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Item 1: Cover Page
Item 1: Cover Page
Part 2A of Form ADV
Firm Brochure
December 19, 2025
Mowery & Schoenfeld Wealth Management, LLC
SEC No. 801-126430
Main Office
475 Half Day Road, Suite 500
Lincolnshire, IL 60069
Branch Office
300 S. Wacker Dr., Suite 920
Chicago, IL 60606
550 Oakland Avenue
Lake Forest, IL 60045
phone: 847-615-1555
email: wealthmanagement@msllcwealth.com
website: www.msllcwealth.com
fax: 843-833-8704
This brochure provides information about the qualifications and business practices of Mowery &
Schoenfeld Wealth Management, LLC. If you have any questions about the contents of this brochure,
please contact us at 847-247-8959. 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. Registration
with the SEC or state regulatory authority does not imply a certain level of skill or expertise.
Additional information about Mowery & Schoenfeld Wealth Management, LLC is also available on the
SEC’s website at www.adviserinfo.sec.gov.
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Part 2A of Form ADV: Mowery & Schoenfeld Wealth Management, LLC Brochure
Item 2: Material Changes
Item 2: Material Changes
This Firm Brochure is our disclosure document prepared according to regulatory requirements
and rules. Consistent with the rules, we will ensure that you receive a summary of any material
changes to this and subsequent Brochures within 120 days of the close of our business fiscal
year. Furthermore, we will provide you with other interim disclosures about material changes as
necessary. There is one material change since the last annual update of this disclosure statement
issued on February 27, 2025:
Item 4: The Firm has amended its use of third party money managers (“TPMMs”) to
reflect that fees paid by clients to TPMMs are in addition to the Firm’s fee schedule.
Item 5: The Firm has amended its fee schedule as of December 20, 2025 for all new
clients. Clients onboarded with the Firm prior to December 20, 2025 will be
grandfathered under their then-existing fee schedules.
Additionally, certain non-material changes and improvements have been implemented
throughout.
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Part 2A of Form ADV: Mowery & Schoenfeld Wealth Management, LLC Brochure
Item 3: Table of Contents
Item 3: Table of Contents
Item 1: Cover Page ...................................................................................................................................................... 1
Item 2: Material Changes .......................................................................................................................................... 2
Item 3: Table of Contents ......................................................................................................................................... 3
Item 4: Advisory Business ......................................................................................................................................... 4
Item 5: Fees and Compensation .......................................................................................................................... 12
Item 6: Performance-Based Fees and Side-by-Side Management ......................................................... 15
Item 7: Types of Clients ........................................................................................................................................... 15
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ................................................. 15
Item 9: Disciplinary Information ........................................................................................................................... 22
Item 10: Other Financial Industry Activities and Affiliations ........................................................................ 22
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading ........................................................................................................................................................... 23
Item 12: Brokerage Practices ................................................................................................................................... 25
Item 13: Review of Accounts ................................................................................................................................... 31
Item 14: Client Referrals and Other Compensation ........................................................................................ 31
Item 15: Custody .......................................................................................................................................................... 32
Item 16: Investment Discretion ............................................................................................................................... 33
Item 17: Voting Client Securities ............................................................................................................................ 33
Item 18: Financial Information ................................................................................................................................ 34
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Part 2A of Form ADV: Mowery & Schoenfeld Wealth Management, LLC Brochure
Item 4: Advisory Business
Item 4: Advisory Business
A. Mowery & Schoenfeld Wealth Management, LLC
Mowery & Schoenfeld Wealth Management, LLC is a registered investment adviser primarily
based in Lincolnshire, IL. We are organized as a limited liability company (“LLC”) under the laws
of the State of Illinois. We have been providing investment advisory services since 1999. We are
primarily owned by Jeffery L. Mowery, Keith A. Schoenfeld, and Michael A. Deering.
The following paragraphs describe our services and fees. Refer to the description of each
investment advisory service listed below for information on how we tailor our advisory services
to your individual needs. As used in this brochure, the words "we," "our," and "us" refer to
Mowery & Schoenfeld Wealth Management, LLC and the words "you," "your," and "client" refer
to you as either a client or prospective client of our firm.
B. Advisory Services Offered
Portfolio Management Services
In order to develop a portfolio that is appropriate for your financial circumstances we will
provide you with a financial plan based on an analysis of your individual needs.
We offer discretionary portfolio management services. Our investment advice is tailored to meet
our clients' needs and investment objectives. If you participate in our discretionary portfolio
management services, we require you to grant our firm discretionary authority to manage your
account. Discretionary authorization will allow us to determine the specific securities, and the
amount of securities, to be purchased or sold for your account without your approval prior to
each transaction. Discretionary authority is typically granted by the investment advisory
agreement you sign with our firm and the appropriate trading authorization forms.
You may limit our discretionary authority (for example, limiting the types of securities that can
be purchased or sold for your account) by providing our firm with your restrictions and
guidelines in writing.
In limited situations we may also offer non-discretionary portfolio management services. If you
enter into non-discretionary arrangements with our firm, we must obtain your approval prior to
executing any transactions on behalf of your account. You have an unrestricted right to decline
to implement any advice provided by our firm on a non-discretionary basis.
As part of our portfolio management services, we may use one or more third party money
managers (“TPMM”) to manage a portion of your account on a discretionary basis. The TPMM(s)
may use one or more of their model portfolios to manage your account. We will regularly
monitor the performance of your accounts managed by TPMM(s), and may hire and fire any
TPMM without your prior approval. TPMM fees paid by clients are in addition to the Firm’s fee
schedule.
As part of our portfolio management services, in addition to other types of investments (see
disclosures below in this section), we may invest your assets according to one or more model
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Part 2A of Form ADV: Mowery & Schoenfeld Wealth Management, LLC Brochure
Item 4: Advisory Business
portfolios developed by our firm. These models are designed for investors with varying degrees
of risk tolerance ranging from a more aggressive investment strategy to a more conservative
investment approach. Clients whose assets are invested in model portfolios may not set
restrictions on the specific holdings or allocations within the model, nor the types of securities
that can be purchased in the model. Nonetheless, clients may impose restrictions on investing in
certain securities or types of securities in their account. In such cases, this may prevent a client
from investing in certain models that are managed by our firm.
Clients should promptly notify us of any changes in such restrictions or in their personal
financial circumstances, investment objectives, goals and tolerance for risk. We will remind
clients of their obligation to inform us of any such changes or any restrictions that should be
imposed on the management of the client’s account. We will also contact clients at least
annually to determine whether there have been any changes in a client's personal financial
circumstances, investment objectives, and tolerance for risk.
IRA Rollover Considerations
As part of our investment advisory services to you, we may recommend that you withdraw the
assets from your employer's retirement plan and roll the assets over to an individual
retirement account (“IRA”) that we will manage on your behalf. If you elect to roll the assets to
an IRA that is subject to our management, we will charge you an asset-based fee as set forth
in the agreement you executed with our firm. This practice presents a conflict of interest
because persons providing investment advice on our behalf have an incentive to recommend
a rollover to you for the purpose of generating fee-based compensation rather than solely
based on your needs. You are under no obligation, contractually or otherwise, to complete the
rollover. Moreover, if you do complete the rollover, you are under no obligation to have the
assets in an IRA managed by our firm.
Many employers permit former employees to keep their retirement assets in their company
plan. Also, current employees can sometimes move assets out of their company plan before
they retire or change jobs. In determining whether to complete the rollover to an IRA, and to
the extent the following options are available, you should consider the costs and benefits of:
Leaving the funds in your employer's (former employer's) plan.
Moving the funds to a new employer’s retirement plan.
Cashing out and taking a taxable distribution from the plan.
Rolling the funds into an IRA rollover account.
Each of these options has advantages and disadvantages and before making a change we
encourage you to speak with your financial representative, CPA and/or tax attorney.
