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Part 2A | Form ADV
Supplemental Information
SEPTEMBER 25, 2025
Plante Moran Financial Advisors, LLC
3000 Town Center, Suite 100 Southfield, MI 48075
SEC File number 801-44058
Phone: 248-223-3611
wealth.plantemoran.com
This brochure provides information about the qualifications and business practices of Plante Moran Financial Advisors, LLC. (“PMFA”). If you have any
questions about the contents of this brochure, please contact us at the telephone number listed above. In addition to the information contained in this
document, you should receive a supplemental document containing the professional biographies of related persons of PMFA. The information in this brochure
has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Registration as an investment
adviser does not imply a certain level of skill or training. Additional information about PMFA is also available on the SEC website at www.adviserinfo.sec.gov
Material Changes
We are providing you with these important required regulatory disclosures regarding Plante Moran Financial Advisors, LLC
(“PMFA”). If you have any questions regarding the content, please contact your Relationship Manager or David T. Doyle, Chief
Compliance Officer of PMFA, at 248.223.3611 or dave.doyle@plantemoran.com.
There have been no material changes since this document was last updated on March 28, 2025.
Pursuant to United States Securities and Exchange Commission (“SEC”) rules, we will ensure that you receive a summary of any
material changes to this and subsequent brochures within 120 days of the close of our fiscal year. We also will provide other
ongoing disclosure information about material changes as necessary.
We will provide you a new brochure, at any time, without charge.
Our brochure is also available on our website http://www.plantemoran.com/wealthmanagement free of charge.
Additional information about PMFA is also available via the SEC’s website www.adviserinfo.sec.gov. The SEC’s website also
provides information about any persons affiliated with PMFA who are registered as investment adviser representatives of
PMFA.
Table of Contents
Material Changes ............................................................................................................................................................................................................. 3
Advisory Services ............................................................................................................................................................................................................ 5
Performance-based Fees and Side-By-Side Management ................................................................................................................................... 8
Types of Clients .............................................................................................................................................................................................................. 9
Types of Investments .................................................................................................................................................................................................... 9
Methods of Analysis, Sources of Information, Investment Strategies, and Risk of Loss ............................................................................. 9
Disciplinary Information ............................................................................................................................................................................................ 11
Other Financial Industry Activities and Affiliations ............................................................................................................................................ 11
Code of Ethics ................................................................................................................................................................................................................. 13
Participation or Interest in Client Transactions ................................................................................................................................................... 14
Brokerage Practices ...................................................................................................................................................................................................... 14
Review of Accounts ....................................................................................................................................................................................................... 18
Client Referrals and Other Compensation .............................................................................................................................................................. 18
Custody ............................................................................................................................................................................................................................ 19
Investment Discretion ................................................................................................................................................................................................. 19
Financial Information ................................................................................................................................................................................................. 20
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ADVISORY SERVICES
Plante Moran Financial Advisors, LLC (“PMFA”) is an investment advisor registered with the United States Securities and
Exchange Commission (“SEC”) engaged in providing investment advisory, financial planning, and estate planning services to
individuals and other entities including institutions, and not-for-profit entities.
PMFA is a wholly owned affiliate of P&M Holding Group, LLP. PMFA has provided investment advisory services since 1977 and
has been registered as an investment advisor with the SEC since May of 1993. Plante Moran, PLLC, wholly owned by P&M
Holding Group, LLP, is one of the nation’s largest public accounting and management consulting firms, with over 3,800 staff
serving clients throughout the United States and globally.
As of June 30, 2025, PMFA has the following total assets under management:
Discretionary
Non-discretionary
Total
$ 9,702,240,868
$ 13,450,506,492
$ 23,152,747,360
Portfolio Advisory Services
PMFA Portfolio Advisory Services is an advisory program that offers discretionary and non-discretionary advisory
management. The selection of discretionary or non-discretionary management is a mutual decision between PMFA and the
client, based upon factors including investment goals, risk tolerance, the complexity of a client’s financial situation, portfolio
value, tax situation, wealth transfer issues, client suitability or other factors. Portfolio Advisory Services involves
recommending, purchasing, and actively monitoring investment portfolios to private clients. PMFA develops a strategic asset
allocation plan consistent with clients’ desired rate of return, time horizon, and risk tolerance.
Depending upon the client relationship, our discretionary Portfolio Advisory Services include:
Portfolio design
Specific mutual fund and exchange-traded fund (ETF) investment selection
Effecting mutual fund and exchange-traded fund (ETF) transactions through brokerage firms, banks, or other custodians
Separate account investment manager recommendations, if part of the portfolio design
Monitoring of assets under the consulting agreement
Investment performance reporting
Portfolio change recommendations (may occur at any time)
Tax lot accounting
Review meetings and discussions as desired
Depending upon the client relationship, our non-discretionary Portfolio Advisory Services include:
Portfolio design
Specific mutual fund and exchange-traded fund (ETF) recommendations
Effecting mutual fund and exchange-traded fund (ETF) transactions through brokerage firms, banks, or other custodians
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Separate account investment manager recommendations, if part of the portfolio design
Specific hedge fund and hedge fund-of-fund recommendations
Other individual alternative investment recommendations
Monitoring of assets under the consulting agreement
Investment performance reporting
Portfolio change recommendations (may occur at any time)
Tax lot accounting
Review meetings and discussions as desired
In connection with these services, PMFA will provide the following:
Analysis of Current Situation — A review of client financial goals, investment objectives, risk tolerances, and the current
investment strategy.
Asset Allocation Strategy — Based on items reviewed in the analysis of the client’s current situation, develop an asset
allocation strategy that is consistent with the client's goals and objectives.
Investment Policy Statement — Written documentation of the investment objectives, expectations, risk tolerances, and
other components of a client's investment strategy (e.g., securities guidelines, monitoring requirements, and discretionary
or nondiscretionary management).
