Overview
- Headquarters
- Eden Prairie, MN
- Average Client Assets
- $0.9 million
- SEC CRD Number
- 284430
Fee Structure
Primary Fee Schedule (ADV PART 2A & 2B)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 2.00% |
| $500,001 | $1,000,000 | 1.75% |
| $1,000,001 | $2,000,000 | 1.50% |
| $2,000,001 | $5,000,000 | 1.25% |
| $5,000,001 | and above | 1.00% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $18,750 | 1.88% |
| $5 million | $71,250 | 1.42% |
| $10 million | $121,250 | 1.21% |
| $50 million | $521,250 | 1.04% |
| $100 million | $1,021,250 | 1.02% |
Clients
- HNW Share of Firm Assets
- 68.53%
- Total Client Accounts
- 6,600
- Discretionary Accounts
- 6,600
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting
Regulatory Filings
Additional Brochure: ADV PART 2A & 2B (2026-02-14)
View Document Text
F O R M A D V P A R T 2 A
D I S C L O S U R E B R O C H U R E
P R E P A R E D I N C O M P L I A N C E W I T H
T H E I N V E S T M E N T A D V I S E R S A C T O F 1 9 4 0 R U L E 2 0 4 - 3 ( A )
Strategic Wealth Group Registered
Investment Advisor, LLC
Office Address:
7820 Terrey Pine Ct, #200
Eden Prairie, MN 55347
Tel: 952-843-4944
Fax: 952-666-5117
Tyler.h@strategicwg.net
F E B R U A R Y 1 4 , 2 0 2 6
This brochure provides information about the qualifications and business practices of
Strategic Wealth Group Registered Investment Advisor, LLC. Being registered as a registered
investment adviser does not imply a certain level of skill or training. If you have any questions
about the contents of this brochure, please contact us at 952-955-7865. 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 Strategic Wealth Group Registered Investment Advisor, LLC
(CRD #284430) is available on the SEC’s website at www.adviserinfo.sec.gov
i
Item 2: Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material
Material Changes since the Last Update
changes occur since the previous release of the Firm Brochure.
•
Since the last update on May 28, 2025, the following changes have occurred:
•
Item 4 assets under management calculation updated.
Full Brochure Available
Item 5 has been updated to disclose updated financial planning fees.
This Firm Brochure is the complete brochure for the Firm.
ii
Item 3: Table of Contents
Form ADV – Part 2A – Firm Brochure
Item 1: Cover Page
Item 2: Material Changes .................................................................................................................... ii
Annual Update ................................................................................................................................................. ii
Material Changes since the Last Update ............................................................................................... ii
Item 3: Table of Contents ................................................................................................................... iii
Full Brochure Available ............................................................................................................................... ii
Item 4: Advisory Business .................................................................................................................. 1
Firm Description ............................................................................................................................................ 1
Types of Advisory Services ........................................................................................................................ 1
Wrap Fee Programs ...................................................................................................................................... 6
Item 5: Fees and Compensation ....................................................................................................... 6
Client Assets Under Management ............................................................................................................ 6
Method of Compensation and Fee Schedule........................................................................................ 6
Client Payment of Fees ...............................................................................................................................10
Additional Client Fees Charged ..............................................................................................................10
Prepayment of Client Fees ........................................................................................................................11
Item 6: Performance-Based Fees and Side-by-Side Management ...................................... 11
External Compensation for the Sale of Securities to Clients .......................................................11
Item 7: Types of Clients ..................................................................................................................... 11
Sharing of Capital Gains .............................................................................................................................11
Description .....................................................................................................................................................11
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .............................. 12
Account Minimums .....................................................................................................................................11
Methods of Analysis ....................................................................................................................................12
Investment Strategy ....................................................................................................................................12
Item 9: Disciplinary Information ................................................................................................... 13
Security Specific Material Risks .............................................................................................................12
Criminal or Civil Actions ...........................................................................................................................13
Administrative Enforcement Proceedings .........................................................................................13
Self-Regulatory Organization Enforcement Proceedings .............................................................13
iii
Strategic Wealth Group Registered Investment Advisor, LLC
Item 10: Other Financial Industry Activities and Affiliations ............................................. 13
Broker-Dealer or Representative Registration ................................................................................13
Futures or Commodity Registration .....................................................................................................13
Material Relationships Maintained by this Advisory Business and Conflicts of Interest 13
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal
.............................................................................................................................................................................14
Trading ................................................................................................................................................... 15
Code of Ethics Description .......................................................................................................................15
Investment Recommendations Involving a Material Financial Interest and Conflict of
Interest .............................................................................................................................................................15
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest .............................................................................................................................................................15
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Item 12: Brokerage Practices ......................................................................................................... 16
Transactions and Conflicts of Interest .................................................................................................16
Factors Used to Select Broker-Dealers for Client Transactions .................................................16
Item 13: Review of Accounts ........................................................................................................... 18
Aggregating Securities Transactions for Client Accounts ............................................................17
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved ..........................................................................................................................................18
Review of Client Accounts on Non-Periodic Basis ..........................................................................18
Item 14: Client Referrals and Other Compensation ................................................................ 18