Selection of Other Advisers
We may recommend that you use the services of a third-party money manager (“TPMM”) to
manage all, or a portion of, your investment portfolio. After gathering information about your
financial situation and objectives, we may recommend that you engage a specific TPMM or
investment program. Factors that we take into consideration when making our
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Item 4: Advisory Business
recommendation(s) include, but are not limited to, the following: the TPMM's performance,
methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment
objectives. We will monitor the TPMM(s)' performance to ensure its management and
investment style remain aligned with your investment goals and objectives.
The TPMM(s) will actively manage your portfolio and will assume discretionary investment
authority over your account. We will assume discretionary authority to hire and fire TPMM(s)
and/or reallocate your assets to other TPMM(s) where we deem such action appropriate.
Retirement Plan Participant Account Management (Discretionary)
We use a third-party platform (Pontera Order Management System), subject to client consent, to
facilitate management of held away assets such as defined contribution plan participant
accounts, with discretion.
The platform allows us access to view and trade the account. We are not affiliated with the
Pontera platform in any way and receive no compensation from them for using such platform.
Upon consent of the client, a link will be provided to the client by Pontera allowing them to
connect an account(s) to the platform. Once client account(s) is connected to the platform, we
will review the current account allocations. When deemed necessary, we will rebalance the
account considering client investment goals and risk tolerance, and any change in allocations
will consider current economic and market trends. The goal is to improve account performance
over time, minimize loss during difficult markets, and manage internal fees that harm account
performance. Client account(s) will be reviewed at least quarterly and allocation changes will be
made as deemed necessary. We may provide these services or, alternatively, may arrange for the
Plan’s other providers to offer these services, as agreed upon between our firm and the client.
Financial Planning Services
Financial planning services are offered to all our portfolio management clients and included in
the overall AUM pricing (please see Item 5.A of this Brochure). We also offer standalone financial
planning for a fee.
Our financial planning services typically involve providing a variety of advisory services to clients
regarding the management of their financial resources based upon an analysis of their individual
needs. These services can range from broad-based financial planning to consultative or single
subject planning. If you retain our firm for financial planning services, we will meet with you to
gather information about your financial circumstances and objectives. We may also use financial
planning software to determine your current financial position and to define and quantify your
long-term goals and objectives. Once we specify those long-term objectives (both financial and
non-financial), we will develop shorter-term, targeted objectives. Once we review and analyze
the information you provide to our firm and the data derived from our financial planning
software, we will deliver a written plan to you, designed to help you achieve your stated financial
goals and objectives.
Financial plans are based on your financial situation at the time we present the plan to you, and
on the financial information you provide to us. You must promptly notify our firm if your
financial situation, goals, objectives, or needs change.
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Part 2A of Form ADV: Mowery & Schoenfeld Wealth Management, LLC Brochure
Item 4: Advisory Business
You are under no obligation to act on our financial planning recommendations. Should you
choose to act on any of our recommendations, you are not obligated to implement the financial
plan through any of our other investment advisory services. Moreover, you may act on our
recommendations by placing securities transactions with any brokerage firm.
We also offer financial consulting services that primarily involve advising clients on specific
financial-related topics. The topics we address may include, but are not limited to, risk
assessment/management, investment planning, financial organization, or financial decision
making/negotiation.
Retirement Plan Advisory Services
We provide various consulting services to qualified employee benefit plans and their fiduciaries.
This suite of institutional services is designed to assist plan sponsors in structuring, managing
and optimizing their corporate retirement plans. Each engagement is individually negotiated
and customized, and may include any or all of the following services.
Fiduciary Services
Service Level 1
We will, on a discretionary basis, select the designated diversified investment options for the
Plan from which Plan participants may choose. We may also create specific asset allocation
models (the “Models”) comprised of any and/or all of the designated investment alternatives.
The designated investment options and the Models are subject to change at our discretion.
We will monitor the Plan investment options on an ongoing and continuous basis and will be
responsible for making additions/deletions. Sponsor must approve the QDIA.
Service Level 2
We will provide the Sponsor and the Plan with the recommended diversified investment
options for the Plan from which Plan participants may choose. We may also create specific
asset allocation models (the “Models”) comprised of any and/or all of the designated
investment alternatives. The Sponsor maintains absolute discretion as to whether or not to
accept any of our recommendations, including the Models. Except for Models (for which we
will retain ongoing discretionary authority for as long as approved for the Plan by the
Sponsor), we will monitor the designated investment alternatives offered by the Plan on at
least a quarterly basis, and, to the extent applicable, make recommendations to the Sponsor
for additions/deletions.
Service Level 3
We will provide the Sponsor and the Plan with recommended diversified investment options
(which do not include the Models) from which Plan participants may choose. The Sponsor
maintains absolute discretion as to whether or not to accept any of our recommendations.
We will monitor the designated investment alternatives offered by the Plan on at least a
quarterly basis, and, to the extent applicable, make recommendations to the Sponsor for
additions/deletions.
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Part 2A of Form ADV: Mowery & Schoenfeld Wealth Management, LLC Brochure
Item 4: Advisory Business
Additional Fiduciary Services
QDIA – We will recommend a qualified default investment alternative (“QDIA”) as defined in
Section 404(c)(5) of ERISA and related regulations, in which a Plan participant’s assets will be
invested in the absence of an affirmative election by a Plan participant. We will also monitor,
evaluate, and, if appropriate, recommend changes to the QDIA. Sponsor must approve the
QDIA regardless of selecting Service Level 1 above.
Investment Policy Statement – We will revise existing (and/or develop and maintain) an
Investment Policy Statement establishing the investment policies and objectives for the Plan,
setting forth the asset classes and investment categories to be offered under the Plan, and
providing the criteria and standards for selecting and monitoring such assets.
Non-Fiduciary Services
Participant Education – We will provide Plan participants with up to four (4) annual general
informational seminars, to include materials which describe the various investment alternatives
available under the Plan, information about investing generally, including information about
different types of investments, information about different investment allocation strategies,
including information about historical returns, and interactive materials designed to help
participants identify appropriate investment strategy.
Miscellaneous
Use of Mutual and Exchange Traded Funds: We utilize mutual funds and exchange traded
funds for our client portfolios. In addition to our investment advisory fee described below, and
transaction and/or custodial fees discussed above, clients will also incur, relative to all mutual
fund and exchange traded fund purchases, charges imposed at the fund level (e.g.,
management fees and other fund expenses). The mutual funds and exchange traded funds we
utilize are generally available directly to the public. Thus, a client can generally obtain the
funds we recommend or utilize independent of engaging us as an investment advisor.
However, if a prospective client does so, then they will not receive our initial and ongoing
investment advisory services.
Please Note - Use of DFA Mutual Funds: We utilize the mutual funds issued by
Dimensional Fund Advisors (“DFA”). DFA funds are generally only available through
registered investment advisers approved by DFA. Thus, if the client was to terminate our
services, and transition to another adviser who has not been approved by DFA to utilize
DFA funds, restrictions regarding additional purchases of, or reallocation among other
DFA funds, will generally apply.
Cash Positions: We continue to treat cash as an asset class. As such, unless we determine to
the contrary, all cash positions (money markets, etc.) shall continue to be included as part of
assets under management for purposes of calculating our advisory fee. At any specific point in
time, depending upon perceived or anticipated market conditions/events (there being no
guarantee that such anticipated market conditions/events will occur), we may maintain cash
positions for defensive purposes. In addition, while assets are maintained in cash, such
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Item 4: Advisory Business
amounts could miss market advances. Depending upon current yields, at any point in time, our
advisory fee could exceed the interest paid by the client’s money market fund.
Inverse/Enhanced Market Strategies: We may utilize long and short mutual funds and/or
exchange traded funds that are designed to perform in either an: (1) inverse relationship to
certain market indices (at a rate of 1 or more times the inverse [opposite] result of the
corresponding index) as an investment strategy and/or for the purpose of hedging against
downside market risk; and (2) enhanced relationship to certain market indices (at a rate of 1 or
more times the actual result of the corresponding index) as an investment strategy and/or for
the purpose of increasing gains in an advancing market. There can be no assurance that any
such strategy will prove profitable or successful. To the contrary, such funds and/or
strategy(ies) can suffer substantial losses. In light of these enhanced risks/rewards, a client may
direct us, in writing, not to employ any or all such strategies for his/her/their/its accounts. In
light of these enhanced risks, a client may direct us, in writing, not to employ any or all such
strategies for the client’s account.
