Overview
- Headquarters
- Tyler, TX
- Total Firm Assets
- $117 million
- Average High-Net-Worth Client Portfolio Size
- $3.4 million
Fee Disclosure
ADV PART 2A FIRM BROCHURE
| Min | Max | Disclosed Annual Rate |
|---|---|---|
| $0 | $250,000 | 1.50% |
| $250,001 | $500,000 | 1.25% |
| $500,001 | $1,000,000 | 1.00% |
| $1,000,001 | and above | 0.75% |
Estimated Annual Fees (Based on ADV disclosures. Where a range is given, we use the upper rate)
| Portfolio Value | Estimated Annual Fee | Effective Fee Rate |
|---|---|---|
| $1 million | $11,875 | 1.19% |
| $5 million | $41,875 | 0.84% |
| $10 million | $79,375 | 0.79% |
| $50 million | $379,375 | 0.76% |
| $100 million | $754,375 | 0.75% |
Clients
- High-Net-Worth Share of Firm Assets
- 94.56%
- Number of High-Net-Worth Clients
- 32
- Total Client Accounts
- 49
- Discretionary Accounts
- 48
- Non-Discretionary Accounts
- 1
Services Offered
Services: Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 142783
Primary Brochure: ADV PART 2A FIRM BROCHURE (2026-09-03)
View Document Text
Murray Securities, Inc.
Firm Brochure - Form ADV Part 2A
This brochure provides information about the qualifications and business practices of Murray Securities, Inc.. If
you have any questions about the contents of this brochure, please contact us at (903) 561-5588 or by email at:
frontdesk@murraysecurities.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 Murray Securities, Inc. is also available on the SEC’s website at
www.adviserinfo.sec.gov. Murray Securities, Inc.’s CRD number is: 142783.
909 ESE Loop 323 Suite 200
Tyler, TX 75701
(903) 561-5588
frontdesk@murraysecurities.com
http://www.murraysecuritiesinc.com
Registration as an investment adviser does not imply a certain level of skill or training.
Version Date: 9/2/2026
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Item 2: Material Changes
The material changes in this brochure from the last annual updating amendment of Murray Securities,
Inc. on 12/5/2025, are described below. Material changes relate to Murray Securities, Inc.’s policies,
practices or conflicts of interest.
• Murray Securities, Inc. has transitioned to registration with the United States Securities and
Exchange Commission from its current registration at the state level.
• Murray Securities, Inc. has disclosed FINRA’s issuance of an Acceptance, Waiver & Consent
(AWC) against Murray Securities, Inc. (Item 9)
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Item 3: Table of Contents
Item 1: Cover Page
Item 2: Material Changes ....................................................................................................................................... ii
Item 3: Table of Contents ...................................................................................................................................... iii
Item 4: Advisory Business ......................................................................................................................................2
Item 5: Fees and Compensation .............................................................................................................................4
Item 6: Performance-Based Fees and Side-By-Side Management ....................................................................5
Item 7: Types of Clients ..........................................................................................................................................6
Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ...............................................................6
Item 9: Disciplinary Information ...........................................................................................................................9
Item 10: Other Financial Industry Activities and Affiliations .........................................................................10
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...............11
Item 12: Brokerage Practices ................................................................................................................................12
Item 13: Review of Accounts ................................................................................................................................13
Item 14: Client Referrals and Other Compensation ..........................................................................................14
Item 15: Custody ....................................................................................................................................................14
Item 16: Investment Discretion ............................................................................................................................14
Item 17: Voting Client Securities (Proxy Voting) ..............................................................................................15
Item 18: Financial Information .............................................................................................................................15
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Item 4: Advisory Business
A. Description of the Advisory Firm
Murray Securities, Inc. (hereinafter “MSI”) is a Corporation organized in the State of
Texas. The firm was formed in October 2006, and the principal owner is Gary Von Murray.
B. Types of Advisory Services
Portfolio Management Services
MSI offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. MSI creates an Investment
Policy Statement for each client, which outlines the client’s current situation (income, tax
levels, and risk tolerance levels). Portfolio management services include, but are not
limited to, the following:
•
•
•
Investment strategy •
•
Asset allocation
•
Risk tolerance
Personal investment policy
Asset selection
Regular portfolio monitoring
MSI evaluates the current investments of each client with respect to their risk tolerance
levels and time horizon. MSI will request discretionary authority from clients in order to
select securities and execute transactions without permission from the client prior to each
transaction. Risk tolerance levels are documented in the Investment Policy Statement,
which is given to each client.