Content of Client Provided Reports and Frequency .......................................................................18
Economic Benefits Provided to Advisory Firm from External Sources and Conflicts of
Interest .............................................................................................................................................................18
Item 15: Custody .................................................................................................................................. 19
Advisory Firm Payments for Client Referrals ...................................................................................19
Item 16: Investment Discretion ..................................................................................................... 20
Account Statements ....................................................................................................................................19
Item 17: Potential Conflicts of Interest in Trading .................................................................. 20
Discretionary Authority for Trading ....................................................................................................20
Trading Fees ..................................................................................................................................................20
Item 18: Voting Client Securities ................................................................................................... 21
Mutual Funds Share Class Selection .....................................................................................................21
Proxy Votes ....................................................................................................................................................21
iv
Strategic Wealth Group Registered Investment Advisor, LLC
Item 19: Financial Information ...................................................................................................... 21
Balance Sheet .................................................................................................................................................21
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
Commitments to Clients ............................................................................................................................21
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 23
Bankruptcy Petitions during the Past Ten Years .............................................................................21
®
Tyler D. Hirth, CFP
....................................................................................................................................23
Item 2 Educational Background and Business Experience .........................................................23
Professional Designations: .......................................................................................................................23
Item 3 Disciplinary Information ............................................................................................................24
Item 4 Other Business Activities ............................................................................................................24
Item 5 Additional Compensation ...........................................................................................................25
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 27
Item 6 Supervision ......................................................................................................................................25
George W. Mulwee .......................................................................................................................................27
Item 2 Educational Background and Business Experience .........................................................27
Item 3 Disciplinary Information ............................................................................................................27
Item 4 Other Business Activities ............................................................................................................27
Item 5 Additional Compensation ...........................................................................................................28
Item 6 Supervision ......................................................................................................................................28
v
Strategic Wealth Group Registered Investment Advisor, LLC
Item 4: Advisory Business
Firm Description
Strategic Wealth Group Registered Investment Advisor, LLC (“Strategic Wealth Group”) was
founded and began offering investment advice in 2016. In July of 2024 the ownership
changed from Nathaniel H. Running to Running Wealth Management Group MN, Inc. which
Types of Advisory Services
is owned by Tyler Hirth.
ASSET MANAGEMENT
Strategic Wealth Group offers discretionary and non-discretionary direct asset management
services to advisory clients. The firm will offer clients ongoing portfolio management
services through determining individual investment goals, time horizons, objectives, and
risk tolerance. Investment strategies, investment selection, asset allocation, portfolio
monitoring and the overall investment program will be based on the above factors.
Discretionary
When the client provides Strategic Wealth Group discretionary authority the client will sign
a limited trading authorization or equivalent. Strategic Wealth Group will have the authority
to execute transactions in the account without seeking client approval on each transaction.
Non-discretionary
When the client elects to use Strategic Wealth Group on a non-discretionary basis, Strategic
Wealth Group will determine the securities to be bought or sold and the amount of the
securities to be bought or sold. However, Strategic Wealth Group will obtain prior client
approval on each and every transaction before executing any transactions.
Sub-Advisors
When deemed appropriate for the Client, Strategic Wealth Group may hire Sub-Advisors to
manage all or a portion of the assets in the Client account. Strategic Wealth Group has full
discretion to hire and fire Sub-Advisors as we deem suitable. Sub-Advisors will maintain the
models or investment strategies agreed upon between Sub-Advisor and Strategic Wealth
Group. Sub-Advisors execute trades on behalf of Strategic Wealth Group in Client accounts.
Strategic Wealth Group will be responsible for the overall direct relationship with the Client.
Strategic Wealth Group retains the authority to terminate the Sub-Advisor relationship at
Strategic Wealth Group’s discretion.
Department of Labor Acknowledgement of Fiduciary Duty.
•
When Strategic Wealth Group provides investment advice regarding retirement plan
accounts or individual retirement accounts, 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. How 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 interests 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;
1
•
•
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.
ASSETS HELD AWAY
Strategic Wealth Group uses a third party platform to facilitate management of held away
assets such as defined contribution plan participant accounts, with discretion. The platform
allows us to avoid being considered to have custody of Client funds since we do not have
direct access to Client log-in credentials to affect trades. We are not affiliated with the
platform in any way and receive no compensation from them for using their platform. A link
will be provided to the Client allowing them to connect an account(s) to the platform. Once
Client account(s) is connected to the platform, Strategic Wealth Group will review the
current account allocations. When deemed necessary, Strategic Wealth Group will rebalance
the account considering client investment goals and risk tolerance, and any change in
allocations will consider current economic and market trends. The goal is to improve account
performance over time, minimize loss during difficult markets, and manage internal fees that
harm account performance. Client account(s) will be reviewed at least quarterly and
allocation changes will be made as deemed necessary.
FINANCIAL PLANNING AND CONSULTING
Financial planning services include a comprehensive evaluation of an investor's current and
future financial state and will be provided by using currently known variables to predict
future cash flows, asset values and withdrawal plans. Strategic Wealth Group will use current
net worth, tax liabilities, asset allocation, and future retirement and estate plans in
developing financial plans.
Strategic Wealth Group offers the following financial planning and consultation services as
outlined below.
Full Financial Plan
Financial planning services include a comprehensive evaluation of an investor's current and
future financial state and will be provided by using currently known variables to predict
future cash flows, asset values and withdrawal plans. Strategic Wealth Group will use current
net worth, tax liabilities, asset allocation, and future retirement and estate plans in
developing financial plans.