Borrowing Against Assets/Risks: A client who has a need to borrow money could determine to
do so by using:
Margin - The account custodian or broker-dealer lends money to the client. The
custodian charges the client interest for the right to borrow money, and uses the assets
in the client’s brokerage account as collateral; and,
Pledged Assets Loan - In consideration for a lender (i.e., a bank, etc.) to make a loan to
the client, the client pledges investment assets held at the account custodian as
collateral.
These above-described collateralized loans are generally utilized because they typically
provide more favorable interest rates than standard commercial loans. These types of
collateralized loans can assist with a pending home purchase, permit the retirement of more
expensive debt, or enable borrowing in lieu of liquidating existing account positions and
incurring capital gains taxes. However, such loans are not without potential material risk to the
client’s investment assets. The lender (i.e., custodian, bank, etc.) will have recourse against the
client’s investment assets in the event of loan default or if the assets fall below a certain level.
For this reason, we do not recommend such borrowing unless it is for specific short-term
purposes (i.e., a bridge loan to purchase a new residence). We do not recommend such
borrowing for investment purposes (i.e., to invest borrowed funds in the market). Regardless, if
the client was to determine to utilize margin or a pledged assets loan, the following economic
benefits would inure to us:
by taking the loan rather than liquidating assets in the client’s account, we continue to
earn a fee on such Account assets; and,
if the client invests any portion of the loan proceeds in an account to be managed by
us, we will receive an advisory fee on the invested amount; and,
if our advisory fee is based upon the higher margined account value, we will earn a
correspondingly higher advisory fee. This could provide us with a disincentive to
encourage the client to discontinue the use of margin.
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Item 4: Advisory Business
Please Note: The Client must accept the above risks and potential corresponding
consequences associated with the use of margin or a pledged assets loan.
Cybersecurity Risk: The information technology systems and networks that we and our third-
party service providers use to provide services to our clients employ various controls that are
designed to prevent cybersecurity incidents stemming from intentional or unintentional
actions that could cause significant interruptions in our operations and/or result in the
unauthorized acquisition or use of clients’ confidential or non-public personal information. In
accordance with Regulation S-P, we are committed to protecting the privacy and security of its
clients' non-public personal information by implementing appropriate administrative,
technical, and physical safeguards. We have established processes to mitigate the risks of
cybersecurity incidents, including the requirement to restrict access to such sensitive data and
to monitor its systems for potential breaches. The Firm and clients are nonetheless subject to
the risk of cybersecurity incidents that could ultimately cause them to incur financial losses
and/or other adverse consequences. Although we have established processes to reduce the
risk of cybersecurity incidents, there is no guarantee that these efforts will always be
successful, especially considering that we do not control the cybersecurity measures and
policies employed by third-party service providers, issuers of securities, broker-dealers,
qualified custodians, governmental and other regulatory authorities, exchanges, and other
financial market operators and providers. In compliance with Regulation S-P, we will notify
clients in the event of a data breach involving their non-public personal information as
required by applicable state and federal laws.
Investment Risk: Different types of investments involve varying degrees of risk, and it should
not be assumed that future performance of any specific investment or investment strategy
(including the investments and/or investment strategies recommended or undertaken by us)
will be profitable or equal any specific performance level(s).
Disclosure Brochure: A copy of our written Brochure as set forth on Part 2A of Form ADV and
Form CRS (Client Relationship Summary) shall be provided to each client prior to, or
contemporaneously with, the execution of an agreement between us and the client.
C. Client-Tailored Services and Client-Imposed Restrictions
Each client’s account will be managed on the basis of the client’s financial situation and
investment objectives and in accordance with any reasonable restrictions imposed by the client
on the management of the account—for example, restricting the type or amount of security to
be purchased in the portfolio.
D. Wrap Fee Programs
We do not participate in wrap fee programs. (Wrap fee programs offer services for one all-
inclusive fee.)
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Part 2A of Form ADV: Mowery & Schoenfeld Wealth Management, LLC Brochure
Item 4: Advisory Business
E. Client Assets Under Management
As of December 31, 2024, we provided continuous management services for $388,961,541 in
client assets on a discretionary basis and $197,865 in client assets on a non-discretionary basis,
for a total of $389,159,406 in assets under management.
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Part 2A of Form ADV: Mowery & Schoenfeld Wealth Management, LLC Brochure
Item 5: Fees and Compensation
Item 5: Fees and Compensation
A. Methods of Compensation and Fee Schedule
Portfolio Management Services
Our fee for portfolio management services is based on a percentage of the assets in your
account and is set forth in the below annual fee schedule.
Clients onboarded with Mowery & Schoenfeld after December 20, 2025 are billed at the following
schedule:
Accounts below $1,000,000 billed at 1.25%
For accounts over $1,000,000 the following fee schedule applies:
Assets Under Management
Annual Fee
First $2,000,000
Next $3,000,000
Next $5,000,000
Next $15,000,000
Above $25,000,000
1.00%
0.80%
0.60%
0.40%
0.30%
Clients onboarded with Mowery & Schoenfeld prior to December 20, 2025 will be grandfathered under
their then-existing fee schedules.
Our annual portfolio management fee is billed and payable, quarterly in advance, based on the
balance at end of the billing period. Our fee is negotiable based on the types of investments in
your portfolio. For example, if your accounts are primarily invested in fixed income products, the
negotiated fee may be lower than if your account is invested in equities.
If the portfolio management agreement is executed at any time other than the first day of a
calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is
payable in proportion to the number of days in the quarter for which you are a client. No fee
adjustments will be made for partial withdrawals or account appreciation or depreciation within
a billing period.
At our discretion, we may combine the account values of family members living in the same
household to determine the applicable advisory fee. For example, we may combine account
values for you and your minor children, joint accounts with your spouse, and other types of
related accounts. Combining account values may increase the asset total, which may result in
your paying a reduced advisory fee based on the available breakpoints in our fee schedule
stated above.
A client investment advisory agreement may be canceled by either party upon written notice.
Upon termination of any account, any unearned, prepaid fees will be promptly refunded.
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Part 2A of Form ADV: Mowery & Schoenfeld Wealth Management, LLC Brochure
Item 5: Fees and Compensation
Third-Party Money Manager Fees
Advisory fees charged by third-party money managers (“TPMM”) are separate and apart from
our advisory fees. Assets managed by TPMMs will be included in calculating our advisory fee,
which is based on the fee schedule set forth in the Portfolio Management Services section in this
brochure. Advisory fees that you pay to the TPMM are established and payable in accordance
with the brochure provided by each TPMM to whom you are referred. These fees may or may
not be negotiable. You should review the recommended TPMM's brochure and take into
consideration the TPMM's fees along with our fees to determine the total amount of fees
associated with this program.
You may be required to sign an agreement directly with the recommended TPMM(s). You may
terminate your advisory relationship with the TPMM according to the terms of your agreement
with the TPMM. You should review each TPMM's brochure for specific information on how you
may terminate your advisory relationship with the TPMM and how you may receive a refund, if
applicable. You should contact the TPMM directly for questions regarding your advisory
agreement with the TPMM.
Retirement Plan Advisory Services Fees
Each engagement is individually negotiated in advance and tailored to accommodate the needs
of the individual plan sponsor, as memorialized in the agreement, and the fees vary based on
the scope of the services to be rendered and assets to be managed.
Minimum Asset Requirement
In general, we require a minimum of $1,000,000 to open and maintain an advisory account. At
our discretion, we may waive this minimum account size. For example, we may waive the
minimum if you appear to have significant potential for increasing your assets under our
management. We may also combine account values for you and your minor children, joint
accounts with your spouse, and other types of related accounts to meet the stated minimum.
B. Client Payment of Fees
We generally require fees to be prepaid on a quarterly basis. Advisory fees will be deducted
directly from the client’s account provided that (i) the client provides written authorization to the
qualified custodian, and (ii) the qualified custodian sends the client a statement, at least
quarterly, indicating all amounts disbursed from the account.
