Overview
- Headquarters
- Mishicot, WI
- Total Firm Assets
- $148 million
- Average High-Net-Worth Client Portfolio Size
- $1.1 million
Fee Structure
Primary Fee Schedule (FORM ADV PART 2A - FIRM BROCHURE AND PART 2B OF FORM ADV: BROCHURE SUPPLEMENT)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | and above | 1.50% |
Minimum Annual Fee: $3,000
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $15,000 | 1.50% |
| $5 million | $75,000 | 1.50% |
| $10 million | $150,000 | 1.50% |
| $50 million | $750,000 | 1.50% |
| $100 million | $1,500,000 | 1.50% |
Clients
- High-Net-Worth Share of Firm Assets
- 42.32%
- Number of High-Net-Worth Clients
- 55
- Total Client Accounts
- 936
- Discretionary Accounts
- 899
- Non-Discretionary Accounts
- 37
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting, Educational Seminars
Regulatory Filings
- SEC CRD Number
- 306943
Primary Brochure: FORM ADV PART 2A - FIRM BROCHURE AND PART 2B OF FORM ADV: BROCHURE SUPPLEMENT (2026-08-28)
View Document Text
Item 1: Cover Page
Part 2A of Form ADV: Firm Brochure
August 28, 2026
524 E. Main Street
PO Box 341
Mishicot, WI 54228
(920)267-6710
muellerwealth.com
Branch Office Locations:
Sherwood Branch:
W579 Castle Drive, Suite B
Sherwood, WI 54169
Mishicot Branch:
524 E. Main Street
PO Box 341
Mishicot, WI 54228
Oshkosh Branch:
2390 State Rd 44, STE B1
Oshkosh, WI 54904
Firm Contact:
Ross Mueller
Managing Member & Chief Compliance Officer
This brochure provides information about the qualifications and business practices of Mueller
Wealth, LLC. If clients have any questions about the contents of this brochure, please contact us at
(920) 267-6710 or RossMueller@MuellerWealth.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 our firm is also available on the SEC’s website at
www.adviserinfo.sec.gov by searching CRD #306943.
Please note that the use of the term “registered investment adviser” and description of our firm
and/or our associates as “registered” does not imply a certain level of skill or training. Clients are
encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise
clients for more information on the qualifications of our firm and our employees.
Item 2: Material Changes
Mueller Wealth, LLC is required to make clients aware of information that has changed since the last
annual update to the Firm Brochure (“Brochure”) and that may be important to them. Clients can
then determine whether to review the brochure in its entirety or to contact us with questions about
the changes.
Since our last annual ADV filing on February 6, 2026, our firm has the following material changes to
disclose:
•
None
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Mueller Wealth, LLC
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 & Compensation ......................................................................................................................................................7
Item 6: Performance-Based Fees & Side-By-Side Management ................................................................................9
Item 7: Types of Clients & Account Requirements ...........................................................................................................9
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ........................................................................9
Item 9: Disciplinary Information ............................................................................................................................................ 20
Item 10: Other Financial Industry Activities & Affiliations....................................................................................... 20
Item 11: Code of Ethics, Participation or Interest in .................................................................................................... 21
Item 12: Brokerage Practices ................................................................................................................................................... 22
Item 13: Review of Accounts or Financial Plans ............................................................................................................. 23
Item 14: Client Referrals & Other Compensation........................................................................................................... 24
Item 15: Custody ............................................................................................................................................................................. 25
Item 16: Investment Discretion............................................................................................................................................... 26
Item 17: Voting Client Securities ............................................................................................................................................ 26
Item 18: Financial Information ................................................................................................................................................ 26
Item 19: Requirements for State-Registered Advisers ............................................................................................... 27
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Mueller Wealth, LLC
Item 4: Advisory Business
Our firm is dedicated to providing individuals and other types of clients with a wide array of
investment advisory services. Our firm is a limited liability company
formed under the laws of the
State of Wisconsin in 2018 and has been in business as an investment adviser since 2020. Our firm is
wholly owned by Ross Mueller.
The purpose of this Brochure is to disclose the conflicts of interest associated with the investment
transactions, compensation and any other matters related to investment decisions made by our firm
or its representatives. As a fiduciary, it is our duty to always act in the client’s best interest. This is
accomplished in part by knowing our client. Our firm has established a service-oriented advisory
practice with open lines of communication for many different types of clients to help meet their
financial goals while remaining sensitive to risk tolerance and time horizons. Working with clients to
understand their investment objectives while educating them about our process, facilitates the kind
of working relationship we value.
Types of Advisory Services Offered
Asset Management:
As part of our Asset Management service, a portfolio is created, consisting of individual stocks, bonds,
exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or
investments. The client’s individual investment strategy is tailored to their specific needs and may
include some or all of the previously mentioned securities. Portfolios will be designed to meet a
particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate
portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary,
rebalanced based upon the client’s individual needs, stated goals and objectives. Our firm uses a method
we call the Seatbelt™ Investment System, which involves the following four steps -- Step 1: Identify
persistent market trends (e.g. low interest rates). Step 2: Evaluate the best way to invest in that trend.
Step 3: Utilize our own proprietary quantitative analysis to possibly adjust and reduce risk proactively.
Step 4: Assess various asset classes for value and invest accordingly. For more information about our
investment strategies, please review Item 8 below.
Held Away Account Asset Management
We use a third-party platform (Pontera, formerly FeeX) to facilitate management of held away assets
such as defined contribution plan participant accounts, with discretion. The platform allows us to
avoid being considered to have custody of Client funds since we do not have direct access to Client log-
in credentials to affect trades. We are not affiliated with the platform in any way and receive no
compensation from them for using their platform. A link will be provided to the Client allowing them
to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser
will review the current account allocations. When deemed necessary, Adviser 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
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.
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Mueller Wealth, LLC
Financial Planning & Consulting:
Our firm provides a variety of standalone financial planning and consulting services to clients for the
management of financial resources based upon an analysis of current situation, goals, and objectives.
Financial planning services will typically involve preparing a financial plan or rendering a financial
consultation for clients based on the client’s financial goals and objectives. This planning or
consulting may encompass Investment Planning, Retirement Planning, Estate Planning, Charitable
Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study,
Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of
Credit Evaluation, or Business and Personal Financial Planning.
Written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients.
Implementation of the recommendations will be at the discretion of the client. Our firm provides
clients with a summary of their financial situation, and observations for financial planning
engagements. Financial consultations are not typically accompanied by a written summary of
observations and recommendations, as the process is less formal than the planning service. Assuming
that all the information and documents requested from the client are provided promptly, plans or
consultations are typically completed within 6 months of the client signing a contract with our firm.
Retirement Plan Consulting:
Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing
basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing,
monitoring and reviewing their company's participant-directed retirement plan. As the needs of the
plan sponsor dictate, areas of advising may include:
•
•
•
•
•
Establishing an Investment Policy Statement – Our firm will assist in the development of a
statement that summarizes the investment goals and objectives along with the broad
strategies to be employed to meet the objectives.
Investment Options – Our firm will work with the Plan Sponsor to evaluate existing
investment options and make recommendations for appropriate changes.
Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation
models to aid Participants in developing strategies to meet their investment objectives, time
horizon, financial situation and tolerance for risk.
Investment Monitoring – Our firm will monitor the performance of the investments and
notify the client in the event of over/underperformance and in times of market volatility.
Participant Education – Our firm will provide opportunities to educate plan participants
about their retirement plan offerings, different investment options, and general guidance on
allocation strategies.