MSI seeks to provide that investment decisions are made in accordance with the fiduciary
duties owed to its accounts and without consideration of MSI’s economic, investment or
other financial interests. To meet its fiduciary obligations, MSI attempts to avoid, among
other things, investment or trading practices that systematically advantage or
disadvantage certain client portfolios, and accordingly, MSI’s policy is to seek fair and
equitable allocation of investment opportunities/transactions among its clients to avoid
favoring one client over another over time. It is MSI’s policy to allocate investment
opportunities and transactions it identifies as being appropriate and prudent among its
clients on a fair and equitable basis over time.
Services Limited to Specific Types of Investments
MSI generally limits its investment advice to mutual funds, fixed income securities,
equities, ETFs and treasury inflation protected/inflation linked bonds. MSI may use other
securities as well to help diversify a portfolio when applicable.
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Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or
individual retirement account, we are fiduciaries within the meaning of Title I of the
Employee Retirement Income Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. The way we make money
creates some conflicts with your interests, so we operate under a special rule that
requires us to act in your best interest and not put our interest ahead of yours. Under
this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put our financial interests ahead of yours when making recommendations
(give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in
your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
C. Client Tailored Services and Client Imposed Restrictions
MSI offers the same suite of services to all of its clients. However, specific client
investment strategies and their implementation are dependent upon the client Investment
Policy Statement which outlines each client’s current situation (income, tax levels, and risk
tolerance levels). Clients may not impose restrictions in investing in certain securities or
types of securities in accordance with their values or beliefs.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees and transaction costs. MSI does not participate in wrap fee
programs.
E. Assets Under Management
MSI has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$98,795,111
$17,851,250
August 2026
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Item 5: Fees and Compensation
A. Fee Schedule
Portfolio Management Fees
Total Assets Under Management Annual Fees
$0 - $250,000
1.50%
$250,001 - $500,000
1.25%
$500,001 - $1,000,000
1.00%
$1,000,001 - AND UP
0.75%
The advisory fee is calculated using the value of the assets in the Account on the last
business day of the prior billing period.
These fees are generally negotiable, and the final fee schedule will be memorialized in the
client’s advisory agreement. Clients may terminate the agreement without penalty for a
full refund of MSI's fees within five business days of signing the Investment Advisory
Contract. Thereafter, clients may terminate the Investment Advisory Contract generally
with 30 days' written notice.
B. Payment of Fees
Payment of Portfolio Management Fees
Asset-based portfolio management fees are withdrawn directly from the client's accounts
with client's written authorization on a quarterly basis. Fees are paid in advance.
C. Client Responsibility For Third Party Fees
Clients are responsible for the payment of all third party fees (i.e. custodian fees,
brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and
distinct from the fees and expenses charged by MSI. Please see Item 12 of this brochure
regarding broker-dealer/custodian.
D. Prepayment of Fees
MSI collects fees in advance. Refunds for fees paid in advance but not yet earned will be
refunded on a prorated basis and returned within fourteen days to the client via check or
return deposit back into the client’s account.
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For all asset-based fees paid in advance, the fee refunded will be equal to the balance of
the fees collected in advance minus the daily rate* times the number of days elapsed in
the billing period up to and including the day of termination. (*The daily rate is calculated
by dividing the annual asset-based fee rate by 365.)
E. Outside Compensation For the Sale of Securities to Clients
Gary Von Murray is a registered representative of a broker-dealer and in this role, accepts
compensation for the sale of investment products to MSI clients.
1. This is a Conflict of Interest
Supervised persons may accept compensation for the sale of investment products,
including asset based sales charges or service fees from the sale of mutual funds to
MSI's clients. This presents a conflict of interest and gives the supervised person an
incentive to recommend products based on the compensation received rather than on
the client’s needs. When recommending the sale of investment products for which the
supervised persons receives compensation, MSI will document the conflict of interest
in the client file and inform the client of the conflict of interest.
2. Clients Have the Option to Purchase Recommended Products From
Other Brokers
Clients always have the option to purchase MSI recommended products through
other brokers or agents that are not affiliated with MSI.
3. Commissions are not MSI's primary source of compensation for
advisory services
Commissions are not MSI’s primary source of compensation for advisory services.