The client is responsible for verifying the accuracy of the fee calculation, as the client’s custodian
will not verify the calculation.
C. Additional Client Fees Charged
All fees paid for investment advisory services are separate and distinct from the fees and
expenses charged by exchange-traded funds, mutual funds, separate account managers, broker-
dealers, and custodians retained by clients. Such fees and expenses are described in each
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Part 2A of Form ADV: Mowery & Schoenfeld Wealth Management, LLC Brochure
Item 5: Fees and Compensation
exchange-traded fund and mutual fund’s prospectus, each separate account manager’s Form
ADV and Brochure and Brochure Supplement or similar disclosure statement, and by any
broker-dealer or custodian retained by the client. Clients are advised to read these materials
carefully before investing. If a mutual fund also imposes sales charges, a client may pay an initial
or deferred sales charge as further described in the mutual fund’s prospectus. A client using our
firm may be precluded from using certain mutual funds or separate account managers because
they may not be offered by the client's custodian.
Please refer to the Brokerage Practices section (Item 12) for additional information regarding the
firm’s brokerage practices.
D. External Compensation for the Sale of Securities to Clients
Our advisory professionals are compensated primarily through a salary and bonus structure and
portion of advisory fees. Our advisory professionals may receive commission-based
compensation for the sale of insurance products. Please see Item 10.C. for detailed information
and conflicts of interest.
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Part 2A of Form ADV: Mowery & Schoenfeld Wealth Management, LLC Brochure
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
Item 6: Performance-Based Fees and Side-by-Side Management
We do not charge performance-based fees and therefore have no economic incentive to
manage clients’ portfolios in any way other than what is in their best interests.
Item 7: Types of Clients
We offer investment advisory services to individuals (other than high net worth individuals), high
net worth individuals, and pension and profit sharing plans (but not the plan participants).
In general, we require a minimum of $1,000,000 to open and maintain an advisory account. At
our discretion, we may waive this minimum account size. For example, we may waive the
minimum if you appear to have significant potential for increasing your assets under our
management. We may also combine account values for you and your minor children, joint
accounts with your spouse, and other types of related accounts to meet the stated minimum.
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
A. Methods of Analysis and Investment Strategies
Investing in securities involves a risk of loss that you, as a client, should be prepared to
bear.
Methods of Analysis
We use a variety of sources of data to conduct our economic, investment and market analysis,
which may include financial newspapers and magazines, economic and market research
materials prepared by others, conference calls hosted by mutual funds, corporate rating services,
annual reports, prospectuses, and company press releases. It is important to keep in mind that
there is no specific approach to investing that guarantees success or positive returns; investing
in securities involves risk of loss that clients should be prepared to bear.
Our investment adviser representatives are responsible for identifying and implementing the
methods of analysis used in formulating investment recommendations to clients. The methods
of analysis may include quantitative methods for optimizing client portfolios, computer-based
risk/return analysis, technical analysis, and statistical and/or computer models utilizing long-
term economic criteria.
Optimization involves the use of mathematical algorithms to determine the appropriate
mix of assets given the firm’s current capital market rate assessment and a particular
client’s risk tolerance.
Quantitative methods include analysis of historical data such as price and volume
statistics, performance data, standard deviation and related risk metrics, how the security
performs relative to the overall stock market, earnings data, price to earnings ratios, and
related data.
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Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
Technical analysis involves charting price and volume data as reported by the exchange
where the security is traded to look for price trends.
Computer models may be used to derive the future value of a security based on
assumptions of various data categories such as earnings, cash flow, profit margins, sales,
and a variety of other company specific metrics.
In addition, we review research material prepared by others, as well as corporate filings,
corporate rating services, and a variety of financial publications. We may employ outside
vendors or utilize third-party software to assist in formulating investment recommendations to
clients.
Mutual Funds, Individual Securities, Third-Party Separate Account Managers, and
Pooled Investment Vehicles
We may recommend ”institutional share class” mutual funds, individual securities (including
fixed income instruments), and pooled investment vehicles. We may also assist the client in
selecting one or more appropriate manager(s) for all or a portion of the client’s portfolio. Such
managers will typically manage assets for clients who commit to the manager a minimum
amount of assets established by that manager—a factor that we will take into account when
recommending managers to clients.
Although we will seek to select only separate account managers who will invest clients' assets
with the highest level of integrity, our selection process cannot ensure that money managers will
perform as desired, and we will have no control over the day-to-day operations of any of the
selected managers. We would not necessarily be aware of certain activities at the underlying
manager level, including without limitation a manager's engaging in unreported risks,
investment “style drift,” or even regulatory breaches or fraud.
A description of the criteria to be used in formulating an investment recommendation for
mutual funds, ETFs, individual securities (including fixed-income securities), managers, and
pooled investment vehicles is set forth below.
We have formed relationships with third-party vendors that
provide a technological platform for separate account management
prepare performance reports
perform or distribute research of individual securities
perform billing and certain other administrative tasks
We may utilize additional independent third parties to assist us in recommending and
monitoring individual securities, mutual funds, managers, and pooled investment vehicles to
clients as appropriate under the circumstances.
We review certain quantitative and qualitative criteria related to mutual funds and managers and
to formulate investment recommendations to our clients. Quantitative criteria may include
the performance history of a mutual fund or manager evaluated against that of its peers
and other benchmarks
an analysis of risk-adjusted returns
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Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
an analysis of the manager’s contribution to the investment return (e.g., manager’s
alpha), standard deviation of returns over specific time periods, sector and style analysis
the fund, sub-advisor or manager’s fee structure
the relevant portfolio manager’s tenure
Qualitative criteria used in selecting/recommending mutual funds or managers include the
investment objectives and/or management style and philosophy of a mutual fund or manager; a
mutual fund or manager’s consistency of investment style; and employee turnover and efficiency
and capacity.
Quantitative and qualitative criteria related to mutual funds and managers are reviewed by us
on a quarterly basis or such other interval as appropriate under the circumstances. In addition,
mutual funds or managers are reviewed to determine the extent to which their investments
reflect efforts to time the market, or evidence style drift such that their portfolios no longer
accurately reflect the particular asset category attributed to the mutual fund or manager (both
of which are negative factors in implementing an asset allocation structure).
We may negotiate reduced account minimum balances and reduced fees with managers under
various circumstances (e.g., for clients with minimum level of assets committed to the manager
for specific periods of time, etc.). There can be no assurance that clients will receive any reduced
account minimum balances or fees, or that all clients, even if apparently similarly situated, will
receive any reduced account minimum balances or fees available to some other clients. Also,
account minimum balances and fees may significantly differ between clients. Each client’s
individual needs and circumstances will determine portfolio weighting, which can have an
impact on fees given the funds or managers utilized. We will endeavor to obtain equal
treatment for our clients with funds or managers, but cannot assure equal treatment.
We will regularly review the activities of mutual funds and managers utilized for the client.
Clients that engage managers or who invest in mutual funds should first review and understand
the disclosure documents of those managers or mutual funds, which contain information
relevant to such retention or investment, including information on the methodology used to
analyze securities, investment strategies, fees and conflicts of interest. Similarly, clients qualified
to invest in pooled investment vehicles should review the private placement memoranda or
other disclosure materials relating to such vehicles before making a decision to invest.
Material Risks of Investment Instruments
We may invest in open-end mutual funds and exchange-traded funds for the vast majority of
our clients. In addition, for certain clients, we may effect transactions in the following types of
securities:
Equity securities
Mutual fund securities
Exchange-traded funds
Fixed income securities
Private placements
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Part 2A of Form ADV: Mowery & Schoenfeld Wealth Management, LLC Brochure
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
Pooled investment vehicles
Equity Securities
Investing in individual companies involves inherent risk. The major risks relate to the
company’s capitalization, quality of the company’s management, quality and cost of the
company’s services, the company’s ability to manage costs, efficiencies in the manufacturing
or service delivery process, management of litigation risk, and the company’s ability to create
shareholder value (i.e., increase the value of the company’s stock price). Foreign securities, in
addition to the general risks of equity securities, have geopolitical risk, financial transparency
risk, currency risk, regulatory risk and liquidity risk.