In providing services for retirement plan consulting, our firm does not provide any advisory services
with respect to the following types of assets: employer securities, real estate (excluding real estate
funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other
illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement
plan consulting services shall be in compliance with the applicable state laws regulating retirement
consulting services. This applies to client accounts that are retirement or other employee benefit
plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide
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Mueller Wealth, LLC
services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section
3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to
the provision of services described therein.
American Funds Service:
Our firm may recommend a mutual fund only investment allocation offered through American Funds
consisting entirely of American Funds F-2 funds. Such accounts will be held direct at American Funds
and custodies with their affiliated custodian, Capital Bank and Trust. As part of this service, our firm
conducts at least one, but sometimes more than one meeting (in person, if possible, otherwise via
telephone conference) with clients in order to understand their current financial situation, existing
resources, financial goals, and tolerance for risk. Based on what is learned, an investment approach
is presented to the client, using American Funds (“AF”). The AF Funds are a family of no-load mutual
funds. Investment strategies utilizing AF are limited to mutual funds offered through the AF family of
funds. We will not evaluate any type of security other than mutual funds offered by AF. Each portfolio
will be initially designed to meet a particular investment goal, which we determine to be suitable to
the client’s circumstances. Once the appropriate portfolio has been determined, we review the
portfolio at least quarterly and if necessary, rebalance the portfolio based upon the client’s individual
needs, stated goals and objectives. Each client has the opportunity to place reasonable restrictions
on the types of investments to be held in the portfolio.
Tailoring of Advisory Services
Our firm offers individualized investment advice to our Asset Management clients. General
investment advice will be offered to our Financial Planning & Consulting, Retirement Plan Consulting
clients.
Each Asset Management client has the opportunity to place reasonable restrictions on the types of
investments to be held in the portfolio. Restrictions on investments in certain securities or types of
securities may not be possible due to the level of difficulty this would entail in managing the account.
Participation in Wrap Fee Programs
Our firm does not offer or sponsor a wrap fee program.
Class Action Lawsuits
Please note: our firm does not determine if securities held by Clients are the subject of a class action
lawsuit or whether Clients are eligible to participate in class action settlements or litigation nor does
our firm initiate or participate in litigation to recover damages on a Client’s behalf for injuries as a
result of actions, misconduct, or negligence by issuers of securities held by Clients.
Regulatory Assets Under Management
As of December 31, 2025, our firm has assets under management of $148,102,768 of which
$143,635,695 is managed on a discretionary basis and $4,467,073 is managed on a non-discretionary
basis.
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Mueller Wealth, LLC
Item 5: Fees & Compensation
Compensation for Our Advisory Services
Asset Management:
The maximum annual fee charged for this service will not exceed 1.50%. Fees to be assessed will be
outlined in the advisory agreement to be signed by the Client. Annualized fees are billed on a pro-
rata basis quarterly in advance based on the value of the account(s) on the last day of the previous
quarter. Fees are negotiable and will be deducted from client account(s). Adjustments will be made
for deposits and withdrawals during the quarter. In rare cases, our firm will agree to directly invoice.
As part of this process, Clients understand the following:
a)
b)
c)
Clients must provide our firm with written authorization permitting direct payment of
advisory fees from their account(s) maintained by a custodian who is independent of our
firm;
The account custodian sends a statement to the client, at least quarterly, showing all account
disbursements, including advisory fees.
Mueller has an annual “fee” minimum of $3,000 per household for those investing less than
200k as a household (Waived for households with more than $200,000 of assets with Mueller
Wealth.). For households that invest less than $200,000 with Mueller Wealth; this $3,000
planning fee is reduced by the assets under management fee. For example, if a client invests
$100,000, the asset management fee will be 1.50% according to the fee schedule above, which
equals $1,500. The remaining $1,500 ($3,000 - $1,500) will be charged for our services and
invoiced separately. This $3,000 is completely phased out once assets with Mueller Wealth
reach $200,000. A minimum of 75% of advisable assets must be managed by Mueller Wealth
if you are engaging us to manage a portion of assets.
Financial Planning & Consulting:
Our firm charges on an hourly or flat fee basis for financial planning and consulting services. The total
estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our
engagement with the client. The maximum hourly fee to be charged will not exceed $500. Flat fees
range from $1,500 to $25,000. Our firm requires payment in full for the Financial Plan upon execution
of the Agreement. The fee-paying arrangements will be determined on a case-by-case basis and will
be detailed in the signed consulting agreement. Our firm will not require a retainer exceeding $1,200
when services cannot be rendered within 6 months.
Retirement Plan Consulting:
Our Retirement Plan Consulting services are billed a fee based on the percentage of Plan assets under
management. The total estimated fee, as well as the ultimate fee charged, is based on the scope and
complexity of our engagement with the client. Retirement Plan Consulting fees are based on a
percentage of managed Plan assets will not exceed 1.50%. The fee-paying arrangements will be
determined on a case-by-case basis and will be detailed in the signed consulting agreement.
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Mueller Wealth, LLC
American Funds Service:
The annual fee charged for this service shall not exceed 1.50%. The annualized advisory fees are
billed on a pro-rata basis quarterly in arrears based on the value of the client’s account on the last
day of the previous quarter. Fees are not negotiable and will be deducted from the client’s account.
Fees may be lower than the noted percentages at each asset class based on the exact amount of the
investment and investment type where applicable. As part of the fee deduction process, the client is
made aware of the following:
a) Your independent custodian sends statements at least quarterly to you showing the market
values for each security included in the Assets and all disbursements in your account
including the amount of the advisory fees paid to us;
b) You provide authorization permitting us to be directly paid by these terms. We send our
invoice directly to the custodian;
c) It is the client’s responsibility to verify the calculation of advisory fees deducted from the
account; and
Other Types of Fees & Expenses
Unless otherwise waived by Mueller Wealth, each account or household shall be charged an annual
$40 platform fee, for access to Mueller Wealth’s resources, platform, and financial programs. Clients
will incur transaction fees for trades executed by their chosen custodian, via individual transaction
charges. These transaction fees are separate from our firm’s advisory fees and will be disclosed by
the chosen custodian. Clients may also pay holdings charges imposed by the chosen custodian for
certain investments, charges imposed directly by a mutual fund, index fund, or exchange traded fund,
which shall be disclosed in the fund’s prospectus (i.e., fund management fees, initial or deferred sales
charges, mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and
qualified retirement plan fees, and other fund expenses), mark-ups and mark-downs, spreads paid to
market makers, fees for trades executed away from custodian, wire transfer fees and other fees and
taxes on brokerage accounts and securities transactions. Our firm does not receive a portion of these
fees.
Financial Institution Consulting Services
Mueller Wealth receives a consulting fee based on the Assets Under Management from Brokerage
Customers who have provided written consent to a broker/dealer to receive the investment
consulting service from Mueller Wealth and have entered into a written advisory contract with
Mueller Wealth. The consulting fee is calculated from the Assets Under Management as of the end of
a calendar quarter period multiplied by the annualized rate which shall not exceed 1.50% of Assets
Under Management. The initial fee is paid only after the completion of one full calendar quarter
period following the date of the executed agreement with broker/dealers.
Termination & Refunds
Either party may terminate the advisory agreement signed with our firm for Asset Management
services in writing at any time. Upon notice of termination our firm will process a pro-rata refund of
the unearned portion of the advisory fees charged in advance. Mueller Wealth will not liquidate any
securities in the account unless instructed by the client to do so. In the event of a client’s death or
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Mueller Wealth, LLC
disability, Mueller Wealth will continue management of the account until we are notified of the
client’s death or disability and given alternative instructions by an authorized party.
Financial Planning & Consulting clients may terminate their agreement at any time before the
delivery of a financial plan by providing written notice. For purposes of calculating refunds, all work
performed by us up to the point of termination shall be calculated at the hourly fee currently in effect.
