios involving a wide range of assumptions, specialized
estate planning analysis, complicated insurance and/or annuity needs and
policies, and equity compensation plans
Level 3 Financial Plan ($10,000+)
This level of financial plan represents a high level of complexity typical of
those with significant assets and/or income who desire assistance with
sophisticated estate planning and legacy strategies, executive level benefits, small
business consulting, complicated charitable giving wishes, complex investments
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and insurance policies, and/or ongoing coordination with other advisors to
include CPAs, estate planning attorneys, insurance advisors, and wealth
managers.
Ongoing Financial Planning Fees
After the initial financial plan is prepared and presented, clients may retain
Mosaicfi for ongoing stand-alone financial planning services to assist with
implementation, monitoring, and updating the financial plan. Ongoing financial
planning services will be provided under a separate financial planning agreement
covering a 12-month period. The fee for this service will be 50 – 100% of the initial
planning fee and will be set based on the areas to be covered and the complexity
of the financial plan. Fees will be collected on a quarterly basis on the first day of
the quarter.
Hourly Fees
For certain projects at Mosaicfi’s discretion, Mosaicfi will bill at an hourly rate
based on actual time spent. The current hourly rate for financial planning services
is $400 per hour and the specific rate charged will be disclosed in the financial
planning agreement in advance of providing any services. This hourly rate will be
evaluated annually and will likely increase from year to year. Mosaicfi will record
the actual time spent each day on our services and may bill for reasonable out-of-
pocket expenses incurred during the engagement. Invoices will typically be issued
monthly or at the project's end.
B. Payment of Fees
Payment of Portfolio Management Fees
Portfolio management fees are withdrawn directly from the client’s accounts with
the client’s written authorization. Fees are paid quarterly.
Payment of Pension Consulting Services Fees
Pension Consulting fees are withdrawn directly from the client’s accounts with the
client’s written authorization. Fees are paid quarterly.
Payment of Financial Planning Fees
Financial planning fees are due upon receipt of invoice.
At no time will Mosaicfi require payment of more than $1,200 in fees more than
six months in advance of the financial planning engagement.
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C. Client Responsibility for Third Party Fees
Clients are responsible for the payment of all third-party fees (i.e., custodian fees,
brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate
and distinct from the fees and expenses charged by Mosaicfi. Please see Item 12 of
this brochure regarding broker/custodian.
D. Prepayment of Fees
Mosaicfi collects fees in advance. Refunds for fees paid in advance will be returned
within fourteen days to the client via check or return deposit back into the client’s
account.
For all asset-based fees paid in advance, the fee refunded will be the balance of the
fees collected in advance minus the daily rate* times the number of days in the
billing period up to and including the day of termination. (*The daily rate is
calculated by dividing the annual asset-based fee by 365.)
For all financial planning fees paid in advance, if the engagement is terminated by
the client within (5) business days of signing the agreement, 100% of the initial
deposit will be refunded. For engagements terminated after (5) business days of
signing the agreement, the fee refunded will be determined by calculating an
estimate of the time spent on the engagement times the current hourly rate and
subtracting the calculated amount from the deposit paid at the beginning of the
engagement.
E. Outside Compensation for the Sale of Securities to Clients
Neither Mosaicfi nor its supervised persons accept any compensation for the sale
of securities or other investment products, including asset-based sales charges or
service fees from the sale of mutual funds.
Item 6: Performance-Based Fees and Side-By-Side Management
Mosaicfi does not accept performance-based fees or other fees based on a share of capital gains
on or capital appreciation of the assets of a client.
Item 7: Types of Clients
Mosaicfi generally provides advisory services to the following types of clients:
❖ Individuals, families, trusts and estates
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❖ High-net-worth individuals
❖ Corporations or other business entities
❖ Pension and profit-sharing plans
Minimum Account Size
For Portfolio Management clients the minimum account balance is $500,000. Management has
the right to make an exception on a case-by-case basis.
For clients engaging Mosaicfi for stand-alone financial planning services, there is no minimum
account/portfolio size and no minimum net worth or income requirement.
Item 8: Methods of Analysis, Investment Strategies, and Risk
of Investment Loss
A. Methods of Analysis and Investment Strategies
Methods of Analysis
Mosaicfi’s methods of analysis include fundamental analysis, technical analysis,
cyclical analysis, quantitative analysis, and modern portfolio theory.