Financial goals
Typical topics reviewed in a financial plan may include but are not limited to:
•
: Based on an individual's or a family's clearly defined financial goals,
including funding a college education for the children, buying a larger home, starting
a business, retiring on time or leaving a legacy. Financial goals should be quantified
Personal net worth statement
and set to milestones for tracking.
: A snapshot of assets and liabilities serves as a
•
Cash flow analysis
benchmark for measuring progress towards financial goals.
: An income and spending plan determines how much can be set
•
Retirement strategy
aside for debt repayment, savings and investing each month.
•
: A strategy for achieving retirement independent of other
financial priorities. Including a strategy for accumulating the required retirement
capital and its planned lifetime distribution.
2
Comprehensive risk management plan
•
Long-term investment plan
: Identify all risk exposures and provide the
necessary coverage to protect the family and its assets against financial loss. The risk
management plan includes a full review of life and disability insurance, personal
liability coverage, property and casualty coverage, and catastrophic coverage.
•
: Include a customized asset allocation strategy based
on specific investment objectives and a risk profile. This investment plan sets
guidelines for selecting, buying and selling investments and establishing benchmarks
Tax reduction strategy
for performance review.
•
Estate preservation
: Identify ways to minimize taxes on personal income to the
extent permissible by the tax code. The strategy should include identification of tax-
favored investment vehicles that can reduce taxation of investment income.
•
: Help update accounts, review beneficiaries for retirement
accounts and life insurance, provide a second look at your current estate planning
documents, and prompt you to update your plan when the legal environment changes
or you have major life events such as a marriage, death, or births.
If a conflict of interest exists between the interests of Strategic Wealth Group and the
interests of the Client, the Client is under no obligation to act upon Strategic Wealth Group’s
recommendation. If the Client elects to act on any of the recommendations, the Client is
under no obligation to effect the transaction through Strategic Wealth Group. Financial plans
will be completed and delivered inside of ninety (90) days contingent upon timely delivery
Hourly Consultation Services
of all required documentation.
This service is appropriate for clients who need assistance with individual topics. This is not
a detailed financial review and will not provide/result in a comprehensive financial plan.
Client may select individual topics above, or other topics as may be deemed appropriate. The
individual topics that will be included in this service will be outlined and agreed upon on the
financial planning and consulting agreement.
If a conflict of interest exists between the interests of Strategic Wealth Group and the
interests of the Client, the Client is under no obligation to act upon Strategic Wealth Group’s
recommendation. If the Client elects to act on any of the recommendations, the Client is
under no obligation to effect the transaction through Strategic Wealth Group. Financial plans
will be completed and delivered inside of ninety (90) days contingent upon timely delivery
Ongoing Financial Planning
of all required documentation.
Ongoing consultations are different than the planning offered above in that the clients are
looking for ongoing support and services as opposed to creating a one-time plan. Ongoing
• Complex estate planning
consultations consist of one or more of the items as described below:
o
o
o
o
o
Insurance
Legal Structures
• Business Consulting
Federal and State Estate Tax Mitigation
Charitable Gifting Strategies
Family Gifting Strategies
o
o
o
o
Group Health Plan
Employee Benefits
• Taxation
Retirement Plan
Tax Management
3
o
o
Medicare IRMAA Surcharge Management
Roth IRA Conversions
•
Asset Location
Tax Deferral
o
o
Investment Counseling
o
o
o
o
Asset Allocation
Due Diligence
Asset Accumulation
o
o
Property/Casualty/Liability
Long Term Care Planning
Disability Income Insurance
Health Insurance
•
• Risk Management
Diversification
o
o
o
Income planning
Life Insurance
o
o
o
o
Social Security Claiming
Investment Income
Asset Annuitization
Business Income
•
Ongoing Financial Planning services will include the following:
•
Initial meeting (in person or virtual) – up to two hours
•
Follow up meeting to deliver and discuss initial recommendations – up to 90
minutes
•
Written financial planning recommendations (paper and/or electronic) – updated
annually
•
Follow up meeting approximately every six (6) months to check on progress and
adjust recommendations as life, financial or otherwise, continues to evolve – up to
60 minutes
•
Regular accountability check-in emails to help client stay on track available upon
request
Phone or email access to answer questions
If a conflict of interest exists between the interests of Strategic Wealth Group and the
interests of the Client, the Client is under no obligation to act upon Strategic Wealth Group’s
recommendation. If the Client elects to act on any of the recommendations, the Client is
under no obligation to effect the transaction through Strategic Wealth Group. Ongoing
financial planning services will continue from year to year unless cancelled by the Client or
Strategic Wealth Group.
ERISA PLAN SERVICES
Strategic Wealth Group provides service to qualified and non-qualified retirement plans
including 401(k) plans, 403(b) plans, pension and profit sharing plans, cash balance plans,
and deferred compensation plans.
Strategic Wealth Group typically acts as a limited scope ERISA 3(21) fiduciary that can
advise, help and assist plan sponsors with their investment decisions on a non-discretionary
basis. As an investment advisor Strategic Wealth Group has a fiduciary duty to act in the best
interest of the client. The plan sponsor is still ultimately responsible for the decisions made
in their plan, though using Strategic Wealth Group can help the plan sponsor delegate
liability by following a diligent process.