Clients will receive a pro-rata refund of unearned fees based on the time and effort expended by our
firm.
Either party to a Retirement Plan Consulting Agreement may terminate at any time by providing
written notice to the other party. Full refunds will only be made in cases where cancellation occurs
within 5 business days of signing an agreement. After 5 business days from initial signing, either
party must provide the other party 30 days written notice to terminate billing. Billing will terminate
30 days after receipt of termination notice. Clients will be charged on a pro-rata basis, which takes
into account work completed by our firm on behalf of the client. Clients will incur charges for bona
fide advisory services rendered up to the point of termination (determined as 30 days from receipt
of said written notice) and such fees will be due and payable.
Commissionable Securities Sales
Our firm and representatives do not sell securities for a commission in advisory accounts.
Item 6: Performance-Based Fees & Side-By-Side Management
Our firm does not charge performance-based fees.
Item 7: Types of Clients & Account Requirements
Our firm has the following types of clients:
•
•
•
•
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Individuals and High Net Worth Individuals;
Trusts, Estates or Charitable Organizations;
Pension and Profit-Sharing Plans;
Corporations, Limited Liability Companies and/or Other Business Types.
Broker/Dealer
Our firm does not have a minimum household requirement for assets under management.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
Our firm uses a method we call the Seatbelt™ Investment System, which involves the following four
steps -- Step 1: Identify persistent market trends (e.g., low interest rates). Step 2: Evaluate the best
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Mueller Wealth, LLC
way to invest in that trend. Step 3: Utilize our own proprietary quantitative analysis to possibly adjust
and reduce risk proactively. Step 4: Assess various asset classes for value and invest accordingly. In
order to carry out the above-mentioned strategies, we may use some, or all, of the following methods
of analysis in formulating our investment advice and/or managing client assets:
Charting:
In this type of technical analysis, our firm reviews charts of market and security activity in
an attempt to identify when the market is moving up or down and to predict when how long the trend
may last and when that trend might reverse.
Cyclical Analysis:
Statistical analysis of specific events occurring at a sufficient number of relatively
predictable intervals that they can be forecasted into the future. Cyclical analysis asserts that cyclical
forces drive price movements in the financial markets. Risks include that cycles may invert or
disappear and there is no expectation that this type of analysis will pinpoint turning points, instead
be used in conjunction with other methods of analysis.
Duration Constraints:
Our firm adhere to a discipline of generally maintaining duration within a
narrow band around benchmark duration in order to limit exposure to market risk. Our portfolio
management team rebalances client portfolios to their current duration targets on a periodic basis.
The risk of constraining duration is that the client may not participate fully in a large rally in bond
prices.
Fundamental Analysis:
The analysis of a business's financial statements (usually to analyze the
business's assets, liabilities, and earnings), health, and its competitors and markets. When analyzing
a stock, futures contract, or currency using fundamental analysis there are two basic approaches one
can use: bottom up analysis and top down analysis. The terms are used to distinguish such analysis
from other types of investment analysis, such as quantitative and technical. Fundamental analysis is
performed on historical and present data, but with the goal of making financial forecasts. There are
several possible objectives: (a) to conduct a company stock valuation and predict its probable price
evolution; (b) to make a projection on its business performance; (c) to evaluate its management and
make internal business decisions; (d) and/or to calculate its credit risk.; and (e) to find out the
intrinsic value of the share.
When the objective of the analysis is to determine what stock to buy and at what price, there are two
basic methodologies investors rely upon: (a) Fundamental analysis maintains that markets may
misprice a security in the short run but that the "correct" price will eventually be reached. Profits can
be made by purchasing the mispriced security and then waiting for the market to recognize its
"mistake" and reprice the security.; and (b) Technical analysis maintains that all information is
reflected already in the price of a security. Technical analysts analyze trends and believe that
sentiment changes predate and predict trend changes. Investors' emotional responses to price
movements lead to recognizable price chart patterns. Technical analysts also analyze historical
trends to predict future price movement. Investors can use one or both of these different but
complementary methods for stock picking. This presents a potential risk, as the price of a security
can move up or down along with the overall market regardless of the economic and financial factors
considered in evaluating the stock.
Quantitative Analysis:
The use of models, or algorithms, to evaluate assets for investment. The
process usually consists of searching vast databases for patterns, such as correlations among liquid
assets or price-movement patterns (trend following or mean reversion). The resulting strategies may
involve high-frequency trading. The results of the analysis are taken into consideration in the
decision to buy or sell securities and in the management of portfolio characteristics. A risk in using
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Mueller Wealth, LLC
quantitative analysis is that the methods or models used may be based on assumptions that prove to
be incorrect.
Qualitative Analysis:
A securities analysis that uses subjective judgment based on unquantifiable
information, such as management expertise, industry cycles, strength of research and development,
and labor relations. Qualitative analysis contrasts with quantitative analysis, which focuses on
numbers that can be found on reports such as balance sheets. The two techniques, however, will often
be used together in order to examine a company's operations and evaluate its potential as an
investment opportunity. Qualitative analysis deals with intangible, inexact concerns that belong to
the social and experiential realm rather than the mathematical one. This approach depends on the
kind of intelligence that machines (currently) lack, since things like positive associations with a
brand, management trustworthiness, customer satisfaction, competitive advantage and cultural
shifts are difficult, arguably impossible, to capture with numerical inputs. A risk in using qualitative
analysis is that subjective judgment may prove incorrect.
Sector Analysis
: Sector analysis involves identification and analysis of various industries or
economic sectors that are likely to exhibit superior performance. Academic studies indicate that the
health of a stock's sector is as important as the performance of the individual stock itself. In other
words, even the best stock located in a weak sector will often perform poorly because that sector is
out of favor. Each industry has differences in terms of its customer base, market share among firms,
industry growth, competition, regulation and business cycles. Learning how the industry operates
provides a deeper understanding of a company's financial health. One method of analyzing a
company's growth potential is examining whether the amount of customers in the overall market is
expected to grow. In some markets, there is zero or negative growth, a factor demanding careful
consideration. Additionally, market analysts recommend that investors should monitor sectors that
are nearing the bottom of performance rankings for possible signs of an impending turnaround.
Technical Analysis:
A security analysis methodology for forecasting the direction of prices through
the study of past market data, primarily price and volume. A fundamental principle of technical
analysis is that a market's price reflects all relevant information, so their analysis looks at the history
of a security's trading pattern rather than external drivers such as economic, fundamental and news
events. Therefore, price action tends to repeat itself due to investors collectively tending toward
patterned behavior – hence technical analysis focuses on identifiable trends and conditions.
Technical analysts also widely use market indicators of many sorts, some of which are mathematical
transformations of price, often including up and down volume, advance/decline data and other
inputs. These indicators are used to help assess whether an asset is trending, and if it is, the
probability of its direction and of continuation. Technicians also look for relationships between
price/volume indices and market indicators. Technical analysis employs models and trading rules
based on price and volume transformations, such as the relative strength index, moving averages,
regressions, inter-market and intra-market price correlations, business cycles, stock market cycles
or, classically, through recognition of chart patterns. Technical analysis is widely used among traders
and financial professionals and is very often used by active day traders, market makers and pit
traders. The risk associated with this type of analysis is that analysts use subjective judgment to
decide which pattern(s) a particular instrument reflects at a given time and what the interpretation
of that pattern should be.