Portfolio Implementation and Manager Search Services — Provide to clients information concerning the investment styles,
strategies, and other important factors to be considered when selecting a manager. We may recommend specific mutual
funds, exchange-traded funds (ETFs), separate account managers, hedge fund-of-fund managers, and alternative investment
vehicles. PMFA does not accept commissions or other fees from any managers, mutual funds, hedge fund-of-funds, broker-
dealers, or product sponsors utilized to implement client portfolios.
Portfolio Monitoring and Measurement Services — Includes reviews of portfolio and manager performance. These reviews
also typically include asset allocation analysis, performance and risk management discussions, appropriate index and group
universe comparisons, transaction summaries, and investment market commentary. At the request of clients, we will hold
meetings to review these services.
Clients requiring complex tax, retirement, business succession planning, insurance consulting and estate planning services can
engage PMFA or its affiliates to provide them under a separate agreement.
FEES & COMPENSATION
Annual fees for advisory services are based upon a percentage of the fair market value of the assets being advised, specifically:
1.00% on the first $ 2,000,000
0.80% on the next $ 3,000,000
0.60% on the next $ 5,000,000
0.40% on the next $ 15,000,000
0.30% over $ 25,000,000
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A minimum annual fee of $5,000 applies to clients subject to this fee schedule. Accounts below $500,000 charged the minimum
fee will experience a fee greater than the published fee schedule.
If you have a margin balance, your margin debit does not reduce the fair market value of the assets being advised. Where it is
determined to be applicable, fixed-fee arrangements are available. Exceptions to the published fee schedule apply to clients who
engaged our services under a prior fee schedule or will be considered on an individual case basis. Fees for services provided to
clients of Plante Moran Trust are subject to the Agreement between those affiliated entities and vary from the rates above.
In all cases, clients will have the opportunity to place reasonable restrictions on the types of investments that will be made on
their behalf. We reserve the right to not accept or to terminate an account if we believe the restrictions imposed impair our
ability to serve the client.
Nonrecurring Services
PMFA occasionally provides nonrecurring services to help a client develop and administer a comprehensive investment strategy
consistent with their financial goals.
Areas of nonrecurring services include:
• Analysis of current situation — A review of client financial goals, investment objectives, risk tolerances, and the current
investment strategy.
• Asset allocation strategy — Based on items reviewed in the analysis of the client’s current situation, develop an asset
allocation strategy that is consistent with the client's goals and objectives.
• Investment policy statement — Written documentation of decisions reached regarding the investment objectives,
expectations, risk tolerances, and other components of a client's investment strategy (e.g., securities guidelines,
monitoring requirements, and discretionary or nondiscretionary management).
• Portfolio manager consideration — Provide clients information concerning the investment styles, strategies, and other
important factors that should be considered when selecting a manager.
Each of the services described above may be completed separately. For nonrecurring engagements, PMFA will not recommend
specific mutual funds, exchange-traded funds (ETFs), separate account managers, hedge fund-of-fund managers, or specific
alternative investment vehicles. All nonrecurring services will be detailed in an engagement agreement executed by the client
and PMFA. Upon completion of the terms of the engagement, PMFA will provide no other services (such as ongoing monitoring
of portfolios).
Nonrecurring services fees are based on a fixed amount or time incurred at standard hourly billing rates, plus direct costs.
Current hourly rates range from $110 to $450.
General Financial Planning Services
PMFA provides consulting services in connection with personal financial matters. These services are offered through private
consultations and through seminars and workshops. Our services range from a one-time consultation to a long-term
relationship during which we provide financial planning services to fit client needs.
Areas of service include:
• Tax planning
• Retirement planning
• Estate planning assistance
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• Business succession planning
• Insurance consulting
• Seminars and workshops
We also offer tax preparation services for individuals, businesses, trusts, and estates through our affiliate Plante & Moran,
PLLC. Fees for these services (except for seminars and workshops) are based on time incurred at our standard hourly billing
rates plus direct costs. Fees for seminars and workshops are based on a flat fee per participant and vary according to the
program.
Fee Calculation Methodology
PMFA calculates and bills fees quarterly in arrears. Unless otherwise agreed upon, fees will be based on the fair market value
using the average daily balance of the assets for the calendar quarter and prorated for the actual number of days the Agreement
is in effect during that quarter. If you have a margin balance, your margin debit does not reduce the fair market value of the
assets being advised. If the relationship is terminated, the fees for the last quarter will be based on the average daily balance of
the Assets from the first day of the quarter through one day prior to the date of termination, prorated for the actual number of
days that the Agreement was in effect during the quarter.
Our fees are deducted directly from client custodial account(s) by making such election on the account application(s). In the
event of multiple custodial accounts, fees will be calculated on such accounts in accordance with the services provided. Fees will
be withdrawn from such accounts as disclosed on the recurring billing invoices. If fees are not deducted directly from client
custodial account(s), then fees shall be due upon receipt of a billing statement from PMFA. Late charges will apply to any
portion not paid within 30 days at a rate of 1.25 percent per month, starting 30 days after the date of the invoice.
PMFA advisory fees do not include fees or expenses which are charged by mutual funds, product issuers, brokerage
commissions, transaction fees, separate account manager fees, or custodian fees. Clients whose assets are invested in mutual
funds and some other investment vehicles such as exchange-traded fund (ETF) securities pay a direct advisory fee to PMFA and
indirect management fees to the issuer.
Clients will pay fees imposed by custodians, brokers, and other third parties that include:
• Fees charged by mutual fund managers
• Fees charged by separate account managers
• Brokerage commissions
• Wire transfer and electronic fund transfer fees
• Custodian fees
• Mark-ups/mark-downs on security transactions
PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
PMFA does not offer performance-based fee programs (fees based on a share of capital gains on or capital appreciation of the
assets of a client) nor does the firm manage or advise on any investment products or programs that would result in side-by-side
management with client accounts.
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TYPES OF CLIENTS
PMFA provides investment advice to individuals, banks and thrift institutions, partnerships, limited liability companies, trusts,
estates, charitable organizations, corporations, and other business entities.