4. Advisory Fees in Addition to Commissions or Markups
Advisory fees that are charged to clients are not reduced to offset the commissions or
markups on investment products recommended to clients.
Item 6: Performance-Based Fees and Side-By-Side Management
MSI does not accept performance-based fees or other fees based on a share of capital gains on or
capital appreciation of the assets of a client.
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Item 7: Types of Clients
MSI generally provides advisory services to the following types of clients:
❖
❖
Individuals
High-Net-Worth Individuals
There is no account minimum for any of MSI’s services.
Item 8: Methods of Analysis, Investment Strategies, & Risk of
Loss
A. Methods of Analysis and Investment Strategies
Methods of Analysis
MSI’s methods of analysis include Fundamental analysis, Quantitative analysis and
Technical analysis.
Fundamental analysis involves the analysis of financial statements, the general financial
health of companies, and/or the analysis of management or competitive advantages.
Quantitative analysis deals with measurable factors as distinguished from qualitative
considerations such as the character of management or the state of employee morale, such
as the value of assets, the cost of capital, historical projections of sales, and so on.
Technical analysis involves the analysis of past market data; primarily price and volume.
Investment Strategies
MSI uses long term trading, short term trading and options trading (including covered
options, uncovered options, or spreading strategies).
Investing in securities involves a risk of loss that you, as a client, should be prepared
to bear.
B. Material Risks Involved
Methods of Analysis
Fundamental analysis concentrates on factors that determine a company’s value and
expected future earnings. This strategy would normally encourage equity purchases in
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stocks that are undervalued or priced below their perceived value. The risk assumed is
that the market will fail to reach expectations of perceived value.
Quantitative analysis Investment strategies using quantitative models may perform
differently than expected as a result of, among other things, the factors used in the models,
the weight placed on each factor, changes from the factors’ historical trends, and technical
issues in the construction and implementation of the models.
Technical analysis attempts to predict a future stock price or direction based on market
trends. The assumption is that the market follows discernible patterns and if these
patterns can be identified then a prediction can be made. The risk is that markets do not
always follow patterns and relying solely on this method may not take into account new
patterns that emerge over time.
Investment Strategies
MSI's use of options trading generally holds greater risk, and clients should be aware that
there is a material risk of loss using any of those strategies.
Long term trading is designed to capture market rates of both return and risk. Due to its
nature, the long-term investment strategy can expose clients to various types of risk that
will typically surface at various intervals during the time the client owns the investments.
These risks include but are not limited to inflation (purchasing power) risk, interest rate
risk, economic risk, market risk, and political/regulatory risk.
Options transactions involve a contract to purchase a security at a given price, not
necessarily at market value, depending on the market. This strategy includes the risk that
an option may expire out of the money resulting in minimal or no value, as well as the
possibility of leveraged loss of trading capital due to the leveraged nature of stock options.
Short term trading risks include liquidity, economic stability, and inflation, in addition to
the long term trading risks listed above. Frequent trading can affect investment
performance, particularly through increased brokerage and other transaction costs and
taxes.
Investing in securities involves a risk of loss that you, as a client, should be prepared
to bear.
C. Risks of Specific Securities Utilized
MSI's use of options trading generally holds greater risk of capital loss. Clients should be
aware that there is a material risk of loss using any investment strategy. The investment
types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds)
are not guaranteed or insured by the FDIC or any other government agency.
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Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may
lose money investing in mutual funds. All mutual funds have costs that lower investment
returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity”
nature.
Equity investment generally refers to buying shares of stocks in return for receiving a
future payment of dividends and/or capital gains if the value of the stock increases. The
value of equity securities may fluctuate in response to specific situations for each
company, industry conditions and the general economic environments.
Fixed income investments generally pay a return on a fixed schedule, though the amount
of the payments can vary. This type of investment can include corporate and government
debt securities, leveraged loans, high yield, and investment grade debt and structured
products, such as mortgage and other asset-backed securities, although individual bonds
may be the best known type of fixed income security. In general, the fixed income market
is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond
prices usually fall, and vice versa. This effect is usually more pronounced for longer-term
securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and
credit and default risks for both issuers and counterparties. The risk of default on treasury
inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting
(extremely unlikely); however, they carry a potential risk of losing share price value, albeit
rather minimal.
Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges,
similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100%
loss in the case of a stock holding bankruptcy). Areas of concern include the lack of
transparency in products and increasing complexity, conflicts of interest and the
possibility of inadequate regulatory compliance. Risks in investing in ETFs include
trading risks, liquidity and shutdown risks, risks associated with a change in authorized
participants and non-participation of authorized participants, risks that trading price
differs from indicative net asset value (iNAV), or price fluctuation and disassociation from
the index being tracked. With regard to trading risks, regular trading adds cost to your
portfolio thus counteracting the low fees that one of the typical benefits of ETFs.
Additionally, regular trading to beneficially “time the market” is difficult to achieve. Even
paid fund managers struggle to do this every year, with the majority failing to beat the
relevant indexes. With regard to liquidity and shutdown risks, not all ETFs have the same
level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading
conditions are more accurately reflected in implied liquidity rather than the average daily
volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded
in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks
of their underlying securities, which may include the risks associated with investing in
smaller companies, foreign securities, commodities, and fixed income investments (as
applicable). Foreign securities in particular are subject to interest rate, currency exchange
rate, economic, and political risks, all of which are magnified in emerging markets. ETFs
that target a small universe of securities, such as a specific region or market sector, are
generally subject to greater market volatility, as well as to the specific risks associated with
that sector, region, or other focus. ETFs that use derivatives, leverage, or complex
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investment strategies are subject to additional risks. The return of an index ETF is usually
different from that of the index it tracks because of fees, expenses, and tracking error. An
ETF may trade at a premium or discount to its net asset value (NAV) (or indicative value
in the case of exchange-traded notes). The degree of liquidity can vary significantly from
one ETF to another and losses may be magnified if no liquid market exists for the ETF’s
shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its
prospectus, offering circular, or similar material, which should be considered carefully
when making investment decisions.
Options are contracts to purchase a security at a given price, risking that an option may
expire out of the money resulting in minimal or no value. An uncovered option is a type
of options contract that is not backed by an offsetting position that would help mitigate
risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss
for an uncovered call option is limitless. Spread option positions entail buying and selling
multiple options on the same underlying security, but with different strike prices or
expiration dates, which helps limit the risk of other option trading strategies. Option
transactions also involve risks including but not limited to economic risk, market risk,
sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk
and interest rate risk.
Past performance is not indicative of future results. Investing in securities involves a
risk of loss that you, as a client, should be prepared to bear.
Item 9: Disciplinary Information
A. Criminal or Civil Actions
There are no criminal or civil actions to report.
B. Administrative Proceedings
There are no administrative proceedings to report.
C. Self-regulatory Organization (SRO) Proceedings
On April 8, 2024, FINRA issued an Acceptance, Waiver & Consent (AWC) against Murray
Securities, Inc. (CRD No. 142783).
Without admitting or denying the findings, the firm consented to findings that it willfully
violated Rule 15L-1(a)(1) of the Securities Exchange Act of 1934 (Regulation Best Interest)
by failing to establish written policies and procedures, and a supervisory system,
including Written Supervisory Procedures (WSPs), reasonably designed to achieve
compliance with Reg BI. Specifically, the firm's written policies and procedures contained
no provisions relating to Reg BI following its implementation date, and the subsequently
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updated policies and procedures addressed Reg BI only in general terms, without
addressing conflicts of interest obligations, care obligations, or specific supervisory
review procedures.
The firm also consented to findings that it violated Exchange Act Section 17(a)(1) and
Exchange Act Rule 17a-14 by omitting required information from its Form CRS and failing
to establish a supervisory system, including WSPs, reasonably designed to achieve
compliance with its Form CRS obligations. The firm's WSPs contained no reference to
Form CRS until more than a year after the Form CRS implementation date.
As a result, the firm was censured, fined $35,000, and required to undertake remediation,
including certifying in writing that it has reviewed and remediated the deficiencies in its
Form CRS and has implemented a supervisory system and training reasonably designed
to achieve compliance with both Regulation Best Interest and Form CRS requirements.
The matter is final. The firm has satisfied the fine and is implementing the required
supervisory system, WSPs, and training..