Variable Annuities (“VA”):
A variable annuity is a type of annuity contract that allows for the
accumulation of capital on a tax-deferred basis. As opposed to a fixed annuity that offers a guaranteed
interest rate and a minimum payment at annuitization, variable annuities offer investors the
opportunity to generate higher rates of returns by investing in equity and bond subaccounts. If a
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Mueller Wealth, LLC
variable annuity is annuitized for income, the income payments can vary based on the performance
of the subaccounts. Risks associated with VAs may include:
•
•
•
•
•
•
•
Taxes and federal penalties for early withdrawal
Surrender charges for early withdrawal can last for years
Earnings taxed at ordinary income tax rates
Mortality expense to compensate the insurance company for insurance risks
Fees and expenses imposed for the subaccounts
Other features with additional fees and charges
Investment losses
Investment Strategies We Use
We use the following strategies in managing client accounts, provided that such strategies are
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizons, among other considerations:
Asset Allocation:
The implementation of an investment strategy that attempts to balance risk versus
reward by adjusting the percentage of each asset in an investment portfolio according to the
investor's risk tolerance, goals and investment time frame. Asset allocation is based on the principle
that different assets perform differently in different market and economic conditions. A fundamental
justification for asset allocation is the notion that different asset classes offer returns that are not
perfectly correlated, hence diversification reduces the overall risk in terms of the variability of
returns for a given level of expected return. Although risk is reduced as long as correlations are not
perfect, it is typically forecast (wholly or in part) based on statistical relationships (like correlation
and variance) that existed over some past period. Expectations for return are often derived in the
same way.
An asset class is a group of economic resources sharing similar characteristics, such as riskiness and
return. There are many types of assets that may or may not be included in an asset allocation strategy.
The "traditional" asset classes are stocks (value, dividend, growth, or sector-specific [or a "blend" of
any two or more of the preceding]; large-cap versus mid-cap, small-cap or micro-cap; domestic,
foreign [developed], emerging or frontier markets), bonds (fixed income securities more generally:
investment-grade or junk [high-yield]; government or corporate; short-term, intermediate, long-
term; domestic, foreign, emerging markets), and cash or cash equivalents. Allocation among these
three provides a starting point. Usually included are hybrid instruments such as convertible bonds
and preferred stocks, counting as a mixture of bonds and stocks. Other alternative assets that may be
considered include: commodities: precious metals, nonferrous metals, agriculture, energy, others.;
Commercial or residential real estate (also REITs); Collectibles such as art, coins, or stamps;
insurance products (annuity, life settlements, catastrophe bonds, personal life insurance products,
etc.); derivatives such as long-short or market neutral strategies, options, collateralized debt, and
futures; foreign currency; venture capital; private equity; and/or distressed securities.
•
There are several types of asset allocation strategies based on investment goals, risk tolerance, time
frames and diversification. The most common forms of asset allocation are: strategic, dynamic,
tactical, and core-satellite.
Strategic Asset Allocation: The primary goal of a strategic asset allocation is to create an asset
mix that seeks to provide the optimal balance between expected risk and return for a long-
term investment horizon. Generally speaking, strategic asset allocation strategies are
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•
•
•
agnostic to economic environments, i.e., they do not change their allocation postures relative
to changing market or economic conditions.
Dynamic Asset Allocation: Dynamic asset allocation is similar to strategic asset allocation in
that portfolios are built by allocating to an asset mix that seeks to provide the optimal balance
between expected risk and return for a long-term investment horizon. Like strategic
allocation strategies, dynamic strategies largely retain exposure to their original asset
classes; however, unlike strategic strategies, dynamic asset allocation portfolios will adjust
their postures over time relative to changes in the economic environment.
Tactical Asset Allocation: Tactical asset allocation is a strategy in which an investor takes a
more active approach that tries to position a portfolio into those assets, sectors, or individual
stocks that show the most potential for perceived gains. While an original asset mix is
formulated much like strategic and dynamic portfolio, tactical strategies are often traded
more actively and are free to move entirely in and out of their core asset classes
Core-Satellite Asset Allocation: Core-Satellite allocation strategies generally contain a 'core'
strategic element making up the most significant portion of the portfolio, while applying a
dynamic or tactical 'satellite' strategy that makes up a smaller part of the portfolio. In this
way, core-satellite allocation strategies are a hybrid of the strategic and dynamic/tactical
allocation strategies mentioned above.
Defensive Strategies:
If our IAR anticipates poor near-term prospects for equity markets, we may
adopt a defensive strategy for clients’ accounts by investing substantially in fixed income securities
and/or money market instruments. We may also utilize low, non, or negative correlated
investments through mutual funds and EFT’s. There can be no guarantee that the use of defensive
techniques would be successful in avoiding losses.
Fixed Income:
Fixed income is a type of investing or budgeting style for which real return rates or
periodic income is received at regular intervals and at reasonably predictable levels. Fixed-income
investors are typically retired individuals who rely on their investments to provide a regular, stable
income stream. This demographic tends to invest heavily in fixed-income investments because of the
reliable returns they offer. Fixed-income investors who live on set amounts of periodically paid
income face the risk of inflation eroding their spending power.
Some examples of fixed-income investments include treasuries, money market instruments,
corporate bonds, asset-backed securities, municipal bonds and international bonds. The primary risk
associated with fixed-income investments is the borrower defaulting on his payment. Other
considerations include exchange rate risk for international bonds and interest rate risk for longer-
dated securities. The most common type of fixed-income security is a bond. Bonds are issued by
federal governments, local municipalities and major corporations. Fixed-income securities are
recommended for investors seeking a diverse portfolio; however, the percentage of the portfolio
dedicated to fixed income depends on your own personal investment style. There is also an
opportunity to diversify the fixed-income component of a portfolio. Riskier fixed-income products,
such as junk bonds and longer-dated products, should comprise a lower percentage of your overall
portfolio.
The interest payment on fixed-income securities is considered regular income and is determined
based on the creditworthiness of the borrower and current market rates. In general, bonds and fixed-
income securities with longer-dated maturities pay a higher rate, also referred to as the coupon rate,
because they are considered riskier. The longer the security is on the market, the more time it has to
lose its value and/or default. At the end of the bond term, or at bond maturity, the borrower returns
the amount borrowed, also referred to as the principal or par value.
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Long-Term Purchases:
Our firm may buy securities for your account and hold them for a relatively
long time (more than a year) in anticipation that the security’s value will appreciate over a long
horizon. The risk of this strategy is that our firm could miss out on potential short-term gains that
could have been profitable to your account, or it’s possible that the security’s value may decline
sharply before our firm makes a decision to sell.
Margin Transactions:
Our firm may purchase stocks, mutual funds, and/or other securities for your
portfolio with money borrowed from your brokerage account. This allows you to purchase more
stock than you would be able to with your available cash, and allows us to purchase stock without
selling other holdings. Margin accounts and transactions are risky and not necessarily appropriate
for every client. The potential risks associated with these transactions are (1) You can lose more
funds than are deposited into the margin account; (2) the forced sale of securities or other assets in
your account; (3) the sale of securities or other assets without contacting you; and (4) you may not
be entitled to choose which securities or other assets in your account(s) are liquidated or sold to
meet a margin call.
Short Sales:
A short sale is a transaction in which an investor sells borrowed securities in
anticipation of a price decline and is required to return an equal number of shares at some point in
the future. These transactions have a number of risks that make it highly unsuitable for the novice
investor. This strategy has a slanted payoff ratio in that the maximum gain (which would occur if the
shorted stock was to plunge to zero) is limited, but the maximum loss is theoretically infinite (since
stocks can in theory go up infinitely in price). The following risks should be considered: (1) In
addition to trading commissions, other costs with short selling include that of borrowing the security
to short it, as well as interest payable on the margin account that holds the shorted security. (2) The
short seller is responsible for making dividend payments on the shorted stock to the entity from
whom the stock has been borrowed. (3) Stocks with very high short interest may occasionally surge
in price. This usually happens when there is a positive development in the stock, which forces short
sellers to buy the shares back to close their short positions. Heavily shorted stocks are also
susceptible to “buy-ins,” which occur when a broker closes out short positions in a difficult-to-borrow
stock whose lenders are demanding it back. (4) Regulators may impose bans on short sales in a
specific sector or even in the broad market to avoid panic and unwarranted selling pressure. Such
actions can cause a spike in stock prices, forcing the short seller to cover short positions at huge
losses. (5) Unlike the “buy-and-hold” investor who can afford to wait for an investment to work out,
the short seller does not have the luxury of time because of the many costs and risks associated with
short selling. Timing is everything when it comes to shorting. (5) Short selling should only be
undertaken by experienced traders who have the discipline to cut a losing short position, rather than
add to it hoping that it will eventually work out.