PMFA manages investment adisory accounts and, unless waived, imposes a minimum dollar value of assets of $500,000 and may
have other conditions for providing services.
TYPES OF INVESTMENTS
PMFA offers investment advice on and uses the following types of investments for implementation of client portfolios:
• Open-end mutual funds
• Exchange-traded funds (ETFs)
• Collective trusts
• Certificates of deposit
• Limited partnership interests
• Interests in limited liability companies
• Options contracts on securities
• Hedge funds and fund-of-funds
• Other alternative investments
Additionally, PMFA may offer investment advice on the following types of investments:
• Equity securities (including exchange-listed securities, over-the-counter securities, and foreign issues)
• Structured notes
• Warrants
• Corporate debt securities
• Commercial paper
• Municipal securities
• U.S. government securities
• Closed-end funds
PMFA recommends the services of Separate Account Managers when appropriate for specific client circumstances.
METHODS OF ANALYSIS, SOURCES OF INFORMATION, INVESTMENT STRATEGIES, AND
RISK OF LOSS
PMFA’s security analysis methods include fundamental and technical analysis and cyclical analysis.
Our investment research group uses an internally developed, proprietary equity market valuation model as a tool for evaluating
current market conditions and determining equity model allocations. This model considers commonly used valuation statistics
(P/E, P/B, PCF ratios, and dividend yield), comparing current market valuations to long-term averages. We then compare the
results between asset classes and investment styles to identify potentially undervalued or overvalued segments of the equity
markets.
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PMFA uses various sources of information, including financial newspapers and magazines, research materials prepared by
others, corporate rating services, annual reports, prospectuses, and annual reports or other filings with the U.S. Securities and
Exchange Commission, and conference calls with fund portfolio managers.
Equity allocation investment strategies include managers that employ both long- and short-term strategies. For some clients,
PMFA may recommend option strategies (including covered options, uncovered options, and spread strategies), and may refer
clients to a third-party provider for certain options strategies.
Fixed income allocations include managers that seek to invest in a range of fixed income assets and credit classes to generate
attractive risk-adjusted returns through current income and, to a lesser extent, capital appreciation.
Managers selected for both equity and fixed income allocations may employ leverage and/or the use of derivatives to increase
potential results. Such strategies involve higher risk and may result in greater losses than unleveraged strategies. Managers
selected may engage in certain arbitrage strategies from time to time, including convertible arbitrage and capital structure
arbitrage.
PMFA may recommend separate account investment management firms to manage a portion of client portfolios. PMFA does not
have trading authorization or otherwise direct the specific investments or investment strategies of such separate account
investment management firms.
PMFA may recommend alternative investment management firms to manage a portion of client portfolios. These alternative
investments may include, but are not limited to, hedge funds, private equity funds, direct real estate, commodities, and/or
fund-of-funds investments that use any or all of these investment strategies. PMFA does not have trading authorization or
otherwise direct the specific investments or investment strategies of such alternative investment management firms.
At the request of clients, PMFA may review investments that we have not recommended.
PMFA may also advise clients with concentrated individual security positions on diversifying these holdings using alternative
strategies. These strategies include, but are not limited to: sale of the security, option strategies, exchange funds, charitable
gifting, and gifting to family members in connection with estate planning. PMFA may also recommend that some or all of a
position be transferred to an annuity trust or remainder trust(s).
Clients may own securities which are not subject to PMFA advisory services. When these conditions exist, PMFA will encourage
clients to place any such securities in a separate custodial account not subject to the terms and conditions of the Consulting
Agreement.
Due to market value changes and appreciation in some asset classes over others, there will be times when asset allocations in
client accounts will vary from those indicated in the investment policy statement. PMFA considers rebalancing when the
actual percentage allocation to to any asset class varies materially (generally five percentage points or more) from its target
allocation. Subject to practical constraints, PMFA will also consider rebalancing when the actual percentage allocation of a sub-
asset class utilized within the portfolio varies by more than 20% from the target allocation. When necessary and/or available,
PMFA will be deploy cash inflows/outflows, in a manner consistent with our strategic asset allocation.
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Independent Advisor Group
PMFA is a member of the Independent Advisor Group (IAG). The IAG operates as a division of Callan Associates, Inc., a registered
investment adviser. The IAG provides applicants access to the following resources and services through non-affiliated third
parties:
• Asset simulation software
• A matrix of nationally ranked money managers who offer separate account management
• Mutual fund research
• Institutional custody services
The IAG directly provides manager searches and performance measurement reports services to PMFA.
The IAG is paid a negotiated fee by PMFA for access to the above-mentioned resources and services.
Risk of Loss
There are risks associated with investing that can result in the loss of principal. The primary risks associated with investing are
(i) market risk (the risk that the market value of the investment will decline), (ii) credit risk (the risk that the counterparty to
the transaction will default on its obligations), (iii) liquidity risk (the risk that the instrument will not be readily marketable),
and (iv) valuation risk (the risk that because the instrument is thinly traded, it will have limited pricing sources). Investments
that employ leverage can increase the risk of loss of principal.
DISCIPLINARY INFORMATION
PMFA is not currently, and has not been in the past, the subject of any disciplinary action by any regulator. No executive officer
or staff member of PMFA is the subject of any disciplinary action by any regulator.
OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
PMFA has arrangements that are material to its advisory business and its clients with a related person who is a broker-dealer,
insurance company or agency, trust company or real estate advisory service as described next.
Other Business Activities
PMFA is not engaged in any business other than providing investment and financial planning advice. The principal business of
PMFA and/or its principal executive officers does not involve anything other than these activities.
Related Entities
P&M Holding Group, LLP (a Delaware limited liability partnership) is a regional firm of certified public accountants. P&M
Holding Group, LLP is a member of PMFA and owns 100 percent of PMFA. From time to time, PMFA provides services to P&M
Holding Group, LLP.