1.
Fiduciary Services are:
4
Provide non-discretionary investment advice to the Client about asset classes and
investment alternatives available for the Plan in accordance with the Plan’s
investment policies and objectives. Client will make the final decision regarding
the initial selection, retention, removal and addition of investment options.
Assist the Client in the development of an investment policy statement (“IPS”).
The IPS establishes the investment policies and objectives for the Plan. Client shall
have the ultimate responsibility and authority to establish such policies and
objectives and to adopt and amend the IPS.
Provide non-discretionary investment advice to the Plan Sponsor with respect to
the selection of a qualified default investment alternative for participants who are
automatically enrolled in the Plan or who have otherwise failed to make
investment elections. The Client retains the sole responsibility to provide all
notices to the Plan participants required under ERISA Section 404(c) (5) and
404(a)-5.
2.
Non-fiduciary Services are:
Assist in the education of Plan participants about general investment information
and the investment alternatives available to them under the Plan. Client
understands Strategic Wealth Group’s assistance in education of the Plan
participants shall be consistent with and within the scope of the Department of
Labor’s definition of investment education (Department of Labor Interpretive
Bulletin 96-1). As such, Strategic Wealth Group is not providing fiduciary advice
as defined by ERISA 3(21)(A)(ii) to the Plan participants. Strategic Wealth Group
will not provide investment advice concerning the prudence of any investment
option or combination of investment options for a particular participant or
beneficiary under the Plan.
Assist in monitoring investment options by preparing periodic investment
reports that document investment performance, consistency of fund management
and conformance to the guidelines set forth in the IPS and make recommendations
to maintain, remove or replace investment options.
Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding
by the employees.
Meet with Client on a periodic basis to discuss the reports and the investment
recommendations.
Strategic Wealth Group may provide these services or, alternatively, may arrange for the
Plan’s other providers to offer these services, as agreed upon between Strategic Wealth
Group and Client.
3.
Strategic Wealth Group has no responsibility to provide services related to the
following types of assets (“Excluded Assets”):
1.
2.
3.
4.
5.
Employer securities;
Real estate (except for real estate funds or publicly traded REITs);
Stock brokerage accounts or mutual fund windows;
Participant loans;
Non-publicly traded partnership interests;
5
6.
not
7.
Other non-publicly traded securities or property (other than collective trusts and
similar vehicles); or
Other hard-to-value or illiquid securities or property.
be included in calculation of Fees paid to Strategic Wealth Group
Excluded Assets will
under this Agreement.
Specific services will be outlined in detail to each plan in the 408(b)2 disclosure.
SELECTION OF OTHER MONEY MANAGERS
Strategic Wealth Group recommends the services of Third Party Money Managers (“TPM”)
to manage client accounts. In such circumstances, Strategic Wealth Group receives referral
fees from the TPM. This is detailed in Item 10 of this brochure. Prior to referring any clients
to TPMs, Strategic Wealth Group will make sure that they are properly registered or notice
filed. Client Tailored Services and Client Imposed Restrictions
The goals and objectives for each client are documented in our client files. Investment
strategies are created that reflect the stated goals and objectives. Clients may impose
restrictions on investing in certain securities or types of securities. Agreements may not be
Wrap Fee Programs
assigned without written client consent.
Strategic Wealth Group sponsors a wrap fee program. The client pays one fee to Strategic
Wealth Group that includes Strategic Wealth Group’s Management Fee and the transaction
costs associated with the transactions. More information is available in the Form ADV Part
Client Assets Under Management
2, Appendix 1.
Strategic Wealth Group has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts:
$
$0
Date Calculated:
December 31, 2025
1,537,238,398
Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
Annual Fee
ASSET MANAGEMENT
Strategic Wealth Group offers discretionary and non-discretionary asset management
services to advisory clients. The fees for these services will be based on a fee up to 2.0% of
assets under management on an annual basis or the Client can elect to have the fees charged
via a blended fee schedule. Accounts within the same household may be combined for a
reduced fee. Fees are billed quarterly in advance based on the amount of assets managed as
of the last business day of the previous quarter. Initial fees for partial quarters are pro-rated.
Lower fees for comparable services may be available from other sources. The blended fee
Portfolio Value
schedule is as follows:
From $0 to $500,000
From $500,001 to $1,000,000
From $1,000,001 to $2,000,000
From $2,000,001 to $5,000,000
For any amount over $5,000,000
2.0%
1.75%
1.5%
1.25%
1.0%
This is a blended fee schedule, the asset management fee is calculated by applying different
rates to different portions of the portfolio. Strategic Wealth Group may group certain related
6
Client accounts for the purposes of achieving the minimum account size and determining the
annualized fee.
For example, a Client with $3,000,000 under management would pay $46,250 on an annual
basis.
First $500,000 x .02 = $10,000
Next $500,000 x .0.175= $8,750
Next $1,000,000 x .015 = $15,000
Next $1,000,000 x .0125 = $12,500
Strategic Wealth Group may also utilize the services of a Sub-Advisor to manage Clients’
investment portfolios by executing a Sub-Advisor agreement with other registered
investment advisor firms. When using Sub-Advisors, the Client will not pay additional fees.