Short-Term Purchases:
When utilizing this strategy, our firm may also purchase securities with the
idea of selling them within a relatively short time (typically a year or less). Our firm does this in an
attempt to take advantage of conditions that our firm believes will soon result in a price swing in the
securities our firm purchase.
Preferred Securities
We prefer to invest our advisory client’s in the following securities in managing client accounts,
provided that such securities are appropriate to the needs of the client and consistent with the
client's investment objectives, risk tolerance, and time horizons, among other considerations:
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Exchange Traded Funds (“ETFs”):
An ETF is a type of Investment Company (usually, an open-end
fund or unit investment trust) whose primary objective is to achieve the same return as a particular
market index. The vast majority of ETFs are designed to track an index, so their performance is close
to that of an index mutual fund, but they are not exact duplicates. A tracking error, or the difference
between the returns of a fund and the returns of the index, can arise due to differences in
composition, management fees, expenses, and handling of dividends. ETFs benefit from continuous
pricing; they can be bought and sold on a stock exchange throughout the trading day. Because ETFs
trade like stocks, you can place orders just like with individual stocks - such as limit orders, good-
until-canceled orders, stop loss orders etc. They can also be sold short. Traditional mutual funds are
bought and redeemed based on their net asset values (“NAV”) at the end of the day. ETFs are bought
and sold at the market prices on the exchanges, which resemble the underlying NAV but are
independent of it. However, arbitrageurs will ensure that ETF prices are kept very close to the NAV
of the underlying securities. Although an investor can buy as few as one share of an ETF, most buy in
board lots. Anything bought in less than a board lot will increase the cost to the investor. Anyone can
buy any ETF no matter where in the world it trades. This provides a benefit over mutual funds, which
generally can only be bought in the country in which they are registered.
One of the main features of ETFs are their low annual fees, especially when compared to traditional
mutual funds. The passive nature of index investing, reduced marketing, and distribution and
accounting expenses all contribute to the lower fees. However, individual investors must pay a
brokerage commission to purchase and sell ETF shares; for those investors who trade frequently,
this can significantly increase the cost of investing in ETFs. That said, with the advent of low-cost
brokerage fees, small or frequent purchases of ETFs are becoming more cost efficient.
Exchange-Traded Notes (ETNs).
An ETN is a senior unsecured debt obligation designed to track the
total return of an underlying market index or other benchmark. ETNs may be linked to a variety of
assets, for example, commodity futures, foreign currency and equities. ETNs are similar to ETFs in
that they are listed on an exchange and can typically be bought or sold throughout the trading day.
However, an ETN is not a mutual fund and does not have a net asset value; the ETN trades at the
prevailing market price. Some of the more common risks of an ETN are as follows. The repayment of
the principal, interest (if any), and the payment of any returns at maturity or upon redemption are
dependent upon the ETN issuer’s ability to pay. In addition, the trading price of the ETN in the
secondary market may be adversely impacted if the issuer’s credit rating is downgraded. The index
or asset class for performance replication in an ETN may or may not be concentrated in a specific
sector, asset class or country and may therefore carry specific risks.
Leveraged and Inverse ETFs, ETNs and Mutual Funds. Leveraged ETFs, ETNs and mutual funds,
sometimes labeled “ultra” or “2x” for example, are designed to provide a multiple of the underlying
index's return, typically on a daily basis. Inverse products are designed to provide the opposite of the
return of the underlying index, typically on a basis. These products are different from and can be
riskier than traditional ETFs, ETNs and mutual funds. Although these products are designed to
provide returns that generally correspond to the underlying index, they may not be able to exactly
replicate the performance of the index because of fund expenses and other factors. This is referred
to as tracking error. Continual re-setting of returns within the product may add to the underlying
costs and increase the tracking error. As a result, this may prevent these products from achieving
their investment objective. In addition, compounding of the returns can produce a divergence from
the underlying index over time, in particular for leveraged products. In highly volatile markets with
large positive and negative swings, return distortions are magnified over time. Because of these
distortions, these products should be actively monitored, as frequently as daily, and are generally not
appropriate as an intermediate or long-term holding. To accomplish their objectives, these products
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use a range of strategies, including swaps, futures contracts and other derivatives. These products
may not be diversified and can be based on commodities or currencies. These products may have
higher expense ratios and be less tax-efficient than more traditional ETFs, ETNs and mutual funds
Structured Products. Structured products are securities derived from another asset, such as a
security or a basket of securities, an index, a commodity, a debt issuance, or a foreign currency.
Structured products frequently limit the upside participation in the reference asset. Structured
products are senior unsecured debt of the issuing bank and subject to the credit risk associated with
that issuer. This credit risk exists whether or not the investment held in the account offers principal
protection. The creditworthiness of the issuer does not affect or enhance the likely performance of
the investment other than the ability of the issuer to meet its obligations. Any payments due at
maturity are dependent on the issuer’s ability to pay. In addition, the trading price of the security in
the secondary market, if there is one, may be adversely impacted if the issuer’s credit rating is
downgraded. Some structured products offer full protection of the principal invested, others offer
only partial or no protection. Investors may be sacrificing a higher yield to obtain the principal
guarantee. In addition, the principal guarantee relates to nominal principal and does not offer
inflation protection. An investor in a structured product never has a claim on the underlying
investment, whether a security, zero coupon bond, or option. There may be little or no secondary
market for the securities and information regarding independent market pricing for the securities
may be limited. This is true even if the product has a ticker symbol or has been approved for listing
on an exchange. Tax treatment of structured products may be different from other investments held
in the account (e.g., income may be taxed as ordinary income even though payment is not received
until maturity). Structured CDs that are insured by the FDIC are subject to applicable FDIC limits.
Individual Stocks
: A common stock is a security that represents ownership in a corporation. Holders
of common stock exercise control by electing a board of directors and voting on corporate policy.
Investing in individual common stocks provides us with more control of what you are invested in and
when that investment is made. Having the ability to decide when to buy or sell helps us time the
taking of gains or losses. Common stocks, however, bear a greater amount of risk when compared to
certificate of deposits, preferred stock and bonds. It is typically more difficult to achieve
diversification when investing in individual common stocks. Additionally, common stockholders are
on the bottom of the priority ladder for ownership structure; if a company goes bankrupt, the
common stockholders do not receive their money until the creditors and preferred shareholders
have received their respective share of the leftover assets.
Municipal Bond
: Municipal bonds are debt obligations generally issued to obtain funds for various
public purposes, including the construction of public facilities. Municipal bonds pay a lower rate of
return than most other types of bonds. Because of a municipal bond’s tax-favored status, investors
should compare the relative after-tax return to the after-tax return of other bonds, depending on the
investor’s tax bracket. Investing in municipal bonds carries the same general risks as investing in
bonds in general. Those risks include interest rate risk, reinvestment risk, inflation risk, market risk,
call or redemption risk, credit risk, and liquidity and valuation risk. Investing in municipal bonds
carries risk unique to these types of bonds, which may include: (a) Legislative risk includes the risk
that a change in the tax code could affect the value of taxable or tax-exempt interest income.; (b)
Municipal bonds generate tax-free income, and therefore pay lower interest rates than taxable bonds.