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P&M Holding Group, LLP provides services to clients who are also clients of PMFA. In some cases, P&M Holding Group, LLP
provides PMFA with client billing and accounting services. In addition, P&M Holding Group, LLP provides office space and other
miscellaneous overhead items to PMFA for a fee which is determined on an annual basis.
Broker-Dealers
P&M Corporate Finance, LLC (PMCF) is a registered broker-dealer for the purpose of offering investment banking services to
middle-market companies. PMCF provides for planning, structuring, and execution of corporate finance transactions including
the sale of privately held companies, raising of buyout debt and leverage financings, management buyouts, acquisition support
of companies, and raising of growth capital in the form of private equity or debt (Reg D or Section 4(2) only). P&M Holding
Group, LLP is a member of Plante Moran Financial Advisors (PMFA) and P&M Holding Group, LLP owns 20 percent of PMCF.
From time to time, PMFA provides services to clients of PMCF and P&M Holding Group, LLP, who are also clients of PMFA.
Plante Moran Insurance Agency Services, LLC (PMIA) is a licensed insurance agency and a registered broker-dealer for the
purpose of offering variable insurance products. PMIA provides only insurance-related products on a commission basis and
does not offer mutual funds or individual securities. P&M Holding Group, LLP, which is a member of PMFA, owns 100 percent of
PMIA.
From time to time, PMFA provides services to clients of PMIA, who are also clients of PMFA. Additionally, PMFA clients have an
opportunity to purchase insurance products through PMIA, which receives a commission on the sale of these products. When a
recommendation is made to purchase life insurance products through PMIA for which a commission is received by PMIA, a
conflict of interest exists. All such compensation is disclosed in advance and taken into consideration when reaching a fee
arrangement with such client.
Trust Company
Plante Moran Trust, N.A. (PMT) is a nationally chartered trust bank. P&M Holding Group, LLP is a member of PMFA and owns
100 percent of P&M Holding Company, Inc., which in turn owns 100 percent of PMT. PMFA provides services to PMT clients
pursuant to an Agreement between PMFA and PMT. Fee arrangements for services provided to clients of PMT are established
based upon the terms of the Agreement. The affiliate relationship between PMFA and PMT, including compensation for clients
of PMT serviced by PMFA or compensation paid to PMT by PMFA creates a conflict of interest since the enterprise as a whole
retains compensation for recommending the related entity that would otherwise be paid to a third-party. This conflict is
mitigated since PMT clients can select their own advisor, PMT has negotiated rates on behalf of its clients and, additionally,
there are access and servicing benefits as a result of the relationship between PMFA and PMT.
Investment Adviser
Plante Moran Real Estate Investment Advisors, LLC, doing business as Plante Moran Realpoint Investment Advisors (“PMREIA”)
is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”) engaged in providing
non-discretionary, real estate securities-related investment advisory services. PMREIA is an affiliate of P&M Holding Group,
LLP. PMREIA was formed as a limited liability company in 2013 and requested registration as an investment adviser with the
SEC in January 2023. PMREIA is owned by P&M Holding Group, LLP, and by Realpoint Member, LLC. Ownership of P&M Holding
Group, LLP and Realpoint Member, LLC, respectively, is spread among the various professionals associated with the Plante
Moran organization. PMREIA also offers Non-RIA Services related to real estate holdings, real estate and development-oriented
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consulting services, and real estate-oriented consulting services. PMFA has retained PMREIA to provide advisory services
related to real estate securities and compensates PMREIA for those services. If appropriate PMFA will recommend the non-
advisory services of PMREIA to its clients. This creates a conflict with clients of PMFA who are also clients of PMREIA because
PMFA compensates PMREIA for services that could otherwise be provided by a third party. Therefore, in such circumstances,
compensation is retained within the enterprise that would not otherwise be retained. This conflict is mitigated since clients will
not pay additional advisory fees to PMFA for services provided by PMREIA to PMFA.
BlackRock RIA Advisory Council
An employee of PMFA is a member of the BlackRock RIA Advisory Council. The council provides input and opinions to assist
BlackRock with product and service initiatives. BlackRock provides the cost of travel and lodging expenses to attend council
events; however, no direct compensation is received for serving on the council. PMFA does recommend BlackRock investments.
We do not believe membership on this board presents a serious conflict of interest or improperly influences our investment
recommendations.
CODE OF ETHICS
PMFA has adopted a Code of Ethics expressing the Firm's commitment to ethical conduct and establishes standards of conduct
for PMFA officers and staff. The Code of Ethics includes requirements that PMFA personnel comply with their fiduciary
obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading
and insider trading. Any individual not in observance of the Code of Ethics subject to disciplinary action. It requires PMFA
personnel to submit quarterly and annual disclosures of trade activity in brokerage accounts (or accounts capable of holding
covered securities) directly to the Compliance Department of PMFA, and requires the Chief Compliance Officer or a delegate to
review those reports.
The Code of Ethics deems each staff person (including temporary staff) who participates in or obtains information concerning
PMFA’s client accounts an “access person.” The filing requirements extend to the staff person’s immediate family members in
the same household, accounts in which they have a beneficial interest, or accounts over which they exercise control.
It is the expressed policy of PMFA that no person employed by PMFA shall prefer his or her own interest to that of an advisory
client or make personal investment decisions based on the investment management trading activities of an advisory client.
PMFA's Code of Ethics requires PMFA staff to pre-clear all purchases and sales of covered securities. Staff may buy or sell
securities for their personal accounts identical to or different from those recommended to clients. Preclearance is not required
for purchases and sales of open-ended mutual funds, obligations of the U.S. government, digital assets, and money market or
similar instruments such as bank certificates of deposits.
PMFA's Code of Ethics further includes the firm's policy prohibiting the use of material non-public information. While PMFA
does not believe that it has any particular access to non-public information, all employees are reminded periodically that such
information may not be used in a personal or professional capacity.