Fundamental analysis involves the analysis of financial statements, the general
financial health of companies, and/or the analysis of management or competitive
advantages.
Technical analysis involves the analysis of past market data; primarily price and
volume.
Cyclical analysis involved the analysis of business cycles to find favorable
conditions for buying and/or selling a security.
Quantitative analysis deals with measurable factors as distinguished from
qualitative considerations such as the character of management or the state of
employee morale, such as the value of assets, the cost of capital, historical
projections of sales, and so on.
Modern portfolio theory is a theory of investment which attempts to maximize
portfolio expected return for a given amount of portfolio risk, or equivalently
minimize risk for a given level of expected return, by carefully choosing the
proportions of various assets.
Investment Strategies
Mosaicfi uses long term trading and short-term trading.
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Investing in securities involves a risk of loss that you, as a client, should be
prepared to bear.
B. Material Risks Involved
Methods of Analysis
Fundamental analysis concentrates on factors that determine a company’s value
and expected future earnings. This strategy would normally encourage equity
purchases in stocks that are undervalued or priced below their perceived value.
The risk assumed is that the market will fail to reach expectations of perceived
value.
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
work long term.
Cyclical analysis assumes that the markets react in cyclical patterns which, once
identified, can be leveraged to provide performance. The risks with this strategy
are twofold: 1) the markets do not always repeat cyclical patterns and 2) if too
many investors begin to implement this strategy, it changes the very cycles these
investors are trying to exploit.
Quantitative Model Risk. Investment strategies using quantitative models may
perform differently than expected as a result of, among other things, the factors
used in the models, the weight placed on each factor, changes from the factors’
historical trends, and technical issues in the construction and implementation of
the models.
Modern Portfolio Theory assumes that investors are risk adverse, 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.
Investment Strategies
Mosaicfi’s use of short-term trading generally holds greater risk, and clients
should be aware that there is a material risk of loss using any of those strategies.
Unless directed by a client or due to client circumstances we do not implement
short term trading strategies.
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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.
Short-term trading risks include liquidity, economic stability, and inflation, in
addition to the long-term trading risks listed above. Frequent trading, can affect
investment performance, particularly through increased brokerage and other
transaction costs and taxes.
Investing in securities involves a risk of loss that you, as a client, should be
prepared to bear.
C. Risks of Specific Securities Utilized
Clients should be aware that there is a material risk of loss using any investment
strategy. The investment types listed below are not guaranteed or insured by the
FDIC or any other government agency.
Mutual Funds and Exchange Traded Funds (ETFs): Investing in mutual funds
and ETFs carries the risk of capital loss and thus clients may lose money investing
in mutual funds and ETFs. All mutual funds and ETFs have costs that lower
investment returns. Mutual funds and ETFs can be of a lower risk nature
depending on their underlying investments.
Mutual funds and ETFs can hold a variety of different investments. Some mutual
funds and ETFs are considered lower risk because they primarily hold bonds (also
referred to as fixed income) and some are considered higher risk because they
primarily hold stocks (also referred to as equities). For more information about
fixed income and equities, see below.
Fixed income (bond) investments generally pay a return on a fixed schedule,
though the amount of the payments can vary. These types of investments include
corporate and government debt securities, leveraged loans, high yield debt, and
investment grade debt and structured products, such as mortgage and other asset-
backed securities Tthe fixed income market can be 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); however, they carry a potential risk of
losing share price value, albeit rather minimal.
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Equities (stocks) are considered to carry a high level of risk. These risks include,
decreasing share price value, not receiving the dividends that were expected,
company bankruptcies/mergers/restructurings, or some combination of all these
risks. A slower-growth or recessionary economic environment could also
adversely affect the price of all stocks.
Real Estate funds (including REITs) face several types of risk that are inherent in
the real estate sector, which historically has experienced significant fluctuations
and cycles in performance. Revenues and cash flows may be adversely affected
by: changes in local real estate market conditions due to changes in national or
local economic conditions or changes in local property market characteristics;
competition from other properties offering the same or similar services; changes
in interest rates and in the state of the debt and equity credit markets; the ongoing
need for capital improvements; changes in real estate tax rates and other operating
expenses; adverse changes in governmental rules and fiscal policies; adverse
changes in zoning laws; the impact of present or future environmental legislation
and compliance with environmental laws.