Investors who anticipate a significant drop in their marginal income-tax rate may benefit from the
higher yield available from taxable bonds.; (c) The risk that investors may have difficulty finding a
buyer when they want to sell and may be forced to sell at a significant discount to market value.
Liquidity risk is greater for thinly traded securities such as lower-rated bonds, bonds that were part
of a small issue, bonds that have recently had their credit rating downgraded or bonds sold by an
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infrequent issuer. Municipal bonds may be less liquid than other bonds.; (d) Credit risk includes the
risk that a borrower will be unable to make interest or principal payments when they are due and
therefore default. To reduce investor concern, insurance policies that guarantee repayment in the
event of default back many municipal bonds.
Mutual Funds
: A mutual fund is a company that pools money from many investors and invests that
money in a variety of differing security types based on the objectives of the fund. The portfolio of the
fund consists of the combined holdings it owns. Each share represents an investor’s proportionate
ownership of the fund’s holdings and the income those holdings generate. The price that investors
pay for mutual fund shares are the fund’s per share net asset value (“NAV”) plus any shareholder fees
that the fund imposes at the time of purchase (such as sales loads). Investors typically cannot
ascertain the exact make-up of a fund’s portfolio at any given time, nor can they directly influence
which securities the fund manager buys and sells or the timing of those trades. With an individual
stock, investors can obtain real-time (or close to real-time) pricing information with relative ease by
checking financial websites or by calling a broker or your investment adviser. Investors can also
monitor how a stock’s price changes from hour to hour—or even second to second. By contrast, with
a mutual fund, the price at which an investor purchases or redeems shares will typically depend on
the fund’s NAV, which is calculated daily after market close.
The benefits of investing through mutual funds include: (a) Mutual funds are professionally managed
by an investment adviser who researches, selects, and monitors the performance of the securities
purchased by the fund; (b) Mutual funds typically have the benefit of diversification, which is an
investing strategy that generally sums up as “Don’t put all your eggs in one basket.” Spreading
investments across a wide range of companies and industry sectors can help lower the risk if a
company or sector fails. Some investors find it easier to achieve diversification through ownership of
mutual funds rather than through ownership of individual stocks or bonds.; (c) Some mutual funds
accommodate investors who do not have a lot of money to invest by setting relatively low dollar
amounts for initial purchases, subsequent monthly purchases, or both.; and (d) At any time, mutual
fund investors can readily redeem their shares at the current NAV, less any fees and charges assessed
on redemption.
Mutual funds also have features that some investors might view as disadvantages: (a) Investors must
pay sales charges, annual fees, and other expenses regardless of how the fund performs. Depending
on the timing of their investment, investors may also have to pay taxes on any capital gains
distributions they receive. This includes instances where the fund performed poorly after purchasing
shares.; (b) Investors typically cannot ascertain the exact make-up of a fund’s portfolio at any given
time, nor can they directly influence which securities the fund manager buys and sells or the timing
of those trades.; and (c) With an individual stock, investors can obtain real-time (or close to real-
time) pricing information with relative ease by checking financial websites or by calling a broker or
your investment adviser. Investors can also monitor how a stock’s price changes from hour to hour—
or even second to second. By contrast, with a mutual fund, the price at which an investor purchases
or redeems shares will typically depend on the fund’s NAV, which the fund might not calculate until
many hours after the investor placed the order. In general, mutual funds must calculate their NAV at
least once every business day, typically after the major U.S. exchanges close.
When investors buy and hold an individual stock or bond, the investor must pay income tax each year
on the dividends or interest the investor receives. However, the investor will not have to pay any
capital gains tax until the investor actually sells and makes a profit. Mutual funds, however, are
different. When an investor buys and holds mutual fund shares, the investor will owe income tax on
any ordinary dividends in the year the investor receives or reinvests them. Moreover, in addition to
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owing taxes on any personal capital gains when the investor sells shares, the investor may have to
pay taxes each year on the fund’s capital gains. That is because the law requires mutual funds to
distribute capital gains to shareholders if they sell securities for a profit, and cannot use losses to
offset these gains.
Options
: An option is a financial derivative that represents a contract sold by one party (the option
writer) to another party (the option holder, or option buyer). The contract offers the buyer the right,
but not the obligation, to buy or sell a security or other financial asset at an agreed-upon price (the
strike price) during a certain period of time or on a specific date (exercise date). Options are
extremely versatile securities. Traders use options to speculate, which is a relatively risky practice,
while hedgers use options to reduce the risk of holding an asset. In terms of speculation, option
buyers and writers have conflicting views regarding the outlook on the performance of a:
• Call Option
: Call options give the option to buy at certain price, so the buyer would want the
stock to go up. Conversely, the option writer needs to provide the underlying shares in the
event that the stock's market price exceeds the strike due to the contractual obligation. An
option writer who sells a call option believes that the underlying stock's price will drop
relative to the option's strike price during the life of the option, as that is how he will reap
maximum profit. This is exactly the opposite outlook of the option buyer. The buyer believes
that the underlying stock will rise; if this happens, the buyer will be able to acquire the stock
for a lower price and then sell it for a profit. However, if the underlying stock does not close
above the strike price on the expiration date, the option buyer would lose the premium paid
for the call option.
• Put Option
: Put options give the option to sell at a certain price, so the buyer would want the
stock to go down. The opposite is true for put option writers. For example, a put option buyer
is bearish on the underlying stock and believes its market price will fall below the specified
strike price on or before a specified date. On the other hand, an option writer who sells a put
option believes the underlying stock's price will increase about a specified price on or before
the expiration date. If the underlying stock's price closes above the specified strike price on
the expiration date, the put option writer's maximum profit is achieved. Conversely, a put
option holder would only benefit from a fall in the underlying stock's price below the strike
price. If the underlying stock's price falls below the strike price, the put option writer is
obligated to purchase shares of the underlying stock at the strike price.
The potential risks associated with these transactions are that (1) all options expire. The closer the
option gets to expiration, the quicker the premium in the option deteriorates; and (2) Prices can move
very quickly. Depending on factors such as time until expiration and the relationship of the stock
price to the option’s strike price, small movements in a stock can translate into big movements in the
underlying options.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear.
While the
stock market may increase and the account(s) could enjoy a gain, it is also possible that the stock
market may decrease and the account(s) could suffer a loss. It is important that clients understand
the risks associated with investing in the stock market, and that their assets are appropriately
diversified in investments. Clients are encouraged to ask our firm any questions regarding their risk
tolerance.
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Capital Risk:
Capital risk is one of the most basic, fundamental risks of investing; it is the risk that
you may lose 100% of your money. All investments carry some form of risk and the loss of capital is
generally a risk for any investment instrument.
Company Risk:
When investing in stock positions, there is always a certain level of company or
industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk
and can be reduced through appropriate diversification. There is the risk that the company will
perform poorly or have its value reduced based on factors specific to the company or its industry.
For example, if a company’s employees go on strike or the company receives unfavorable media
attention for its actions, the value of the company may be reduced.
Credit Risk:
Credit risk can be a factor in situations where an investment’s performance relies on a
borrower’s repayment of borrowed funds. With credit risk, an investor can experience a loss or
unfavorable performance if a borrower does not repay the borrowed funds as expected or required.
Investment holdings that involve forms of indebtedness (i.e. borrowed funds) are subject to credit
risk.