Copies of the PMFA Code of Ethics are available upon request by contacting us at Plante Moran Financial Advisors, Attn: David
T. Doyle, Chief Compliance Officer, 3000 Town Center, Suite 100, Southfield, MI 48075 or by sending an e-mail to
dave.doyle@plantemoran.com.
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PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
From time to time, officers, directors, and employees of PMFA may purchase or sell the same open-end mutual fund shares and
ETFs or alternative investments that it recommends to clients. Similarly, PMFA may recommend the purchase or sale by clients
of open-end mutual fund shares, ETFs, alternative investments or individual securities owned by PMFA personnel or related
persons. Because of the nature of open-ended mutual fund shares, we believe no conflict of interest is present. PMFA staff may
trade exchange-traded fund (ETF) securities or individual securities which are bought and sold on the same basis as clients.
Client transactions will always take precedence over transactions by PMFA staff. Transactions in Covered Securities by staff
deemed access persons require review and preapproval by either the Chief Compliance Officer, Chief Operating Officer, or
President of PMFA, or their designees, prior to placing the trade.
BROKERAGE PRACTICES
General
We recommend custodians/brokers to hold client assets and execute transactions. When considering whether the terms
provided are, overall, most advantageous to clients when compared with other available providers and their services we take
into account a wide range of factors, including:
Combination of transaction execution services and asset custody services
Capability to execute, clear and settle trades
Capability to facilitate transfers and payments to and from accounts
Competitiveness of the price of services
Prior service to PMFA and PMFA’s clients
Services delivered or paid for by custodian
•
•
•
• Breadth of available investment products
• Availability of investment research and tools that assist us in making investment decisions
• Quality of services
•
• Reputation, financial strength, security and stability
•
•
• Availability of other products and services that benefit PMFA, as discussed in this brochure
PMFA is not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides
execution quality comparable to other brokers or dealers.
PMFA has no affiliations or soft dollar agreements with third parties in connection with client transactions. PMFA receives no
cash compensation other than the investment advisory or consultation fees paid by its clients.
Custodial Brokerage Accounts – Charles Schwab & Co., Inc.
Charles Schwab & Co., Inc., a registered broker-dealer, member SIPC, is one of the custodial firms that PMFA recommends to
clients for establishing brokerage accounts to maintain custody of client assets and to effect trades for their accounts. PMFA is
independently owned and operated and not affiliated with Schwab. Schwab will hold client assets in a brokerage account and
buy and sell securities when PMFA or client instructs them to. While PMFA may recommend that clients use Schwab as a
custodian/broker, clients will decide whether to do so and will open accounts with Schwab by entering into an account
agreement directly with them. Charges and fees for Schwab’s services will be disclosed in their agreements with clients or in
other disclosure documents and will be in addition to fees that clients pay to PMFA.
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Conflicts of interest associated with this arrangement are described below as well as in “Client Referrals and Other
Compensation.” Clients should consider these conflicts of interest when selecting a custodian.
Schwab provides PMFA with access to its institutional trading and custody services, which are typically not available to Schwab
retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge
to them so long as a total of at least $10 million of advisor's clients' assets are maintained in accounts at Schwab Institutional,
and are not otherwise contingent upon PMFA committing to Schwab any specific amount of business (assets in custody or
trading). Schwab's services include brokerage, custody, research, and access to mutual funds and other investments that are
otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment.
PMFA uses the research provided by Schwab to benefit all our clients whether or not they custody their assets at Schwab.
Schwab also makes available to PMFA other products and services that benefit PMFA but may not benefit its clients' accounts.
Some of these products and services assist PMFA in managing and administering client accounts. Schwab Advisor Services also
makes available to PMFA other services intended to help PMFA manage and further develop its business enterprise. These
services include consulting, conferences on practice management, speakers at PMFA conferences, regulatory compliance, and
marketing. In addition, Schwab may make available, arrange, and/or pay for these types of services rendered to PMFA by
independent third parties. Schwab may also reimburse or waive expenses related to PMFA staff attendance at Schwab sponsored
events. While PMFA, as a fiduciary, endeavors to act in its clients' best interests, PMFA’s recommendation that clients maintain
their assets in accounts at Schwab is influenced, in part, by the benefit to PMFA of the availability of some of the foregoing
products and services, which creates a conflict of interest. This conflict is mitigated by the client’s ability to select other
custodians and because we believe Schwab provides custodial services at a reasonable cost.
For PMFA's client accounts maintained in its custody, Schwab generally does not charge separately for custody, but is
compensated by account holders through commissions or other transaction-related fees for securities trades that are executed
through Schwab or that settle into Schwab accounts. Certain trades, including those for certain mutual funds and ETFs, do not
incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your
account in Schwab's Cash Features Program.
Custodial Brokerage Accounts – Fidelity Investments
Fidelity Investments (“Fidelity”) a registered broker-dealer, member SIPC, is another custodial firm made available by PMFA to
maintain custody of client assets and to effect trades for their accounts. PMFA is independently owned and operated and not
affiliated with Fidelity. Fidelity provides PMFA with access to its institutional trading and custody services, which are not
typically available to Fidelity retail investors. These services generally are available to independent investment advisors on an
unsolicited basis, at no charge to them. Fidelity's services include brokerage, custody, and access to mutual funds and other
investments that are generally available only to institutional investors or would require a significantly higher minimum initial
investment. PMFA uses any research or market updates provided by Fidelity to benefit all our clients whether or not they
custody their assets at Fidelity.
Fidelity also makes available to PMFA other products and services that benefit PMFA but do not directly benefit its clients'
accounts. Some of these products and services assist PMFA in managing and administering client accounts. Fidelity
Institutional also makes available to PMFA other services intended to help PMFA manage and further develop its business
enterprise. These services include consulting, conferences on practice management, regulatory compliance, and marketing. In
addition, Fidelity may make available, arrange, and/or pay for these types of services rendered to PMFA by independent third
parties. While PMFA, as a fiduciary, endeavors to act in its clients' best interests, PMFA’s recommendation that clients maintain
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their assets in accounts at Fidelity is influenced, in part, by the benefit to PMFA of the availability of some of the foregoing
products and services, which creates a conflict of interest. This conflict is mitigated by the client’s ability to select other
custodians and because we believe Fidelity provides custodial services at a reasonable cost.