Item 10: Other Financial Industry Activities and Affiliations
A. Registration as a Broker/Dealer or Broker/Dealer Representative
MSI is registered as a broker-dealer with the Financial Industry Regulatory Authority
(FINRA) and the U.S. Securities and Exchange Commission (SEC). In addition to
providing investment advisory services, MSI engages in broker-dealer activities,
including the execution of securities transactions for clients and other broker-dealer
functions.
As a result of this dual registration, MSI and its associated persons may act in the capacity
of both investment adviser and broker-dealer with respect to client accounts. When acting
as a broker-dealer, MSI may receive commissions, markups, markdowns, or other
transaction-based compensation in connection with the purchase or sale of securities for
clients. This compensation is separate from, in addition to, advisory fees charged to
clients.
This dual registration creates a conflict of interest: MSI has a financial incentive to
recommend securities transactions that generate broker-dealer compensation rather than
recommendations that are solely in the client's best interest. MSI addresses this conflict
through its best interest obligation under Regulation Best Interest (Reg BI) and its
fiduciary duty in the advisory context, as well as through disclosure and supervisory
procedures designed to ensure that recommendations are appropriate for each client.
Clients are not required to execute transactions through MSI in its broker-dealer capacity.
Clients who direct brokerage to MSI should be aware that this may result in higher
transaction costs than if the client used an unaffiliated broker-dealer, and that MSI may
not be able to obtain best execution in all cases.
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B. Registration as a Futures Commission Merchant, Commodity
Pool Operator, or a Commodity Trading Advisor
Neither MSI nor its representatives are registered as or have pending applications to
become either a Futures Commission Merchant, Commodity Pool Operator, or
Commodity Trading Advisor or an associated person of the foregoing entities.
C. Registration Relationships Material to this Advisory Business
and Possible Conflicts of Interests
Gary Von Murray is a registered representative of Murray Securities, Inc. and from time
to time, will offer clients advice or products from those activities. Clients should be aware
that these services pay a commission or other compensation and involve a conflict of
interest, as commissionable products conflict with the fiduciary duties of a registered
investment adviser. MSI always acts in the best interest of the client, including with
respect to the sale of commissionable products to advisory clients. Clients are in no way
required to implement the plan through any representative of MSI in such individual’s
capacity as a registered representative.
D. Selection of Other Advisers or Managers and How This Adviser
is Compensated for Those Selections
MSI does not utilize nor select third-party investment advisers.
Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
A. Code of Ethics
MSI has a written Code of Ethics that covers the following areas: Prohibited Purchases
and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions,
Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality,
Service on a Board of Directors, Compliance Procedures, Compliance with Laws and
Regulations, Procedures and Reporting, Certification of Compliance, Reporting
Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual
Review, and Sanctions. MSI's Code of Ethics is available free upon request to any client or
prospective client.
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B. Recommendations Involving Material Financial Interests
If an agency cross transaction arises, MSI will only execute such transaction with the
consent of the applicable client. An agency cross transaction is generally defined as a
transaction where a person acts as investment adviser in relation to a transaction in which
the investment adviser, or any person controlled by or under common control with the
investment adviser, acts as broker for both the advisory client and for another person on
the other side of the transaction.
C. Investing Personal Money in the Same Securities as Clients
From time to time, representatives of MSI may buy or sell securities for themselves that
they also recommend to clients. This may provide an opportunity for representatives of
MSI to buy or sell the same securities before or after recommending the same securities to
clients resulting in representatives profiting off the recommendations they provide to
clients. Such transactions may create a conflict of interest. MSI will always document any
transactions that could be construed as conflicts of interest and will never engage in
trading that operates to the client’s disadvantage when similar securities are being bought
or sold.
D. Trading Securities At/Around the Same Time as Clients’
Securities
From time to time, representatives of MSI may buy or sell securities for themselves at or
around the same time as clients. This may provide an opportunity for representatives of
MSI to buy or sell securities before or after recommending securities to clients resulting in
representatives profiting off the recommendations they provide to clients. Such
transactions may create a conflict of interest; however, MSI will never engage in trading
that operates to the client’s disadvantage if representatives of MSI buy or sell securities at
or around the same time as clients.