Past performance is not indicative of future results. Investing in securities
involves a risk of loss that you, as a client, should be prepared to bear.
Item 9: Disciplinary Information
A. Criminal or Civil Actions
There are no criminal or civil actions to report.
B. Administrative Proceedings
There are no administrative proceedings to report.
C. Self-regulatory Organization (SRO) Proceedings
There are no self-regulatory organization proceedings to report.
Item 10: Other Financial Industry Activities and Affiliations
As a fiduciary, Mosaicfi has certain legal obligations, including the obligation to act in clients'
best interest. Mosaicfi maintains a Business Continuity and Succession Plan and seeks to avoid
a disruption of service to clients in the event of an unforeseen loss of key personnel, due to a
disability or death. To that end, Mosaicfi has entered into a succession agreement with Strategic
Wealth Partners Group, LLC, effective September 14, 2017. Mosaicfi can provide additional
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information to any current or prospective client upon request to Jenifer A. Aronson, CFA,
Managing Partner at (847) 371-5203 or jenifer@mosaicfi.com.
A. Registration as a Broker/Dealer or Broker/Dealer
Representative
Neither Mosaicfi nor its representatives are registered as, or have pending
applications to become, a broker/dealer or a representative of a broker/dealer.
B. Registration as a Futures Commission Merchant, Commodity
Pool Operator, or a Commodity Trading Advisor
Neither Mosaicfi nor its representatives are registered as or have pending
applications to become either a Futures Commission Merchant, Commodity Pool
Operator, or Commodity Trading Advisor or an associated person of the foregoing
entities.
C. Registration Relationships Material to this Advisory Business
and Possible Conflicts of Interests
Tamra R. Wener and her husband are joint partners in Austin Ventures, LLC, a
residential rental business. The business was started in April 2003 and is used to
purchase residential real estate and rehab the properties to sell or rent. She spends
less than 5 hours per month on this business and none of the hours are spent
during securities trading hours. Duties include financial due diligence, legal
document review, and accounting.
Tamra R. Wener is an adjunct instructor at Northwestern University School of
Professional Studies. When class is in session, she spends 9 hours per month on
this activity.
D. Selection of Other Advisers or Managers and How This Adviser
is Compensated for Those Selections
Mosaicfi does not utilize nor select third-party- investment advisers. All assets are
managed by Mosaicfi management.
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Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
A. Code of Ethics
Mosaicfi has a written Code of Ethics that covers the following areas: Prohibited
Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted
Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment,
Confidentiality, Service on a Board of Directors, Compliance Procedures,
Compliance with Laws and Regulations, Procedures and Reporting, Certification
of Compliance, Reporting Violations, Compliance Officer Duties, Training and
Education, Recordkeeping, Annual Review, and Sanctions. Our Code of Ethics is
available free upon request to any client or prospective client.
B. Recommendations Involving Material Financial Interests
Mosaicfi does not recommend that clients buy or sell any security in which a
related person to Mosaicfi or Mosaicfi has a material financial interest.
C. Investing Personal Money in the Same Securities as Clients
From time to time, representatives of Mosaicfi may buy or sell securities for
themselves that they also recommend to clients. This may provide an opportunity
for representatives of Mosaicfi to buy or sell the same securities before or after
recommending the same securities to clients resulting in representatives profiting
off the recommendations they provide to clients. Such transactions may create a
conflict of interest. Mosaicfi will always document any transactions that could be
construed as conflicts of interest and will never engage in trading that operates to
the client’s disadvantage when similar securities are being bought or sold.
D. Trading Securities At/Around the Same Time as Clients’
Securities
From time to time, representatives of Mosaicfi may buy or sell securities for
themselves at or around the same time as clients. This may provide an opportunity
for representatives of Mosaicfi to buy or sell securities before or after
recommending securities to clients resulting in representatives profiting off the
recommendations they provide to clients. Such transactions may create a conflict
of interest; however, Mosaicfi will never engage in trading that operates to the
client’s disadvantage when similar securities are being bought or sold.