For PMFA's client accounts maintained in its custody, Fidelity does not charge separately for custody, but is compensated by
account holders through commissions or other transaction-related fees for securities trades that are executed through Fidelity
or that settle into Fidelity accounts. Fidelity provides disclosures to clients regarding their costs and Fidelity’s compensation.
Directed Brokerage and Use of Other Custodians
On occasion, clients will request referrals of full-service brokerage firms or brokers at those firms. In these cases, PMFA will
provide information on several brokerage firms or brokers at those firms it believes are appropriate. The client will then
interview and select from among the candidates. In no case does PMFA or related personnel receive any remuneration from any
brokerage firm or brokers at those firms.
Clients may elect to use a custodian and/or brokerage firm other than those listed above. Using a different custodian and/or
brokerage firm may result in additional costs or in transaction fees and commissions that are higher or lower than those of the
custodian recommended by PMFA. Using a different custodian and/or brokerage firm may result in price or execution different
than what can be obtained from the custodian recommended by PMFA and may restrict the ability of PMFA to negotiate
commissions and fees.
Separate Account Managers
For those situations in which a money manager has discretionary authority to manage a separate custody account of a client of
PMFA, it is the sole discretion of the manager and/or client as to the brokerage firm utilized to execute trades in the client's
account.
Plante Moran Trust
Plante Moran Trust, N.A. (PMT), when serving as trustee, has the authority to determine the securities to be bought or sold,
their amounts, the broker or dealer to be used, and the commission rates paid. PMT is also a client of PMFA with respect to
certain trust accounts. An investment management agreement between PMT and PMFA exists. Under this agreement PMFA
provides PMT advice on the investment of PMT client assets. Depending upon the specific relationship, the services may be
discretionary or nondiscretionary. PMT pays PMFA a fee for these services. In certain instances, PMFA compensates PMT for
fees related to trust servicing that would otherwise be charged to the client. This conflict is mitigated by the fact that
compensation is not paid by the affected clients.
Trade Errors
PMFA has policies, procedures, and internal controls designed to prevent trade errors. While we strive to be error free, due to
the number of client transactions processed, we recognize that errors will occur. It is the policy of PMFA that clients do not
incur a loss resulting from a trade or administrative error which is attributable to PMFA. Whenever possible and as soon as
practical after the error has been discovered, PMFA will reallocate any erroneous trade into a trade error account. If the error
results in a loss, PMFA will assume the loss. It is possible that Clients may not profit from the error, even if the correction
results in a gain. Trade corrections require us to process a cancellation of the incorrect trade in the client account and submit a
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trade with the correct trade conditions; correct number of shares, price, etc. As a result of this procedure, post correction a
client account in which an error occurred will reflect a trade as it should have correctly been processed.
PMFA may not be able to maintain a trade error account with every custodian (e.g., accounts at client directed brokers or
banks). In these instances, PMFA may compensate client for losses resulting from a trade or administrative error attributable
to PMFA via a reduction in the client's account fees.
Trade Allocation
Transactions for each client generally will be effected independently. PMFA may (but is not obligated to) combine or “batch”
such orders to obtain best execution, to obtain more favorable transaction terms, or to allocate equitably among PMFA’s clients
differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed
independently. PMFA does not receive any additional compensation or remuneration as a result of the aggregation.
PMFA has a fiduciary duty to act in the best interests of its advisory clients. It is the policy of PMFA to provide equal and fair
treatment to clients. No client should receive preferential treatment over any other. In particular, trades may not be allocated
to one client over another to:
• Favor one client at the expense of another;
• Generate higher fees paid by one client over another or to produce greater performance compensation to PMFA;
• Develop a relationship with a client or prospective client;
• Compensate a client for fee differentials, past services or benefits rendered to PMFA or to induce future services or
benefits to be rendered to PMFA; or
• Equalize performance among different clients.
Because of the diversity of objectives, risk tolerances, tax situations, and differences in the timing of capital contributions and
withdrawals, client investment positions and the placement of trades will inevitably differ among clients. PMFA intends to
execute trades in client accounts on a timely basis in a manner that is fair and equitable to the maximum possible extent to each
client.
Private Placement Securities
On occasion, PMFA may be invited by an issuer to participate in an offering of private placement securities. PMFA will only
consider recommending such securities to clients who meet the eligibility requirements for private placement securities and for
whom an investment in such securities is suitable. Criteria include, but are not limited to: risk tolerance, investment time
horizon, liquidity of other assets, prior investment experience, and overall portfolio diversification. Due to suitability
determinations, these investments may not be made available to all clients.
Shareholder Class Action Lawsuits
PMFA will assist clients with the completion of proof of claim forms and, to the extent available, provide trade information
and/or custodian statements to support any such claims. Unless otherwise provided for, PMFA will not file or submit claims on
behalf of clients. PMFA will not track the status of any such claims or collect settlements on the behalf of clients.
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REVIEW OF ACCOUNTS
A Relationship Manager, with extensive experience, is assigned to each account and is responsible for monitoring and
maintaining compliance with client-specific guidelines. Formal reviews are performed at least quarterly and include client
portfolio structure, strategies, adherence to client investment policy and guidelines, and benchmarks. More frequent reviews
that occur on an ongoing basis include market conditions, portfolio holdings and transactions, cash flows and account
performance. Account reviews can also be triggered by general economic conditions, fund reports, news information,
performance publications, income tax changes, changes in client investment objectives or financial situation, and client
requests.
Account and performance information is provided to clients electronically, unless the client opts out of electronic delivery.
Clients are encouraged to compare the account balances and positions provided by us to those balances reflected on the
statements received directly from account custodians. Clients should contact us or the account custodian with any questions
they may have. Also, clients should notify us promptly if statements on all accounts are not received from the custodian on at
least a quarterly basis.