Mutual Fund Securities
Investing in mutual funds carries inherent risk. The major risks of investing in a mutual fund
include the quality and experience of the portfolio management team and its ability to create
fund value by investing in securities that have positive growth, the amount of individual
company diversification, the type and amount of industry diversification, and the type and
amount of sector diversification within specific industries. In addition, mutual funds tend to be
tax inefficient and therefore investors may pay capital gains taxes on fund investments while
not having yet sold the fund.
Exchange-Traded Funds (“ETFs”)
ETFs are investment companies whose shares are bought and sold on a securities exchange.
An ETF holds a portfolio of securities designed to track a particular market segment or index.
Some examples of ETFs are SPDRs®, streetTRACKS®, DIAMONDSSM, NASDAQ 100 Index
Tracking StockSM (“QQQs SM”) iShares® and VIPERs®. ETFs have embedded expenses that the
client indirectly bears.
Investing in ETFs involves risk. Specifically, ETFs, depending on the underlying portfolio and its
size, can have wide price (bid and ask) spreads, thus diluting or negating any upward price
movement of the ETF or enhancing any downward price movement. Also, ETFs require more
frequent portfolio reporting by regulators and are thereby more susceptible to actions by
hedge funds that could have a negative impact on the price of the ETF. Certain ETFs may
employ leverage, which creates additional volatility and price risk depending on the amount of
leverage utilized, the collateral and the liquidity of the supporting collateral.
Further, the use of leverage (i.e., employing the use of margin) generally results in additional
interest costs to the ETF. Certain ETFs are highly leveraged and therefore have additional
volatility and liquidity risk. Volatility and liquidity can severely and negatively impact the price
of the ETF’s underlying portfolio securities, thereby causing significant price fluctuations of the
ETF.
Fixed Income Securities
Fixed income securities carry additional risks than those of equity securities described above.
These risks include the company’s ability to retire its debt at maturity, the current interest rate
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Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
environment, the coupon interest rate promised to bondholders, legal constraints,
jurisdictional risk (U.S or foreign) and currency risk. If bonds have maturities of ten years or
greater, they will likely have greater price swings when interest rates move up or down. The
shorter the maturity the less volatile the price swings. Foreign bonds have liquidity and
currency risk.
Private Placements
Private placements carry significant risk in that companies using the private placement market
conduct securities offerings that are exempt from registration under the federal securities laws,
which means that investors do not have access to public information and such investors are
not provided with the same amount of information that they would receive if the securities
offering was a public offering. Moreover, many companies using private placements do so to
raise equity capital in the start-up phase of their business, or require additional capital to
complete another phase in their growth objective. In addition, the securities issued in
connection with private placements are restricted securities, which means that they are not
traded on a secondary market, such as a stock exchange, and they are thus illiquid and cannot
be readily converted to cash.
Pooled Investment Vehicles
A pooled investment vehicle, such as a commodity pool or investment company, is generally
offered only to investors who meet specified suitability, net worth and annual income criteria.
Pooled investment vehicles sell securities through private placements and thus are illiquid and
subject to a variety of risks that are disclosed in each pooled investment vehicle’s confidential
private placement memorandum or disclosure document. Investors should read these
documents carefully and consult with their professional advisors prior to committing
investment dollars. Because many of the securities involved in pooled investment vehicles do
not have transparent trading markets from which accurate and current pricing information can
be derived, or in the case of private equity investments where portfolio security companies are
privately held with no publicly traded market, the firm will be unable to monitor or verify the
accuracy of such performance information.
B. Investment Strategy and Method of Analysis Material Risks
Our investment strategy is custom-tailored to the client’s goals, investment objectives, risk
tolerance, and personal and financial circumstances.
Margin Leverage
Although we, as a general business practice, do not utilize leverage, there may be instances in
which exchange-traded funds, other separate account managers and, in very limited
circumstances, we will utilize leverage. In this regard please review the following:
The use of margin leverage enhances the overall risk of investment gain and loss to the client’s
investment portfolio. For example, investors are able to control $2 of a security for $1. So if the
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Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
price of a security rises by $1, the investor earns a 100% return on their investment. Conversely,
if the security declines by $.50, then the investor loses 50% of their investment.
The use of margin leverage entails borrowing, which results in additional interest costs to the
investor.
Broker-dealers who carry customer accounts require a minimum equity requirement when
clients utilize margin leverage. The minimum equity requirement is stated as a percentage of the
value of the underlying collateral security with an absolute minimum dollar requirement. For
example, if the price of a security declines in value to the point where the excess equity used to
satisfy the minimum requirement dissipates, the broker-dealer will require the client to deposit
additional collateral to the account in the form of cash or marketable securities. A deposit of
securities to the account will require a larger deposit, as the security being deposited is included
in the computation of the minimum equity requirement. In addition, when leverage is utilized
and the client needs to withdraw cash, the client must sell a disproportionate amount of
collateral securities to release enough cash to satisfy the withdrawal amount based upon similar
reasoning as cited above.
Regulations concerning the use of margin leverage are established by the Federal Reserve Board
and vary if the client’s account is held at a broker-dealer versus a bank custodian. Broker-dealers
and bank custodians may apply more stringent rules as they deem necessary.
Short-Term Trading
Although we, as a general business practice, do not utilize short-term trading, there may be
instances in which short-term trading may be necessary or an appropriate strategy. In this
regard, please read the following:
There is an inherent risk for clients who trade frequently in that high-frequency trading creates
substantial transaction costs that in the aggregate could negatively impact account
performance.
Short Selling
We generally do not engage in short selling but reserve the right to do so in the exercise of our
sole judgment. Short selling involves the sale of a security that is borrowed rather than owned.
When a short sale is effected, the investor is expecting the price of the security to decline in
value so that a purchase or closeout of the short sale can be effected at a significantly lower
price. The primary risks of effecting short sales are the availability to borrow the stock, the
unlimited potential for loss, and the requirement to fund any difference between the short credit
balance and the market value of the security.
Option Strategies
Various option strategies give the holder the right to acquire or sell underlying securities at the
contract strike price up until expiration of the option. Each contract is worth 100 shares of the
underlying security. Options entail greater risk but allow an investor to have market exposure to
a particular security or group of securities without the capital commitment required to purchase
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Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
the underlying security or groups of securities. In addition, options allow investors to hedge
security positions held in the portfolio. For detailed information on the use of options and
option strategies, please contact the Options Clearing Corporation for the current Options Risk
Disclosure Statement.
As part of our investment strategy, we may employ the following option strategies:
Covered call writing
Long call options purchases
Long put options purchases
Collars
Exchange fund replication
Covered Call Writing
Covered call writing is the sale of in-, at-, or out-of-the-money call option against a long
security position held in the client portfolio. This type of transaction is used to generate
income. It also serves to create downside protection in the event the security position declines
in value. Income is received from the proceeds of the option sale. Such income may be
reduced to the extent it is necessary to buy back the option position prior to its expiration.
This strategy may involve a degree of trading velocity, transaction costs and significant losses
if the underlying security has volatile price movement. Covered call strategies are generally
suited for companies with little price volatility.
Long Call Option Purchases
Long call option purchases allow the option holder to be exposed to the general market
characteristics of a security without the outlay of capital necessary to own the security. Options
are wasting assets and expire (usually within nine months of issuance), and as a result can
expose the investor to significant loss.
Long Put Option Purchases
Long put option purchases allow the option holder to sell or “put” the underlying security at
the contract strike price at a future date. If the price of the underlying security declines in
value, the value of the long put option increases. In this way long puts are often used to hedge
a long stock position. Options are wasting assets and expire (usually within nine months of
issuance), and as a result can expose the investor to significant loss.
C. Concentration Risks
There is an inherent risk for clients who have their investment portfolios heavily weighted in one
security, one industry or industry sector, one geographic location, one investment manager, one
type of investment instrument (equities versus fixed income). Clients who have diversified
portfolios, as a general rule, incur less volatility and therefore less fluctuation in portfolio value
than those who have concentrated holdings. Concentrated holdings may offer the potential for
higher gain, but also offer the potential for significant loss.