The Sub-Advisors fees are inclusive of the total fee disclosed by Strategic Wealth Group. Sub-
Advisor directly deducts their portion of the fee separately from Strategic Wealth Group.
In addition, Strategic Wealth Group may utilize a Third Party Asset Manager Program
(TAMP) available through the LPL platform. Additional fees will be incurred if using the
TAMP. LPL fee is an additional annual fee of 0.25% and Parametric charges the following:
Parametric Custom Core
Benchmark
Fee
MSCI World ex USA
MSCI EAFE
MSCI World
Dev World ex-US ADR
Developed Word ADR
Developed World ADR
Quality Domestic
US Broad Cap
US Large Cap
US Large-Mid Cap Growth
Large-Mid Cap Value
US Midcap 400
US Smallcap 600
US SRI Broad Cap
Russell 3000
S&P 500)
Russell 1000 Growth
Russell 1000 Value
S&P 400
S&P 600
MSCI KLD 400 Social
.28%
.28%
.33%
.33%
.28%
.28%
.28%
.28%
.28%
.28%
.33%
Minimum
Account Size
$250,000
$250,000
$500,000
$250,000
$250,000
$500,000
$250,000
$250,000
$250,000
$250,000
$250,000
The annual fee may be negotiable based upon certain criteria (e.g., historical relationship,
type of assets, anticipated future earning capacity, anticipated future additional assets, dollar
amounts of assets to be managed, related accounts, account composition, negotiations with
Clients, etc.).
Clients may terminate their account within five (5) business days of signing the Investment
Advisory Agreement with no obligation. Clients may terminate advisory services with thirty
(30) days written notice. The client will be entitled to a pro rata refund for the days service
was not provided in the final quarter.
Client shall be given thirty (30) days prior written notice of any increase in fees. Both parties
will acknowledge any increase in fees in writing before any increase in said fees occurs.
ASSETS HELD AWAY
7
Strategic Wealth Group offers discretionary direct asset management services to advisory
Clients. Strategic Wealth Group charges an annual investment advisory fee based on the total
assets under management of no more than 1.5% annually.
The annual fee is negotiable. The Advisory Fee for the initial period will be paid on a pro rata
basis based on the number of days in the billing period for which services under this
Agreement were provided, in arrears, based on the billing period ending value of the Client’s
managed assets. For all future periods, the Advisory Fee will be assessed and payable each
billing period, in advance, based on the balance of Client’s managed assets as of the prior
period-end, in accordance with the fee schedule listed in the Agreement. By executing this
Agreement, Client is authorizing Strategic Wealth Group to debit its Advisory Fees directly
from one or more of the Client’s Accounts. The Advisory Fee payable for any Held Away
Account will be deducted directly from another Client Account, and if there are insufficient
funds available in another Client Account or Strategic Wealth Group believes that deducting
the Advisory Fee from another Client Account would be prohibited by applicable law, it will
invoice the Client.
No fee adjustment will be made for Account deposits and withdrawals during a billing
period.
In addition to the fees paid to Strategic Wealth Group, investments used in managing the
Account may subject Client to additional fees. For example, mutual funds, index funds,
exchange traded funds and private funds typically charge ongoing management fees and
have other expenses for the operation of those funds. These fees should not be confused with
“loads” or commissions. Strategic Wealth Group does not receive any additional
compensation, either directly or indirectly, from these investments.
FINANCIAL PLANNING AND CONSULTING FEES
Strategic Wealth Group charges either an hourly fee or fixed fee based on complexity and
unique Client needs for the following financial planning services. Prior to the planning
Full Financial Plan
process the Client will be provided an estimated plan fee.
Hourly Consultation Services
Full Financial Plan services are offered on a fixed fee basis ranging from $2,500 to $25,000.
Hourly Consultation Services are offered based on an hourly fee of $500 per hour.
Services are completed and delivered inside of ninety (90) days contingent upon timely
delivery of all required documentation. Fees for full financial plans and hourly consultations
are billed 50% in advance with the balance due upon delivery.
Client may cancel within five (5) business days of signing Agreement with no obligation and
without penalty. If the Client cancels after five (5) business days, any unearned fees will be
Ongoing Financial Planning
refunded to the Client. This will be calculated based on the percentage of work completed.
Ongoing financial planning services are offered for a flat fee of up to $25,000 per year. Fees
will be charged monthly or quarterly. Initial payment will be due upon signing the
agreement and the monthly/quarterly fee within 10 days of receipt of invoice.
For example, if the ongoing annual financial planning fee is $20,000 and the client chooses
to pay monthly, $1,666,67 will be due initially with $1,666.67 due in subsequent months.
Ongoing financial planning services will continue from year to year unless cancelled by the
Client or Strategic Wealth Group. Client may cancel within five (5) business days of signing
8
Agreement with no obligation and without penalty. If the Client cancels after five (5)
business days, any unearned fees will be refunded to the Client. This will be calculated based
on the percentage of work completed.