CLIENT REFERRALS AND OTHER COMPENSATION
PMFA receives client referrals from Charles Schwab & Co., Inc. (“Schwab”) through PMFA’s participation in Schwab Advisor
Network® (“the Service”). The Service is designed to help investors find an independent investment advisor. Schwab is a broker-
dealer independent of and unaffiliated with PMFA. Schwab does not supervise PMFA and has no responsibility for PMFA’s
management of clients’ portfolios or other advice or services. PMFA pays Schwab fees to receive client referrals through the
Service. PMFA’s participation in the Service raises conflicts of interest described below.
PMFA pays Schwab a Participation Fee on all referred clients’ accounts that are maintained in custody at Schwab and a Non-
Schwab Custody Fee on all accounts that are maintained at, or transferred to, another custodian. The Participation Fee paid by
PMFA is a percentage of the fees the client owes to PMFA or a percentage of the value of the assets in the client’s account,
subject to a minimum Participation Fee. PMFA pays Schwab the Participation Fee for so long as the referred client’s account
remains in custody at Schwab. The Participation Fee is billed to PMFA quarterly and may be increased, decreased, or waived by
Schwab from time to time. The Participation Fee is paid by PMFA and not by the client. PMFA has agreed not to charge clients
referred through the Service fees or costs greater than the fees or costs PMFA charges clients with similar portfolios who were
not referred through the Service.
PMFA generally pays Schwab a Non-Schwab Custody Fee if custody of a referred client’s account is not maintained by, or assets
in the account are transferred from Schwab. This Fee does not apply if the client was solely responsible for the decision not to
maintain custody at Schwab. The Non-Schwab Custody Fee is a one-time payment equal to a percentage of the assets placed
with a custodian other than Schwab. The Non-Schwab Custody Fee is higher than the Participation Fees Advisor generally would
pay in a single year. Thus, PMFA will have an incentive to recommend that client accounts be held in custody at Schwab.
The Participation and Non-Schwab Custody Fees will be based on assets in accounts of PMFA’s clients who were referred by
Schwab and those referred clients’ family members living in the same household. Thus, PMA will have incentives to encourage
household members of clients referred through the Service to maintain custody of their accounts and execute transactions at
Schwab and to instruct Schwab to debit PMFA’s fees directly from the accounts.
For accounts of PMFA’s clients maintained in custody at Schwab, Schwab will not charge the client separately for custody but
will receive compensation from PMFA’s clients in the form of commissions or other transaction-related compensation on
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securities trades executed through Schwab. Schwab also will receive a fee (generally lower than the applicable commission on
trades it executes) for clearance and settlement of trades executed through broker-dealers other than Schwab. Schwab’s fees for
trades executed at other broker-dealers are in addition to the other broker-dealer’s fees. Thus, PMFA may have an incentive to
cause trades to be executed through Schwab rather than another broker-dealer. PMFA nevertheless, acknowledges its duty to
seek best execution of trades for client accounts. Trades for client accounts held in custody at Schwab may be executed through
a different broker-dealer than trades for PMFA’s other clients. Thus, trades for accounts custodied at Schwab may be executed
at different times and different prices than trades for other accounts that are executed at other broker-dealers.
Our professionals are paid a base compensation and may receive a performance-based bonus. Although, they do not receive
differential compensation based on the products sold or product sales commissions, a conflict exists inasmuch as raises and
bonuses are based upon factors that include client acquisition and asset growth.
CUSTODY
PMFA is deemed to have custody of certain client funds and/or securities due to its affiliated entity, Plante Moran Trust, and
when PMFA provides services to certain accounts. PMFA is also deemed to have custody when it directly debits advisory fees
from client custodian accounts. In accordance with Rule 206(4)-2 of the Investment Advisers Act of 1940, all cash and securities
are maintained with a qualified custodian, clients receive account statements directly from the custodian at least quarterly, and
all clients receive written notification of the name of the custodian and contact information. This information is found on the
statements provided by the custodian.
Client account custodians will provide account statements directly to account holders. In addition, PMFA will provide
information regarding client account(s) which is based on sources we believe to be reliable and accurate. Clients should compare
the account balances and positions provided by PMFA to those balances reflected on your statements received directly from the
account custodian. If clients have any questions, they should contact us or the account custodian. Clients should notify us
promptly if they do not receive statements from all their account custodian(s) on at least a quarterly basis.
INVESTMENT DISCRETION
PMFA services are provided on either a discretionary or non-discretionary basis. Discretionary management allows PMFA to
determine the investments to buy or sell without obtaining specific client consent. However, the selection of investments for
discretionary accounts is based upon each client's investment objectives, risk tolerance, and financial situation. Individual risk
limitations, suitability, and appropriateness are discussed with each client and his/her Relationship Manager prior to an
engagement and are documented in the investment policy statement provided to each client. We also manage advisory accounts
without discretion, meaning specific client consent must be granted prior to each transaction. Clients have an unrestricted
right to decline to implement any advice issued on a non-discretionary basis.
In all cases, clients have the opportunity to place reasonable restrictions on the types of investments that will be made on their
behalf. We reserve the right to not accept or terminate an account if we believe the restrictions imposed impair our ability to
service the client.
Rights Retained by Client with Respect to Securities and Funds
Advisory clients who delegate investment discretion to PMFA have the ability to impose reasonable restrictions on the
investments made within their account(s) or reasonably modify existing restrictions they may have already imposed.
Reasonable restrictions include the designation of particular securities or types of securities (e.g., mutual funds with
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investments in the tobacco industry) that should not be purchased or that should be sold if held in an account. However, if
investment discretion has been delegated to PMFA, it may be determined that the implementation of such a restriction may be
impractical. In the event such a determination is made, PMFA will be notify the client promptly. PMFA reserves the right to not
accept or terminate an account if we believe the restrictions imposed are not reasonable.