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Item 12: Brokerage Practices
A. Factors Used to Select Custodians and/or Broker/Dealers
Custodians/broker-dealers will be recommended based on Mosaicfi’s duty to seek
“best execution,” which is the obligation to seek to execute securities transactions
for a client on terms that are the most favorable to the client under the
circumstances. The client will not necessarily pay the lowest commission or
commission equivalent, and Mosaicfi may also consider the market expertise and
research access provided by the payment of commissions, including but not
limited to access to written research, oral communication with analysts,
admittance to research conferences and other resources provided by the brokers
to aid in the research efforts of Mosaicfi. Mosaicfi will never charge a premium or
commission on transactions, beyond the actual cost imposed by the broker-
dealer/custodian. Mosaicfi will only refer clients to broker-dealers/custodians
properly registered in that state in which the client resides. Mosaicfi recommends
Charles Schwab & Co., Inc. (“Schwab”) Member FINRA/SIPC.
1. Research and Other Soft-Dollar Benefits
While Mosaicfi has no formal soft dollars program in which soft dollars are
used to pay for third party services, Mosaicfi may receive research, products,
or other services from its broker/dealer in connection with client securities
transactions (“soft dollar benefits”) consistent with (and not outside of) the safe
harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as
amended, and may consider these benefits in recommending brokers. There
can be no assurance that any particular client will benefit from any particular
soft dollar research or other benefits. Mosaicfi benefits by not having to
produce or pay for the research, products or services, and Mosaicfi will have
an incentive to recommend a broker dealer based on receiving research or
services. Clients should be aware that Mosaicfi’s acceptance of soft dollar
benefits may result in higher commissions charged to the client.
2. Brokerage for Client Referrals
Mosaicfi receives no referrals from a broker-dealer or third party in exchange
for using that broker-dealer or third party.
3. Clients Directing Which Broker/Dealer/Custodian to Use
Mosaicfi will require clients to use a specific broker-dealer to execute
transactions.
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B. Aggregating (Block) Trading for Multiple Client Accounts
If Mosaicfi buys or sells the same securities on behalf of more than one client, it
might, but would be under no obligation to, aggregate or bunch, to the extent
permitted by applicable law and regulations, the securities to be purchased or sold
for multiple clients in order to seek more favorable prices, lower brokerage
commissions or more efficient execution. In such case, Mosaicfi would place an
aggregate order with the broker on behalf of all such clients to ensure fairness for
all clients; provided, however, that trades would be reviewed periodically to ensure
that accounts are not systematically disadvantaged by this policy. Mosaicfi would
determine the appropriate number of shares to place with brokers and will select
the appropriate brokers consistent with the Adviser’s duty to seek best execution,
except for those accounts with specific brokerage direction (if any).
Item 13: Reviews of Accounts
A. Frequency and Nature of Periodic Reviews and Who Makes
Those Reviews
All client portfolio management accounts are reviewed at least quarterly by Tamra
R Wener or Jenifer Aronson, with regard to clients’ respective investment policies
and risk tolerance levels.
All financial plans are reviewed prior to plan delivery to the client by Tamra R
Wener. There is only one level of review for financial plans, and that is the review
conducted to create the financial plan.
B. Factors That Will Trigger a Non-Periodic Review of Client
Accounts
Portfolio management reviews may be triggered by material market, economic or
political events, or by changes in client's financial situations (such as retirement,
termination of employment, physical move, or inheritance).
With respect to stand-alone financial planning engagements, Mosaicfi’s services
will generally conclude upon delivery of the financial plan, unless the client has
engaged Mosaicfi for additional services.
C. Content and Frequency of Regular Reports Provided to Clients
Each portfolio management client will receive at least quarterly a written report
that details the client’s account including assets held and asset value, which report
will come from the custodian and at least quarterly a written report from Mosaicfi.
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Each financial planning client will receive the financial plan upon completion.
Item 14: Client Referrals and Other Compensation
A. Economic Benefits Provided by Third Parties for Advice
Rendered to Clients (Includes Sales Awards or Other Prizes)
Mosaicfi participates in the institutional advisor program (the “Program”) offered
by Schwab. Schwab offers independent investment advisor services which include
custody of securities, trade execution, clearance and settlement of transactions.