ERISA PLAN SERVICES
The annual fees are based on the market value of the Included Assets and will not exceed
1%. Fees are charged quarterly in advance based on the assets as calculated by the custodian
or record keeper of the Included Assets (without adjustments for anticipated withdrawals
by Plan participants or other anticipated or scheduled transfers or distribution of assets) on
the last business day of the previous quarter. If the services to be provided start any time
other than the first day of a quarter, the fee will be prorated based on the number of days
remaining in the quarter. If this Agreement is terminated prior to the end of the fee period,
the client shall be entitled to a prorated refund based on the number of days during the fee
period services were provided.
The compensation of Strategic Wealth Group for the services is described in detail in
Schedule A of the ERISA Plan Agreement. The Plan is obligated to pay the fees, however the
Plan Sponsor may elect to pay the fees. Client may elect to be billed directly or have fees
deducted from Plan Assets. Strategic Wealth Group does not reasonably expect to receive
any additional compensation, directly or indirectly, for its services under this Agreement. If
additional compensation is received, Strategic Wealth Group will disclose this compensation,
the services rendered, and the payer of compensation. Strategic Wealth Group will offset the
compensation against the fees agreed upon under this Agreement.
SELECTION OF OTHER MONEY MANAGERS
Strategic Wealth Group may at times use the services of TPMs and receive a referral fee for
referring clients. Strategic Wealth Group will be paid a portion of the advisory fee paid to the
TPM. Strategic Wealth Group has entered into a Referral Agreement with the following
Brinker Capital Investments, LLC (“Brinker”) CRD #107975
TPMs:
Brinker Fee
Brinker charges each Client an all-inclusive fee that encompasses all Program components
provide by Brinker. The Brinker Fee is accordance with the pricing schedules set forth below
and is billed quarterly in advance. Brinker agrees to collect the Advisor Fee on behalf of
Strategic Wealth Group on a quarterly basis, promptly following Brinker’s receipt of the
Asset Tier
Advisor Fee from Clients.
Up to $100,000
$100,000 to $1 million
Next $1 million
Next $1 million
Next $2 million
Over $5 million
0.64%
0.50%
0.45%
0.40%
0.35%
Negotiable
Because Brinker’s standard fee schedule is “tiered”, the actual Brinker Fee Component will
vary based upon changes in the total value of the client’s account (resulting from
appreciation, depreciation, liquidations or additional contributions).Strategic Wealth Group
fee is equal to a percentage of the net asset value of the client's account, as determined by
Strategic Wealth Group and disclosed to the client. Strategic Wealth Group fee generally
ranges from 0.20% to 1.50% of the account net asset value, but the fee could be more or less.
The client pays a single fee to Brinker and Brinker pays the Strategic Wealth Group’s fee to
Strategic Wealth Group.
9
Client Payment of Fees
Investment management fees are billed quarterly, in advance, meaning that we invoice you
at the beginning of the three-month billing period. Payment in full is expected upon invoice
presentation. Fees are usually deducted from a designated client account to facilitate billing.
The client must consent in advance to direct debiting of their investment account. By
opening an advisory account with Strategic Wealth Group, the client authorizes the
custodian to deduct Strategic Wealth Group’s investment management fee.
•
Fees for Assets Held Away services are paid via:
•
Check – to be remitted by Client to Strategic Wealth Group
Deducted from a non-qualified account managed by Strategic Wealth Group
Fees for ERISA services will either be deducted from Plan assets or paid directly to Strategic
Wealth Group. The Client must consent in advance to direct debiting of their investment
account.
•
Clients can choose to pay for financial planning via the following methods:
•
Check – to be remitted by Client to Strategic Wealth Group
Deducted from a non-qualified account managed by Strategic Wealth Group
Fees for asset management services provided by TPM are deducted from a designated Client
account by TPM to facilitate billing. The Client must consent in advance to direct debiting of
Additional Client Fees Charged
their investment account.
Custodians may charge transaction fees on purchases or sales of certain mutual funds,
equities, and exchange-traded funds. These charges may include Mutual Fund transactions
fees, postage and handling and miscellaneous fees (fee levied to recover costs associated
with fees assessed by self-regulatory organizations). The selection of the security is more
important than the fee that the custodian charges to buy or sell the security. In certain
situations, Strategic Wealth Group may elect to pay for transaction-related fees within a
client’s account. In the event that happens, clients should understand that this presents a
potential conflict of interest because Strategic Wealth Group may have a disincentive to trade
securities in the account to keep the execution costs low, therefore retaining a larger portion
of the management fee.
Clients may also incur certain charges, including those imposed by the custodian. These may
include, but are not limited to, the following: mutual fund or money market 12b-1 fees, sub-
transfer agent fees, certain deferred sales charges on previously purchased mutual funds
transferred into the account, other transaction charges and service fees, IRA and qualified
retirement plan fees, alternative investment administrative fees, administrative servicing
fees for trust accounts, creation and development fees or similar fees imposed by unit
investment trust sponsors, managed futures investor servicing fees, and other charges
required by law. Strategic Wealth Group does not receive any portion of these fees. Further
information regarding charges and fees assessed by a mutual fund or variable annuity are
available in the appropriate prospectus.
Mutual funds may also charge a redemption fee if a redemption is made within a specific
time period following the investment. The terms of any redemption fee are disclosed in the
fund’s prospectus. Transactions in mutual fund shares (e.g., for rebalancing, liquidations,
deposits or tax harvesting) may be subject to a fund’s frequent trading policy.