Equity (Stock) Market Risk:
Common stocks are susceptible to general stock market fluctuations
and, volatile increases and decreases in value as market confidence in and perceptions of their issuers
change. If you held common stock, or common stock equivalents, of any given issuer, you would
generally be exposed to greater risk than if you held preferred stocks and debt obligations of the
issuer.
ETF & Mutual Fund Risk
: When investing in an ETF or mutual fund, you will bear additional
expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including
the potential duplication of management fees. The risk of owning an ETF or mutual fund generally
reflects the risks of owning the underlying securities, the ETF, or mutual fund holds. Clients will also
incur brokerage costs when purchasing ETFs.
Financial Risk:
Financial risk is represented by internal disruptions within an investment or the
issuer of an investment that can lead to unfavorable performance of the investment. Examples of
financial risk can be found in cases like Enron or many of the dot com companies that were caught
up in a period of extraordinary market valuations that were not based on solid financial footings of
the companies.
Fixed Income Securities Risk:
Typically, the values of fixed-income securities change inversely with
prevailing interest rates. Therefore, a fundamental risk of fixed-income securities is interest rate risk,
which is the risk that their value will generally decline as prevailing interest rates rise, which may
cause your account value to likewise decrease, and vice versa. How specific fixed income securities
may react to changes in interest rates will depend on the specific characteristics of each security.
Fixed-income securities are also subject to credit risk, prepayment risk, valuation risk, and liquidity
risk. Credit risk is the chance that a bond issuer will fail to pay interest and principal in a timely
manner, or that negative perceptions of the issuer’s ability to make such payments will cause the
price of a bond to decline.
Inflation Risk
: Inflation risk involves the concern that in the future, your investment or proceeds
from your investment will not be worth what they are today. Throughout time, the prices of resources
and end-user products generally increase and thus, the same general goods and products today will
likely be more expensive in the future. The longer an investment is held, the greater the chance that
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the proceeds from that investment will be worth less in the future than what they are today. Said
another way, a dollar tomorrow will likely get you less than what it can today.
Manager Risk:
There is always the possibility that poor security selection will cause your
investments to underperform relative to benchmarks or other funds with a similar investment
objective.
Options Risk
: Options on securities may be subject to greater fluctuations in value than an
investment in the underlying securities. Additionally, options have an expiration date, which makes
them “decay” in value over the amount of time they are held and can expire worthless. Purchasing
and writing put and call options are highly specialized activities and entail greater than ordinary
investment risks.
Past Performance:
Charting and technical analysis are often used interchangeably. Technical
analysis generally attempts to forecast an investment’s future potential by analyzing its past
performance and other related statistics. In particular, technical analysis often times involves an
evaluation of historical pricing and volume of a particular security for the purpose of forecasting
where future price and volume figures may go. As with any investment analysis method, technical
analysis runs the risk of not knowing the future and thus, investors should realize that even the most
diligent and thorough technical analysis cannot predict or guarantee the future performance of any
particular investment instrument or issuer thereof.
Description of Material, Significant or Unusual Risks
Our firm generally invests client cash balances in money market funds, FDIC Insured Certificates of
Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, our
firm tries to achieve the highest return on client cash balances through relatively low-risk
conservative investments. In most cases, at least a partial cash balance will be maintained in a money
market account so that our firm may debit advisory fees for our services related to our Asset
Management services, as applicable.
Item 9: Disciplinary Information
Mueller Wealth and our personnel seek to maintain the highest level of business professionalism,
integrity, and ethics. We are required to disclose the facts of any legal or disciplinary events that are
material to a client’s evaluation of our business or the integrity of our management. There are no
legal or disciplinary events that are material to the evaluation of our advisory business or the
integrity of our management.
Item 10: Other Financial Industry Activities & Affiliations
Representatives of our firm are insurance agents/brokers. They offer insurance products and receive
customary fees as a result of insurance sales. A conflict of interest exists as these insurance sales
create an incentive to recommend products based on the compensation adviser and/or our
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supervised persons may earn. To mitigate this potential conflict, our firm will act in the client’s best
interest.
Item 11: Code of Ethics, Participation or Interest in
Client Transactions & Personal Trading
As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material
facts and to act solely in the best interest of each of our clients at all times. Our fiduciary duty is the
underlying principle for our firm’s Code of Ethics, which includes procedures for personal securities
transaction and insider trading. Our firm requires all representatives to conduct business with the
highest level of ethical standards and to comply with all federal and state securities laws at all times.
Upon employment with our firm, and at least annually thereafter, all representatives of our firm will
acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our firm and
representatives must conduct business in an honest, ethical, and fair manner and avoid all circumstances
that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure
is provided to give all clients a summary of our Code of Ethics. If a client or a potential client wishes to
review our Code of Ethics in its entirety, a copy will be provided promptly upon request.
Our firm recognizes that the personal investment transactions of our representatives demands the
application of a Code of Ethics with high standards and requires that all such transactions be carried out
in a way that does not endanger the interest of any client. At the same time, our firm also believes that if
investment goals are similar for clients and for our representatives, it is logical, and even desirable, that
there be common ownership of some securities.
1
.accounts
In order to prevent conflicts of interest, our firm has established procedures for transactions effected by
2
. In order to monitor compliance with our
our representatives for their personal accounts
personal trading policy, our firm has pre-clearance requirements and a quarterly securities transaction
reporting system for all of our representatives.
Neither our firm nor a related person recommends, buys or sells for client accounts, securities in
which our firm or a related person has a material financial interest without prior disclosure to the
client.
Related persons of our firm may buy or sell securities and other investments that are also
recommended to clients. In order to minimize this conflict of interest, our related persons will place
client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which
is available upon request.
Likewise, related persons of our firm buy or sell securities for themselves at or about the same time they
buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our
1
For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse,
his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our
associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect
beneficial interest in.
2
For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse,
his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our
associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect
beneficial interest in.
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related persons will place client interests ahead of their own interests and adhere to our firm’s Code of
Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying
or selling the same securities prior to buying or selling for our clients in the same day unless included in
a block trade.
Item 12: Brokerage Practices
Selecting a Brokerage Firm
In order for MW to provide asset management services, we request you utilize the brokerage and
custodial services of Charles Schwab (“Schwab”) and Altruist Financial (“Altruist”), for which we have
an existing relationship. Mueller Wealth, Schwab, and Altruist are not affiliated companies. In
considering which independent qualified custodian will be the best fit for Mueller Wealth’s business
model, we are evaluating the following factors, which is not an all-inclusive list:
Financial strength
Reputation
Reporting capabilities
Execution capabilities
Pricing, and
Types and quality of research
While you are free to choose any broker-dealer or other service provider, we recommend that you
establish an account with a brokerage firm with which we have an existing relationship. Such
relationships may include benefits provided to our firm, including, but not limited to research,
market information, and administrative services that help our firm manage your account(s). We
believe that recommended broker-dealers provide quality execution services for our clients at
competitive prices. Price is not the sole factor we consider in evaluating best execution. We also
consider the quality of the brokerage services provided by the recommended broker-dealers,
including the value of research provided, the firm’s reputation, execution capabilities, commission
rates, and responsiveness to our clients and our firm.
You may direct us in writing to use a particular broker-dealer to execute some or all of the
transactions for your account. If you do so, you are responsible for negotiating the terms and
arrangements for the account with that broker-dealer. We may not be able to negotiate commissions,
obtain volume discounts, or best execution. In addition, under these circumstances a difference in
commission charges may exist between the commissions charged to clients who direct us to use a
particular broker or dealer and other clients who do not direct us to use a particular broker or dealer.
Mueller Wealth does not receive client referrals from broker-dealers in exchange for cash or other
compensation, such as brokerage services or research.
Mueller Wealth does not have any formal soft dollar arrangements.