Mosaicfi receives some benefits from Schwab through its participation in the
Program.
As part of the Program, Mosaicfi may recommend Schwab to clients for custody
and brokerage services. There is no direct link between Mosaicfi’s participation in
the Program and the investment advice it gives to its clients, although Mosaicfi
receives economic benefits through its participation in the Program that are
typically not available to Schwab retail investors. These benefits include the
following products and services (provided without cost or at a discount): receipt of
duplicate client statements and confirmations; research related products and tools;
consulting services; access to a trading desk serving Mosaicfi participants; access to
block trading (which provides the ability to aggregate securities transactions for
execution and then allocate the appropriate shares to client accounts); the ability to
have Mosaicfi’s fees deducted directly from client accounts; access to an electronic
communications network for client order entry and account information; access to
mutual funds with no transaction fees and to certain institutional money managers;
and discounts on compliance, marketing, research, technology, and practice
management products or services provided to Mosaicfi by third party vendors.
Schwab may also pay for business consulting and professional services received by
Mosaicfi’s related persons. Some of the products and services made available by
Schwab through the Program may benefit Mosaicfi but may not benefit its client
accounts. These products or services may assist Mosaicfi in managing and
administering client accounts, including accounts not maintained at Schwab. Other
services made available by Schwab are intended to help Mosaicfi manage and
further develop its business enterprise. The benefits received by Mosaicfi or its
personnel through participation in the Program do not depend on the amount of
brokerage transactions directed to Schwab. As part of its fiduciary duties to clients,
Mosaicfi endeavors at all times to put the interests of its clients first. Clients should
be aware, however, that the receipt of economic benefits by Mosaicfi or its related
persons in and of itself creates a conflict of interest and may indirectly influence
Mosaicfi’s choice of Schwab for custody and brokerage services.
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B. Compensation to Non – Advisory Personnel for Client Referrals
Mosaicfi does not directly or indirectly compensate any person who is not advisory
personnel for client referrals.
Item 15: Custody
When it deducts fees directly from client accounts at a selected custodian, Mosaicfi will be
deemed to have limited custody of client’s assets and must have written authorization from the
client to do so. Clients will receive all account statements and billing invoices that are required in
each jurisdiction and should carefully review those statements for accuracy.
Item 16: Investment Discretion
Mosaicfi provides discretionary portfolio management services to clients. The Investment
Advisory Contract established with each client outlines the discretionary authority for trading.
Where investment discretion has been granted, Mosaicfi generally manages the client’s account
and makes investment decisions without consultation with the client as to what securities to buy
or sell, when the securities are to be bought or sold for the account, the total amount of the
securities to be bought/sold, or the price per share. In some instances, Mosaicfi’s discretionary
authority in making these determinations may be limited by conditions imposed by a client (in
investment guidelines or objectives, or client instructions otherwise provided to Mosaicfi).
Item 17: Voting Client Securities (Proxy Voting)
Mosaicfi will not ask for, nor accept voting authority for client securities. Clients will receive
proxies directly from the issuer of the security or the custodian. Clients should direct all proxy
questions to the issuer of the security.
Item 18: Financial Information
A. Balance Sheet
Mosaicfi neither requires nor solicits prepayment of more than $1200 in fees per
client, six months or more in advance and therefore does not need to include a
balance sheet with this brochure.
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B. Financial Conditions Reasonably Likely to Impair Ability to
Meet Contractual Commitments to Clients
Neither Mosaicfi nor its management has any financial condition that is likely to
reasonably impair Mosaicfi’s ability to meet contractual commitments to clients.
C. Bankruptcy Petitions in Previous Ten Years
Mosaicfi has not been the subject of a bankruptcy petition in the last ten years.
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Artificial Intelligence
We may utilize artificial intelligence (AI) tools internally to assist in summarizing and organizing notes
from client meetings to enhance record-keeping and efficiency. These AI tools do not replace human
oversight, and all notes are reviewed for accuracy and compliance with regulatory standards. AI is not used
to make investment decisions or communicate directly with clients. We conduct thorough due diligence
upfront and ongoing assessments of our AI tools' privacy and cybersecurity protocols to ensure they meet
standards of security and confidentiality. If you have any questions or wish to opt out of AI-assisted
notetaking, please contact us.
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