Proxy Voting
PMFA shall have no obligation or authority to take any action or render any advice with respect to the voting of proxies solicited
by or with respect to issuers of securities held in client accounts.
FINANCIAL INFORMATION
PMFA does not believe there are any financial impairments that hinder our ability to meet our contractual commitments to our
clients. PMFA does not collect client fees in advance.
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CONSUMER PRIVACY NOTICE
Protecting your privacy is important to us. We want our customers to understand what information we collect and how we use
it. We will continue to adhere to the privacy policies and practices described in this notice even after your account is closed or
becomes inactive. We may amend our policy at any time, and will inform you of any changes as required by law.
FACTS
Why?
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but
not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read
this notice carefully to understand what we do.
What?
The types of personal information we collect and share depend on the services you receive from us. This information can
include:
Your Social Security number and investment experience
Account balances and assets
Account transactions and transaction history
How?
All financial companies need to share customer personal information to run their everyday business. In the section on the next
page, we list the reasons financial companies can share their customers’ personal information, the reasons Plante Moran
Financial Advisors, LLC chooses to share, and whether you can limit this sharing.
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DOES PMFA SHARE?
CAN YOU LIMIT THIS SHARING?
REASONS WE CAN SHARE YOUR
PERSONAL INFORMATION
Yes
No
For our everyday business
purposes—such as to process your
transactions, maintain your
account(s), respond to court orders
and legal investigations,
or report to regulatory agencies.
For our marketing purposes—
Yes
No
To offer our products and services
to you.
No
We don’t share.
For joint marketing with other
financial companies.
Yes
No
See State Law section below for other
options.
For our affiliates’ everyday business
purposes —
Information about your
transactions and experiences.
No
We don’t share.
For our affiliates’ everyday business
purposes —
Information about your
creditworthiness.
Yes
Yes
For our affiliates to market to
you.
You may elect to “opt-out” of marketing
received directly from our affiliates.
For nonaffiliates to market to you.
No
We don’t share
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WHAT WE DO
How does PMFA protect my personal information?
To protect your personal information from unauthorized access and use, we use security measures that comply with federal
law. These measures include computer safeguards and secured files and buildings. Third parties that provide support services
on our behalf may also receive personal information about you, and we require that they adhere to confidentiality standards
with respect to any such information.
How does PMFA collect my personal information?
We collect your personal information, for example, when:
You enter into an investment advisory contract
We assist you with opening an account at a qualified custodian/brokerage firm
We prepare financial independence projections
You direct us to buy securities or direct us to sell your securities
You seek advice about your investments
Why can’t I limit all sharing?
Federal law gives you the right to limit only:
Sharing for affiliates’ everyday business purposes, information about your creditworthiness
Affiliates from using your information to market to you
Sharing for nonaffiliates to market to you
State laws and individual companies may give you additional rights to limit sharing. (See below for more on your rights under
state law.)
What happens when I limit sharing for an account I hold jointly with someone else?
Unless specified otherwise, an opt-out request will extend to all accounts in your client relationship. Examples include accounts
owned jointly with your spouse, related revocable trust accounts, and minor children’s UTMA accounts. Related accounts with
other owners or signatories will not be affected, for example, an irrevocable trust with a trustee other than you.
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DEFINITIONS
Affiliates: Companies related by common ownership or control. They can be financial and nonfinancial companies.
Our affiliates include financial companies with a Plante & Moran name and other financial companies such as P&M Corporate
Finance.
Nonaffiliates: Companies not related by common ownership or control. They can be financial and nonfinancial companies.
PMFA does not share with nonaffiliates so they can market to you. PMFA may share information with nonaffiliates that assist
us with servicing your accounts, such as securities broker-dealers, custodians, and service providers that assist us with
information transfers. PMFA may share information with joint account holders and those with whom you have consented to our
sharing your information, such as tax advisers, attorneys, and bank officers.
Joint marketing: A formal agreement between nonaffiliated financial companies that together market financial products or
services to you.
PMFA doesn’t jointly market.
STATE LAW
You may have other privacy protections under state law. Our information sharing procedures will comply with all applicable
state laws .Residents of certain states may receive additional information concerning use and sharing of information.
California: In accordance with California law, we will not share information we collect about you with companies outside of
PMFA, unless the law allows. We will limit sharing among our affiliated entities to the extent required by California law.
QUESTIONS?
If you have any questions regarding this notice or how to opt out of any information sharing with our affiliates, please contact
either your Relationship Manager or our compliance department at 248.223.3611 or 312.928.5349.
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SOLICITATION AND MARKETING BY AFFILIATES
Plante Moran Financial Advisors is providing you with this notice regarding solicitation and marketing by entities affiliated
with us.
Federal law provides you the right to limit marketing from our affiliates. As such, we are providing you with this notice to
inform you about your choice to limit marketing from our affiliates.
You may limit our affiliates in P&M Holding Group, LLP (Plante & Moran), such as our insurance services, trust company, and
investment banking affiliates, from marketing their products or services to you based on your personal information that we
collect and share with them (“opt-out”). This information includes your personal contact information such as telephone number
and address. It may also include your e-mail address.
Client’s choice to limit marketing offers from our affiliates will remain effective until you instruct us in writing to the contrary.
After consultation with you, should it be determined that an affiliate can provide services you require, your decision to opt-out
will not restrict us from recommending an affiliate entity to you. If you have multiple account relationships with PMFA and
elect to “opt-out,” this election will extend to all your account relationships with PMFA unless you specify differently.
To limit marketing offers or to “opt out,” please contact us:
By telephone: Compliance Department 248.223.3611 or 312.928.5349
On the Web:
www.plantemoran.com/services/wealth-management
By mail: Check the box, print your name, and send to:
Plante Moran Financial Advisors, LLC
Attn: Compliance Department
3000 Town Center Dr., Suite 100
Southfield, MI 48075
Do not allow your affiliates to use my personal information to market to me.
Name: _______________________________________________ (please print)
Relationship Manager: _______________________________________________
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