Item 12: Brokerage Practices
A. Factors Used to Select Custodians and/or Broker/Dealers
Custodians/broker-dealers will be recommended based on MSI’s duty to seek “best
execution,” which is the obligation to seek execution of securities transactions for a client
on the most favorable terms for the client under the circumstances. Clients will not
necessarily pay the lowest commission or commission equivalent, and MSI may also
consider the market expertise and research access provided by the broker-
dealer/custodian, including but not limited to access to written research, oral
communication with analysts, admittance to research conferences and other resources
provided by the brokers that may aid in MSI's research efforts. MSI will never charge a
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premium or commission on transactions, beyond the actual cost imposed by the broker-
dealer/custodian.
MSI will require clients to use Hilltop Securities.
1. Research and Other Soft-Dollar Benefits
MSI receives no research, product, or services other than execution from broker-
dealers or custodians in connection with client securities transactions (“soft dollar
benefits”).
2. Brokerage for Client Referrals
MSI receives no referrals from a broker-dealer or third party in exchange for using
that broker-dealer or third party.
3. Clients Directing Which Broker/Dealer/Custodian to Use
MSI will require clients to use a specific broker-dealer to execute transactions. Not all
advisers require clients to use a particular broker-dealer.
B. Aggregating (Block) Trading for Multiple Client Accounts
If MSI buys or sells the same securities on behalf of more than one client, then it may (but
would be under no obligation to) aggregate or bunch such securities in a single transaction
for multiple clients in order to seek more favorable prices, lower brokerage commissions,
or more efficient execution. In such case, MSI would place an aggregate order with the
broker on behalf of all such clients in order to ensure fairness for all clients; provided,
however, that trades would be reviewed periodically to ensure that accounts are not
systematically disadvantaged by this policy. MSI would determine the appropriate
number of shares and select the appropriate brokers consistent with its duty to seek best
execution, except for those accounts with specific brokerage direction (if any).
Item 13: Review of Accounts
A. Frequency and Nature of Periodic Reviews and Who Makes
Those Reviews
All client accounts for MSI's advisory services provided on an ongoing basis are reviewed
at least Quarterly by Gary Von Murray, Owner, with regard to clients’ respective
investment policies and risk tolerance levels. All accounts at MSI are assigned to this
reviewer.
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B. Factors That Will Trigger a Non-Periodic Review of Client
Accounts
Reviews may be triggered by material market, economic or political events, or by changes
in client's financial situations (such as retirement, termination of employment, physical
move, or inheritance).
C. Content and Frequency of Regular Reports Provided to Clients
Each client of MSI's advisory services provided on an ongoing basis will receive a
quarterly report detailing the client’s account, including assets held, asset value, and
calculation of fees. This written report will come from the custodian.
Item 14: Client Referrals and Other Compensation
A. Economic Benefits Provided by Third Parties for Advice
Rendered to Clients (Includes Sales Awards or Other Prizes)
MSI does not receive any economic benefit, directly or indirectly from any third party for
advice rendered to MSI's clients.
B. Compensation to Non – Advisory Personnel for Client Referrals
MSI does not directly or indirectly compensate any person who is not advisory personnel
for client referrals.
Item 15: Custody
When advisory fees are deducted directly from client accounts at client's custodian, MSI will be
deemed to have limited custody of client's assets and must have written authorization from the
client to do so. Clients will receive all account statements and billing invoices that are required in
each jurisdiction, and they should carefully review those statements for accuracy.
Item 16: Investment Discretion
MSI provides discretionary and non-discretionary investment advisory services to clients. The
advisory contract established with each client sets forth the discretionary authority for trading.
Where investment discretion has been granted, MSI generally manages the client’s account and
makes investment decisions without consultation with the client as to when the securities are to
be bought or sold for the account, the total amount of the securities to be bought/sold, what
securities to buy or sell, or the price per share.
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Item 17: Voting Client Securities (Proxy Voting)
MSI will not ask for, nor accept voting authority for client securities. Clients will receive proxies
directly from the issuer of the security or the custodian. Clients should direct all proxy questions
to the issuer of the security.
Item 18: Financial Information
A. Balance Sheet
MSI neither requires nor solicits prepayment of more than $1,200 in fees per client, six
months or more in advance, and therefore is not required to include a balance sheet with
this brochure.
B. Financial Conditions Reasonably Likely to Impair Ability to
Meet Contractual Commitments to Clients
Neither MSI nor its management has any financial condition that is likely to reasonably
impair MSI’s ability to meet contractual commitments to clients.
C. Bankruptcy Petitions in Previous Ten Years
MSI has not been the subject of a bankruptcy petition in the last ten years.
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