10
Client should be aware that margin borrowing involves additional risks. Margin borrowing
will result in increased gain if the value of the securities in the account go up, but will result
in increased losses if the account value decreases. The custodian will charge margin interest
on any margin debt within the client’s account if a client elects to utilize margin. Margin rates
change and are based on prevailing interest rates at the time of use.
Strategic Wealth Group, in its sole discretion, may waive its minimum fee and/or charge a
lesser investment advisory fee based upon certain criteria (e.g., historical relationship, type
of assets, anticipated future earning capacity, anticipated future additional assets, dollar
amounts of assets to be managed, related accounts, account composition, negotiations with
clients, etc.).
Prepayment of Client Fees
For more details on the brokerage practices, see Item 12 of this brochure.
Investment management fees are billed quarterly in advance; financial plans are billed 50%
External Compensation for the Sale of Securities to Clients
in advance.
Investment Advisor Representatives of Strategic Wealth Group may receive external
compensation for the sale of securities to clients as registered representatives of LPL
Financial LLC (LPL), a broker-dealer. Approximately 75% of their time is spent in this
practice and less than 15% of their total revenue is generated as registered representatives.
They will offer clients products from this activity.
This represents a conflict of interest because it gives an incentive to recommend products
based on the commission received. As registered representatives, they do not charge
advisory fees for the services offered through LPL. This conflict is mitigated by disclosures,
procedures, and the firm’s fiduciary obligation to place the best interest of the Client first
and Clients are not required to purchase any products or services. Clients have the option to
purchase these products through another registered representative of their choosing.
Item 6: Performance-Based Fees and Side-by-Side Management
Sharing of Capital Gains
Fees are not based on a share of the capital gains or capital appreciation of managed
securities.
Strategic Wealth Group does not use a performance-based fee structure because of the
conflict of interest. Performance-based compensation may create an incentive for the adviser
to recommend an investment that may carry a higher degree of risk to the client.
Item 7: Types of Clients
Description
Strategic Wealth Group generally provides investment advice to individuals, pension and
profit sharing plans, trusts, estates, or charitable organizations, corporations or business
entities.
Account Minimums
Client relationships vary in scope and length of service.
Strategic Wealth Group does not require a minimum to open an account.
11
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Security analysis methods may include fundamental analysis and technical analysis.
Investing in securities involves risk of loss that clients should be prepared to bear. Past
performance is not a guarantee of future returns.
Fundamental analysis involves evaluating a stock using real data such as company revenues,
earnings, return on equity, and profits margins to determine underlying value and potential
growth. Technical analysis involves evaluating securities based on past prices and volume.
When creating a financial plan, Strategic Wealth Group utilizes fundamental analysis to
provide review of insurance policies for economic value and income replacement. Technical
analysis is used to review mutual funds and individual stocks. The main sources of
information include Morningstar, client documents such as tax returns and insurance
policies.
The main sources of information include financial newspapers and magazines, research
material prepared by others, corporate rating services, annual reports, prospectuses, filings
Investment Strategy
with the Securities and Exchange Commission and company press releases.
The investment strategy for a specific client is based upon the objectives stated by the client
during consultations. The client may change these objectives at any time. Each client
executes an Investment Policy Statement or Risk Tolerance that documents their objectives
and their desired investment strategy.
Security Specific Material Risks
Other strategies may include margin trading.
All investment programs have certain risks that are borne by the investor. Fundamental
analysis may involve interest rate risk, market risk, business risk, and financial risk. Risks
involved in technical analysis are inflation risk, reinvestment risk, and market risk.
Interest-rate Risk
•
Our investment approach constantly keeps the risk of loss in mind. Investors face the
following investment risks and should discuss these risks with Strategic Wealth Group:
• Market Risk
: Fluctuations in interest rates may cause investment prices to
fluctuate. For example, when interest rates rise, yields on existing bonds become less
attractive, causing their market values to decline.
•
: The price of a security, bond, or mutual fund may drop in reaction to
tangible and intangible events and conditions. This type of risk is caused by external
factors independent of a security’s particular underlying circumstances. For example,
Inflation Risk
political, economic and social conditions may trigger market events.
: When any type of inflation is present, a dollar today will buy more than
• Reinvestment Risk
a dollar next year, because purchasing power is eroding at the rate of inflation.
• Business Risk
: This is the risk that future proceeds from investments may have
to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily
relates to fixed income securities.
: These risks are associated with a particular industry or a particular
company within an industry. For example, oil-drilling companies depend on finding
oil and then refining it, a lengthy process, before they can generate a profit. They carry
a higher risk of profitability than an electric company which generates its income
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• Financial Risk
from a steady stream of customers who buy electricity no matter what the economic
environment is like.
• Trading on Margin:
: Excessive borrowing to finance a business’ operations increases the
risk of profitability, because the company must meet the terms of its obligations in
good times and bad. During periods of financial stress, the inability to meet loan
obligations may result in bankruptcy and/or a declining market value.
In a cash account, the risk is limited to the amount of money that
has been invested. In a margin account, risk includes the amount of money invested
plus the amount that has been loaned. As market conditions fluctuate, the value of
marginable securities will also fluctuate, causing a change in the overall account
balance and debt ratio. As a result, if the value of the securities held in a margin
account depreciates, the client will be required to deposit additional cash or make full
payment of the margin loan to bring account back up to maintenance levels. Clients
who cannot comply with such a margin call may be sold out or bought in by the
brokerage firm.