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Part 2A of Form ADV: Mowery & Schoenfeld Wealth Management, LLC Brochure
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 9: Disciplinary Information
A. Criminal or Civil Actions
There is nothing to report on this item.
B. Administrative Enforcement Proceedings
There is nothing to report on this item.
C. Self-Regulatory Organization Enforcement Proceedings
There is nothing to report on this item.
Item 10: Other Financial Industry Activities and Affiliations
A. Broker-Dealer or Representative Registration
Neither our firm nor its affiliates, employees, or independent contractors are registered broker-
dealers and do not have an application to register pending.
B. Futures or Commodity Registration
Neither our firm nor its affiliates are registered as a commodity firm, futures commission
merchant, commodity pool operator or commodity trading advisor and do not have an
application to register pending.
C. Material Relationships Maintained by this Advisory Business and
Conflicts of Interest
Mowery & Schoenfeld, LLC
We are affiliated with Mowery & Schoenfeld, LLC, through common control and ownership. If
you require accounting or tax services, we will recommend that you use the services of our
affiliate. Our advisory services are separate and distinct from the compensation paid to our
affiliate for their services. This affiliated firm is otherwise regulated by the professional
organizations to which it belongs and must comply with the rules of those organizations. These
rules may prohibit paying or receiving referral fees to or from investment advisers that are not
members of the same organization.
Referral arrangements with an affiliated entity present a conflict of interest for us because we
may have a direct or indirect financial incentive to recommend an affiliated firm’s services. While
we believe that compensation charged by an affiliated firm is competitive, such compensation
may be higher than fees charged by other firms providing the same or similar services. You are
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Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
under no obligation to use the services of any firm we recommend, whether affiliated or
otherwise, and may obtain comparable services and/or lower fees through other firms.
Insurance Sales
Certain managers, members, and registered employees of our firm are licensed insurance agents
and may recommend insurance products offered by such carriers for whom they function as
agents and receive a commission for doing so. Please be advised there is a conflict of interest in
that there is an economic incentive to recommend insurance and other products of such
carriers. Please also be advised that we strive to put our clients’ interests first and foremost, and
clients may utilize any insurance carrier or insurance agency they desire.
D. Recommendation or Selection of Other Investment Advisors and
Conflicts of Interest
We may engage third-party investment managers to manage client accounts. Please note that
third-party manager fees will be in addition to the fee we charge for our advisory services. You
are under no obligation to use any third-party provider recommended by us and may use the
provider of your choice.
Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
A. Code of Ethics Description
In accordance with the Advisers Act, we have adopted policies and procedures designed to
detect and prevent insider trading. In addition, we have adopted a Code of Ethics (the “Code”).
Among other things, the Code includes written procedures governing the conduct of our firm’s
advisory and access persons. The Code also imposes certain reporting obligations on persons
subject to the Code. The Code and applicable securities transactions are monitored by our chief
compliance officer. We will send clients a copy of our Code of Ethics upon written request.
We have policies and procedures in place to ensure that the interests of our clients are given
preference over those of our firm, our affiliates and our employees. For example, there are
policies in place to prevent the misappropriation of material non-public information, and such
other policies and procedures reasonably designed to comply with federal and state securities
laws.
B. Investment Recommendations Involving a Material Financial Interest and
Conflicts of Interest
We do not engage in principal trading (i.e., the practice of selling stock to advisory clients from a
firm’s inventory or buying stocks from advisory clients into a firm’s inventory). In addition, we do
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Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
not recommend any securities to advisory clients in which we have some proprietary or
ownership interest.
C. Advisory Firm Purchase or Sale of Same Securities Recommended to
Clients and Conflicts of Interest
Our firm, its affiliates, employees and their families, trusts, estates, charitable organizations and
retirement plans established by it may purchase or sell the same securities as are purchased or
sold for clients in accordance with its Code of Ethics policies and procedures. The personal
securities transactions by advisory representatives and employees may raise potential conflicts
of interest when they trade in a security that is:
owned by the client, or
considered for purchase or sale for the client.
Such conflict generally refers to the practice of front-running (trading ahead of the client), which
we specifically prohibit. We have adopted policies and procedures that are intended to address
these conflicts of interest. These policies and procedures:
require our advisory representatives and employees to act in the client’s best interest
prohibit fraudulent conduct in connection with the trading of securities in a client
account
prohibit employees from personally benefitting by causing a client to act, or fail to act in
making investment decisions
prohibit the firm or its employees from profiting or causing others to profit on
knowledge of completed or contemplated client transactions
allocate investment opportunities in a fair and equitable manner
provide for the review of transactions to discover and correct any trades that result in an
advisory representative or employee benefitting at the expense of a client.
Advisory representatives and employees must follow our firm’s procedures when purchasing or
selling the same securities purchased or sold for the client.
D. Client Securities Recommendations or Trades and Concurrent Advisory
Firm Securities Transactions and Conflicts of Interest
Our firm, its affiliates, employees and their families, trusts, estates, charitable organizations, and
retirement plans established by it may effect securities transactions for their own accounts that
differ from those recommended or effected for other of our clients. We will make a reasonable
attempt to trade securities in client accounts at or prior to trading the securities in our affiliate,
corporate, employee or employee-related accounts. Trades executed the same day will likely be
subject to an average pricing calculation. It is our policy to place the clients’ interests above
those of our firm and our employees.
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Part 2A of Form ADV: Mowery & Schoenfeld Wealth Management, LLC Brochure
Item 12: Brokerage Practices
Item 12: Brokerage Practices
A. Factors Used to Select Broker-Dealers for Client Transactions
Custodian Recommendations
We may recommend that clients establish brokerage accounts with Fidelity Institutional division
of Fidelity Investments or the Schwab Advisor Services division of Charles Schwab & Co., Inc.,
members SIPC/FINRA (hereinafter collectively referred to as “custodian”), to maintain custody of
clients’ assets and to effect trades for their accounts. Although we may recommend that clients
establish accounts at the custodian, it is the client’s decision to custody assets with the
custodian. We are independently owned and operated and not affiliated with custodian. For
client accounts maintained in its custody, the custodian generally does not charge separately for
custody services but is compensated by account holders through commissions and other
transaction-related or asset-based fees for securities trades that are executed through the
custodian or that settle into custodian accounts.
We consider the financial strength, reputation, operational efficiency, cost, execution capability,
level of customer service, and related factors in recommending broker-dealers or custodians to
advisory clients.
In certain instances and subject to our approval, we will recommend to clients certain other
broker-dealers and/or custodians based on the needs of the individual client, and taking into
consideration the nature of the services required, the experience of the broker-dealer or
custodian, the cost and quality of the services, and the reputation of the broker-dealer or
custodian. The final determination to engage a broker-dealer or custodian recommended by us
will be made by and in the sole discretion of the client. The client recognizes that broker-dealers
and/or custodians have different cost and fee structures and trade execution capabilities. As a
result, there may be disparities with respect to the cost of services and/or the transaction prices
for securities transactions executed on behalf of the client. Clients are responsible for assessing
the commissions and other costs charged by broker-dealers and/or custodians.
How We Select Brokers/Custodians to Recommend
We seek to recommend a custodian/broker who will hold client assets and execute
transactions on terms that are overall most advantageous when compared to other available
providers and their services. We consider a wide range of factors, including, among others, the
following:
combination of transaction execution services along with asset custody services
(generally without a separate fee for custody)
capability to execute, clear, and settle trades (buy and sell securities for client accounts)
capabilities to facilitate transfers and payments to and from accounts (wire transfers,
check requests, bill payment, etc.)
breadth of investment products made available (stocks, bonds, mutual funds, exchange-
traded funds (ETFs), etc.)