When Mueller Wealth buys or sells the same security for two or more clients (including our personal
accounts), we may place concurrent orders to be executed together as a single “block” in order to
facilitate orderly and efficient execution. Each client account will be charged or credited with the
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Mueller Wealth, LLC
average price per unit. We receive no additional compensation or remuneration of any kind because
we aggregate client transactions. No client is favored over any other client. If an order is not
completely filled, it is allocated pro-rata based on an allocation statement prepared by Mueller
Wealth prior to placing the order. Because of an order’s aggregation, some clients may pay higher
transaction costs, or greater spreads, or receive less favorable net prices on transactions than would
otherwise be the case if the order had not been aggregated.
Special Considerations for ERISA Clients
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account
through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such
direction is permitted provided that the goods and services provided are reasonable expenses of the
plan incurred in the ordinary course of its business for which it otherwise would be obligated and
empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services
purchased are not for the exclusive benefit of the plan. Consequently, our firm will request that plan
sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will
be for the exclusive benefit of the plan.
Item 13: Review of Accounts or Financial Plans
Our Chief Compliance Officer reviews accounts on at least an annual basis for our Asset Management
clients. The nature of these reviews is to learn whether client accounts are in line with their
investment objectives, appropriately positioned based on market conditions, and investment
policies, if applicable. Our firm does not provide written reports to clients, unless asked to do so.
Verbal reports to clients take place on at least an annual basis when our Asset Management, clients
are contacted.
Our firm may review client accounts more frequently than described above. Among the factors which
may trigger an off-cycle review are major market or economic events, the client’s life events, requests
by the client, etc.
Financial Planning clients do not receive reviews of their written plans unless they take action to
schedule a financial consultation with us. Our firm does not provide ongoing services to financial
planning clients, but are willing to meet with such clients upon their request to discuss updates to
their plans, changes in their circumstances, etc. Financial Planning clients do not receive written or
verbal updated reports regarding their financial plans unless they separately engage our firm for a
post-financial plan meeting or update to their initial written financial plan.
Retirement Plan Consulting clients receive reviews of their retirement plans for the duration of the
service. Our firm also provides ongoing services where clients are met with upon their request to
discuss updates to their plans, changes in their circumstances, etc. Retirement Plan Consulting clients
do not receive written or verbal updated reports regarding their plans unless they choose to engage
our firm for ongoing services.
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Mueller Wealth, LLC
Item 14: Client Referrals & Other Compensation
Schwab & Altruist
Our firm may recommend Schwab or Altruist to clients for custody and brokerage services. There is
no direct link between our firm’s participation in the program and the investment advice given to
clients, although we receive economic benefits through our participation in the program that are
typically not available to Schwab or Altruist 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 our firm’s 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; and discounts on compliance,
marketing, research, technology, and practice management products or services provided to us by
third party vendors. Schwab or Altruist may also have paid for business consulting and professional
services received by our firm’s related persons. Some of the products and services made available by
Schwab or Altruist through the program may benefit our firm but may not benefit our client accounts.
These products or services may assist us in managing and administering client accounts, including
accounts not maintained at Schwab or Altruist. Other services made available by Schwab or Altruist
are intended to help us manage and further develop our business enterprise. The benefits received
by our firm or our personnel through participation in the program do not depend on the amount of
brokerage transactions directed to Schwab or Altruist. As part of our fiduciary duties to our 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 firm’s choice of Schwab or Altruist for
custody and brokerage services.
Product Sponsor Funded Events
Various product wholesalers provide financial assistance to allow us to sponsor client educational
seminars, or attend such seminars hosted by the product sponsor. This money is not directly tied to
our use of their products, nor it is contingent upon any future business to be directed to their
products, nonetheless it creates a conflict of interest that may incentivize us to utilize their products.
Our firm will adhere to our fiduciary duty to act in our client’s best interest when selecting what
products to use in client accounts.
Referral Fees
Our firm does not pay referral fees (non-commission based) to independent solicitors (non-
registered representatives) for the referral of their clients to our firm in accordance with relevant
state and federal statutes and rules.
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Mueller Wealth, LLC
Client Directed Referrals
Clients may request the services of an accountant or accounting firm, lawyer or law firm, insurance
company or agency, pension consultant, real estate broker or dealer or other professional, and our
firm may facilitate such a referral. Our firm shall receive no compensation for such a client directed
referral.
Client Testimonials
Our firm does welcome client testimonials via a third-party ratings platform (i.e., Google Reviews)
with an invitation for such on our firm’s official website. In keeping with the requirements of the SEC
Marketing Rule, we indicate whether those providing the comments are compensated in any way in
exchange for their rating and reviews, and our firm, in fact, does not offer direct or indirect
compensation for such client testimonials.
Item 15: Custody
State and federal Securities Bureaus generally take the position that any arrangement under which a
registered investment adviser is authorized or permitted to withdraw client funds or securities
maintained with a custodian upon the adviser’s instruction to the custodian is deemed to have
custody of client funds and securities. As such, our firm has adopted the following safeguarding
procedures:
a)
b)
Clients must provide our firm with written authorization permitting direct payment of
advisory fees from their account(s) maintained by a custodian who is independent of our
firm;
The account custodian sends a statement to the client, at least quarterly, showing all account
disbursements, including advisory fees.
Clients are encouraged to raise any questions with us about the custody, safety or security of their
assets and our custodial recommendations.
Third Party Money Movement:
On February 21, 2017, the SEC issued a no-action letter (“Letter”) with respect to Rule 206(4)-2
(“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided
guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client
funds to a third party under a standing letter of instruction (“SLOA”) is deemed to have custody. As
such, our firm has adopted the following safeguards in conjunction with our custodian:
•
•
The client provides an instruction to the qualified custodian, in writing, that includes the
client’s signature, the third party’s name, and either the third party’s address or the third
party’s account number at a custodian to which the transfer should be directed.
The client authorizes the investment adviser, in writing, either on the qualified custodian’s
form or separately, to direct transfers to the third party either on a specified schedule or from
time to time.
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Mueller Wealth, LLC
•
•
•
•
•
The client’s qualified custodian performs appropriate verification of the instruction, such as
a signature review or other method to verify the client’s authorization, and provides a
transfer of funds notice to the client promptly after each transfer.
The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
The investment adviser has no authority or ability to designate or change the identity of the
third party, the address, or any other information about the third party contained in the
client’s instruction.
The investment adviser maintains records showing that the third party is not a related party
of the investment adviser or located at the same address as the investment adviser.
The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
Item 16: Investment Discretion
Clients have the option of providing our firm with investment discretion on their behalf, pursuant to
an executed investment advisory client agreement. By granting investment discretion, our firm is
authorized to execute securities transactions, determine which securities are bought and sold, and
the total amount to be bought and sold. Should clients grant our firm non-discretionary authority,
our firm would be required to obtain the client’s permission prior to effecting securities transactions.
Limitations may be imposed by the client in the form of specific constraints on any of these areas of
discretion with our firm’s written acknowledgement.
Item 17: Voting Client Securities
Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or
other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent
to our firm, our firm will forward them to the appropriate client and ask the party who sent them to
mail them directly to the client in the future. Clients may call, write or email us to discuss questions
they may have about particular proxy votes or other solicitations.
Item 18: Financial Information
•
Our firm is not required to provide financial information in this Brochure because:
•
•
•
Our firm does not require the prepayment of more than $1,200 in fees when services cannot
be rendered within 6 months.
Our firm does not take custody of client funds or securities.
Our firm does not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
Our firm has never been the subject of a bankruptcy proceeding.
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Item 19: Requirements for State-Registered Advisers
Mueller Wealth, LLC is SEC registered, therefore there is nothing to be disclosed in this section.
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