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Item 12: Brokerage Practices
availability of investment research and tools that assist us in making investment
decisions
quality of services
competitiveness of the price of those services (commission rates, margin interest rates,
other fees, etc.) and willingness to negotiate them
reputation, financial strength, and stability of the provider
their prior service to us and our other clients
availability of other products and services that benefit us, as discussed below
Soft Dollar Arrangements
As a result of our recommendation to clients to custody assets with a specific custodian, the
firm is deemed to be in receipt of soft dollar benefits from said custodian. These soft-dollar
benefits are in the form of institutional trading and custody services, other products and
services, and additional compensation received from custodians. Please refer to the following
items for disclosure of such benefits.
Institutional Trading and Custody Services
The custodian provides us with access to its institutional trading and custody services, which
are typically not available to the custodian’s retail investors. These services generally are
available to independent investment advisors on an unsolicited basis, at no charge to them so
long as a certain minimum amount of the advisor’s clients’ assets are maintained in accounts
at a particular custodian. The custodian’s brokerage services include the execution of securities
transactions, custody, research, and access to mutual funds and other investments that are
otherwise generally available only to institutional investors or would require a significantly
higher minimum initial investment.
Other Products and Services
Custodian also makes available other products and services that benefit our firm but may not
directly benefit our clients’ accounts. Many of these products and services may be used to
service all or some substantial number of our accounts, including accounts not maintained at
custodian. The custodian may also make available software and other technology that
provide access to client account data (such as trade confirmations and account
statements)
facilitate trade execution and allocate aggregated trade orders for multiple client
accounts
provide research, pricing and other market data
facilitate payment of our fees from its clients’ accounts
assist with back-office functions, recordkeeping and client reporting
The custodian may also offer other services intended to help us manage and further develop
our business enterprise. These services may include
compliance, legal and business consulting
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Item 12: Brokerage Practices
publications and conferences on practice management and business succession
access to employee benefits providers, human capital consultants and insurance
providers
The custodian may also provide other benefits such as educational events or occasional
business entertainment of our personnel. In evaluating whether to recommend that clients
custody their assets at the custodian, we may take into account the availability of some of the
foregoing products and services and other arrangements as part of the total mix of factors it
considers, and not solely the nature, cost or quality of custody and brokerage services
provided by the custodian, which may create a potential conflict of interest.
Independent Third Parties
The custodian may make available, arrange, and/or pay third-party vendors for the types of
services rendered to us. The custodian may discount or waive fees it would otherwise charge
for some of these services or all or a part of the fees of a third party providing these services
to us.
Additional Compensation Received from Custodians
We may participate in institutional customer programs sponsored by broker-dealers or
custodians. We may recommend these broker-dealers or custodians to clients for custody and
brokerage services. There is no direct link between our participation in such programs and the
investment advice we give to our clients, although we receive economic benefits through our
participation in the programs that are typically not available to retail investors. These benefits
may 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 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 advisory 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
Discounts on compliance, marketing, research, technology, and practice management
products or services provided to us by third-party vendors
The custodian may also pay for business consulting and professional services received by our
firm’s related persons, and may pay or reimburse expenses (including client transition
expenses, travel, lodging, meals and entertainment expenses for our personnel to attend
conferences). Some of the products and services made available by such custodian through its
institutional customer programs may benefit us but may not benefit our client accounts. These
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Item 12: Brokerage Practices
products or services may assist us in managing and administering client accounts, including
accounts not maintained at the custodian as applicable. Other services made available through
the programs are intended to help us manage and further develop our business enterprise.
The benefits received by our firm or our personnel through participation in these programs do
not depend on the amount of brokerage transactions directed to the broker-dealer.
We also participate in similar institutional advisor programs offered by other independent
broker-dealers or trust companies, and our continued participation may require us to maintain
a predetermined level of assets at such firms. In connection with our participation in such
programs, we will typically receive benefits similar to those listed above, including research,
payments for business consulting and professional services received by our firm’s related
persons, and reimbursement of expenses (including travel, lodging, meals and entertainment
expenses for our personnel to attend conferences sponsored by the broker-dealer or trust
company).
As part of our fiduciary duties to clients, we endeavor at all times to put the interests of our
clients first. Clients should be aware, however, that the receipt of economic benefits by our
firm or our related persons in and of itself creates a potential conflict of interest and may
indirectly influence our recommendation of broker-dealers for custody and brokerage services.
Brokerage for Client Referrals
We do not engage in the practice of directing brokerage commissions in exchange for the
referral of advisory clients.
Directed Brokerage
Our Recommendations
We typically recommend Fidelity or Schwab as custodian for clients’ funds and securities and
to execute securities transactions on our clients’ behalf.
Client-Directed Brokerage
Occasionally, clients may direct us to use a particular broker-dealer to execute portfolio
transactions for their account or request that certain types of securities not be purchased for
their account. Clients who designate the use of a particular broker-dealer should be aware that
they will lose any possible advantage we derive from aggregating transactions. Such client
trades are typically effected after the trades of clients who have not directed the use of a
particular broker-dealer. We lose the ability to aggregate trades with other advisory clients,
potentially subjecting the client to inferior trade execution prices as well as higher
commissions.
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Item 12: Brokerage Practices
B. Aggregating Securities Transactions for Client Accounts
Best Execution
Pursuant to the terms of our investment advisory agreement with clients, we have discretionary
authority to determine which securities are to be bought and sold, and the amount of such
securities. We recognize that the analysis of execution quality involves a number of factors, both
qualitative and quantitative. We will follow a process in an attempt to ensure that we are seeking
to obtain the most favorable execution under the prevailing circumstances when placing client
orders. These factors include but are not limited to the following:
The financial strength, reputation and stability of the broker
The efficiency with which the transaction is effected
The ability to effect prompt and reliable executions at favorable prices (including the
applicable dealer spread or commission, if any)
The availability of the broker to stand ready to effect transactions of varying degrees of
difficulty in the future
The efficiency of error resolution, clearance and settlement
Block trading and positioning capabilities
Performance measurement
Online access to computerized data regarding customer accounts
Availability, comprehensiveness, and frequency of brokerage and research services
Commission rates
The economic benefit to the client
Related matters involved in the receipt of brokerage services
Consistent with our fiduciary responsibilities, we seek to ensure that clients receive best
execution with respect to clients’ transactions by blocking client trades to reduce commissions
and transaction costs. To the best of our knowledge, these custodians provide high-quality
execution, and our clients do not pay higher transaction costs in return for such execution.
Commission rates and securities transaction fees charged to effect such transactions are
established by the client’s independent custodian and/or broker-dealer. Based upon our own
knowledge of the securities industry, we believe that such commission rates are competitive
within the securities industry. Lower commissions or better execution may be able to be
achieved elsewhere.
Security Allocation
Since we may be managing accounts with similar investment objectives, we may aggregate
orders for securities for such accounts. In such event, allocation of the securities so purchased or
sold, as well as expenses incurred in the transaction, is made by our firm in the manner we
consider to be the most equitable and consistent with our fiduciary obligations to such
accounts.
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Part 2A of Form ADV: Mowery & Schoenfeld Wealth Management, LLC Brochure
Item 12: Brokerage Practices
Our allocation procedures seek to allocate investment opportunities among clients in the fairest
possible way, taking into account the clients’ best interests. We will follow procedures to ensure
that allocations do not involve a practice of favoring or discriminating against any client or
group of clients. Account performance is never a factor in trade allocations.
Our advice to certain clients and entities and the action of our firm for those and other clients
are frequently premised not only on the merits of a particular investment, but also on the
suitability of that investment for the particular client in light of his or her applicable investment
objective, guidelines and circumstances. Thus, any action of our firm with respect to a particular
investment may, for a particular client, differ or be opposed to the recommendation, advice, or
actions of our firm to or on behalf of other clients.
Order Aggregation
Orders for the same security entered on behalf of more than one client will generally be
aggregated (i.e., blocked or bunched) subject to the aggregation being in the best interests of
all participating clients. Subsequent orders for the same security entered during the same
trading day may be aggregated with any previously unfilled orders. Subsequent orders may also
be aggregated with filled orders if the market price for the security has not materially changed
and the aggregation does not cause any unintended duration exposure. All clients participating
in each aggregated order will receive the average price and, subject to minimum ticket charges
and possible step outs, pay a pro rata portion of commissions.
To minimize performance dispersion, “strategy” trades should be aggregated and average
priced. However, when a trade is to be executed for an individual account and the trade is not in
the best interests of other accounts, then the trade will only be performed for that account. This
is true even if we believe that a larger size block trade would lead to best overall price for the
security being transacted.
Allocation of Trades
All allocations will be made prior to the close of business on the trade date. In the event an
order is “partially filled,” the allocation will be made in the best interests of all the clients in the
order, taking into account all relevant factors including, but not limited to, the size of each
client’s allocation, clients’ liquidity needs and previous allocations. In most cases, accounts will
get a pro forma allocation based on the initial allocation. This policy also applies if an order is
“over-filled.”
We act in accordance with our duty to seek best price and execution and will not continue any
arrangements if we determine that such arrangements are no longer in the best interest of our
clients.
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Part 2A of Form ADV: Mowery & Schoenfeld Wealth Management, LLC Brochure
Item 18: Financial Information
Item 13: Review of Accounts
A. Schedule for Periodic Review of Client Accounts or Financial Plans and
Advisory Persons Involved
Accounts are reviewed by the investment adviser representative servicing the client’s account.
The frequency of reviews is determined based on the client’s investment objectives, but reviews
are conducted no less frequently than semi-annually. More frequent reviews may also be
triggered by a change in the client’s investment objectives, tax considerations, large deposits or
withdrawals, large purchases or sales, loss of confidence in the underlying investment, or
changes in macro-economic climate.
B. Review of Client Accounts on Non-Periodic Basis
We may perform ad hoc reviews on an as-needed basis if there have been material changes in
the client’s investment objectives or risk tolerance, or a material change in how we formulate
investment advice.
C. Content of Client-Provided Reports and Frequency
We may report on a quarterly basis or at some other interval agreed upon with the client,
information on contributions and withdrawals in the client's investment portfolio, and the
performance of the client's portfolio measured against appropriate benchmarks (including
benchmarks selected by the client).
The client’s independent custodian provides account statements directly to the client no less
frequently than quarterly. The custodian’s statement is the official record of the client’s securities
account and supersedes any statements or reports created on behalf of the client by us.
Item 14: Client Referrals and Other Compensation
A. Economic Benefits Provided to the Advisory Firm from External Sources
and Conflicts of Interest
Custodians
We receive an economic benefit from our custodians (Fidelity or Schwab) in the form of the
support products and services they make available to us and other independent investment
advisors that have their clients maintain accounts at the custodian. These products and services,
how they benefit us, and the related conflicts of interest are described above in Item 12:
Brokerage Practices. The availability of custodians’ products and services to us is not based on
our giving particular investment advice, such as buying particular securities for our clients.
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Part 2A of Form ADV: Mowery & Schoenfeld Wealth Management, LLC Brochure
Item 18: Financial Information
Third-Party Service Providers
Please refer to the disclosures in Items 10 regarding referrals to third-party service providers. We
may receive economic benefits for referring clients to third-party service providers. You are
under no obligation to utilize any service provider recommended to you by our firm or our
affiliates.
B. Advisory Firm Payments for Client Referrals
Employees of our affiliate, Mowery & Schoenfeld, LLC, may recommend to clients our firm’s
financial services and receive a referral fee. The receipt of such compensation creates a conflict
of interest in that Mowery & Schoenfeld, LLC, has an economic interest to recommend our firm.
Please be advised that the payment of a referral fee does not increase the client’s advisory fee
paid to the firm.
We maintain one legacy solicitor agreement but do not accept any new client referrals.
Item 15: Custody
We are considered to have custody of client assets for purposes of the Advisers Act for the
following reasons:
The client authorizes us to instruct their custodian to deduct our advisory fees directly
from the client’s account. The custodian maintains actual custody of clients’ assets.
Our authority to direct client requests, utilizing standing instructions, for wire transfer of
funds for first-party money movement and third-party money movement (checks and/or
journals, ACH, Fed-wires). The firm has elected to meet the SEC’s seven conditions to
avoid the surprise custody exam, as outlined below:
1. 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.
2. 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.
3. 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.
4. The client has the ability to terminate or change the instruction to the client’s
qualified custodian.
5. 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.
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Part 2A of Form ADV: Mowery & Schoenfeld Wealth Management, LLC Brochure
Item 18: Financial Information
6. 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.
7. The client’s qualified custodian sends the client, in writing, an initial notice confirming
the instruction and an annual notice reconfirming the instruction.
Individual advisory clients will receive at least quarterly account statements directly from their
custodian containing a description of all activity, cash balances, and portfolio holdings in their
accounts. Clients are urged to compare the account balance(s) shown on their account
statements to the quarter-end balance(s) on their custodian's monthly statement. The
custodian’s statement is the official record of the account.
Item 16: Investment Discretion
Clients may grant a limited power of attorney to us with respect to trading activity in their
accounts by signing the appropriate custodian limited power of attorney form. In those cases,
we will exercise full discretion as to the nature and type of securities to be purchased and sold,
and the amount of securities for such transactions. Investment limitations may be designated by
the client as outlined in the investment advisory agreement. In addition, subject to the terms of
the investment advisory agreement, we may be granted discretionary authority for the retention
of independent third-party investment management firms. Investment limitations may be
designated by the client as outlined in the investment advisory agreement. Please see the
applicable third-party manager’s disclosure brochure for detailed information relating to
discretionary authority.
Item 17: Voting Client Securities
Other than for accounts managed by third-party managers or accounts where the client directs
the trading, we will vote proxies for clients utilizing the Broadridge proxy voting platform. We
owe certain fiduciary duties with respect to the voting of proxies. These fiduciary duties include
(i) the duty of care which is required to monitor corporate events and to vote the proxies, and
(ii) the duty of loyalty which is required to vote proxies in a manner consistent with the best
interests of the client and to put the client's interests before its own interests. In keeping with its
fiduciary duties, we have adopted a Proxy Voting Policy, which sets forth policies and
procedures designed to ensure that our votes each client's securities in the best interests of the
client.
We will be authorized to take action and render any advice with respect to the voting of proxies
for securities held in the client’s account. The firm utilizes a third-party service provider
(Broadridge) for recommendations with respect to proxy voting. Clients may contact us for
information about how we voted with respect to any of the securities held in their account.
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Part 2A of Form ADV: Mowery & Schoenfeld Wealth Management, LLC Brochure
Item 18: Financial Information
From time to time, securities held in the accounts of clients will be the subject of class action or
consumer antitrust class action litigation. we, in coordination with Broadridge asset recovery
services, will
determine if securities held by the client are subject to a pending or resolved class action
or consumer antitrust class action lawsuit;
evaluate a client’s eligibility to submit a claim to participate in the proceeds of a
securities class action settlement or verdict; and/or
initiate litigation to recover damages on behalf of clients who may have been injured as
a result of actions, misconduct, or negligence by corporate management of issuers
whose securities are held by clients.
Successful asset recovery by Broadridge for class action litigation results in Broadridge keeping
20% of the assets recovered. For successful asset recovery in consumer antitrust class action
litigation will result in Broadridge keeping 33% of the assets recovered.
As a general rule, we will vote all proxies relating to a particular proposal the same way for all
client accounts holding the security in accordance with our Proxy Voting Policy, unless a client
specifically instructs in writing to vote such client's securities otherwise. When making proxy
voting decisions, we may seek advice or assistance from third-party consultants, such as proxy
voting services or legal counsel. A copy of our Proxy Voting Policy will be provided upon receipt
of a written request.
Item 18: Financial Information
A. Balance Sheet
We do not require the prepayment of fees of $1,200 or more, six months or more in advance,
and as such are not required to file a balance sheet.
B. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability
to Meet Commitments to Clients
We do not have any financial issues that would impair our ability to provide services to clients.
C. Bankruptcy Petitions During the Past Ten Years
There is nothing to report on this item.
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Part 2A of Form ADV: Mowery & Schoenfeld Wealth Management, LLC Brochure