•
The risks associated with utilizing Sub-Advisors include:
o
Manager Risk
•
Sub-Advisor fails to execute the stated investment strategy.
o
Business Risk
•
Sub-Advisor has financial or regulatory problems.
The specific risks associated with the portfolios of the Sub-Advisor’s which is
disclosed in the Sub-Advisor’s Form ADV Part 2.
Item 9: Disciplinary Information
Criminal or Civil Actions
Administrative Enforcement Proceedings
The firm and its management have not been involved in any criminal or civil action.
The firm and its management have not been involved in administrative enforcement
Self-Regulatory Organization Enforcement Proceedings
proceedings.
The firm and its management have not been involved in legal or disciplinary events related
to past or present investment clients.
Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer or Representative Registration
Futures or Commodity Registration
Representatives of Strategic Wealth Group are currently registered representatives of LPL.
Neither Strategic Wealth Group nor its employees are registered or has an application
pending to register as a futures commission merchant, commodity pool operator, or a
Material Relationships Maintained by this Advisory Business and Conflicts of Interest
commodity trading advisor.
Certain associated persons of Strategic Wealth Group are licensed as insurance agents for
various insurance companies, registered representatives of LPL and/or investment advisor
representatives of non-affiliated Registered Investment Advisory firms. Approximately 5%
13
of their time is spent in their insurance practices and greater than 50% in their capacities
with LPL. As a result of this relationship, LPL may have access to certain confidential
information (e.g., financial information, investment objectives, transactions and holdings)
about Strategic Wealth Group’s clients, even if client does not establish any account through
LPL. If you would like a copy of the LPL privacy policy, please contact your financial advisor.
From time to time, associated persons will offer clients services from those activities.
This represents a conflict of interest because it gives an incentive to recommend products
and services based on the commission amount received. This conflict is mitigated by
disclosures, procedures, and the firm’s Fiduciary obligation to place the best interest of the
client first and the clients are not required to purchase any products or services. Clients have
the option to purchase these products or services through another insurance agent,
Business Entities of Investment Advisor Representatives
registered representative or investment advisor representative of their choosing.
Investment Advisor Representatives may have their own legal business entities whose
business names and logos may appear on marketing materials as approved by Strategic
Wealth Group or client statements as approved by the Custodian. The Client should
understand that the businesses are legal entities of the Investment Advisor Representative
and not of Strategic Wealth Group, nor the Custodian. Additionally, the business entity may
provide services other than as an Investment Advisor Representative as disclosed herein;
However, Investment Advisory Services of the Investment Advisor Representatives are
Recommendations or Selections of Other Investment Advisors and Conflicts of
provided through Strategic Wealth Group.
Interest
Strategic Wealth Group may also utilize the services of a Sub-Advisor to manage Clients’
investment portfolios. Sub-Advisors will maintain the models or investment strategies
agreed upon between Sub-Advisor and Strategic Wealth Group. Sub-Advisors execute all
trades on behalf of Strategic Wealth Group in Client accounts. Strategic Wealth Group will be
responsible for the overall direct relationship with the Client. Strategic Wealth Group retains
the authority to terminate the Sub-Advisor relationship at Strategic Wealth Group’s
discretion.
In addition to the authority granted to Strategic Wealth Group, Clients will grant Strategic
Wealth Group full discretionary authority and authorizes Strategic Wealth Group to select
and appoint one or more independent investment advisors (“Advisors”) to provide
investment advisory services to Client without prior consultation with or the prior consent
of Client. Such Advisors shall have all of the same authority relating to the management of
Client’s investment accounts as is granted to Strategic Wealth Group in the Agreement. In
addition, at Strategic Wealth Group’s discretion, Strategic Wealth Group may grant such
Advisors full authority to further delegate such discretionary investment authority to
additional Advisors. Strategic Wealth Group ensures that before selecting other advisors for
Client that the other advisors are properly licensed or registered as an investment advisor.
This practice represents a conflict of interest as Strategic Wealth Group may select Sub-
Advisors who charge a lower fee for their services than other Sub-Advisors. This conflict is
mitigated by disclosures, procedures, and by the fact that Strategic Wealth Group has a
fiduciary duty to place the best interest of the Client first and will adhere to their code of
ethics.
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Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
Code of Ethics Description
The employees of Strategic Wealth Group have committed to a Code of Ethics (“Code”). The
purpose of our Code is to set forth standards of conduct expected of Strategic Wealth Group
employees and addresses conflicts that may arise. The Code defines acceptable behavior for
employees of Strategic Wealth Group. The Code reflects Strategic Wealth Group and its
supervised persons’ responsibility to act in the best interest of their client.
One area the Code addresses is when employees buy or sell securities for their personal
accounts and how to mitigate any conflict of interest with our clients. We do not allow any
employees to use non-public material information for their personal profit or to use internal
research for their personal benefit in conflict with the benefit to our clients.
Strategic Wealth Group policy prohibits any person from acting upon or otherwise misusing
non-public or inside information. No advisory representative or other employee, officer or
director of Strategic Wealth Group may recommend any transaction in a security or its
derivative to advisory clients or engage in personal securities transactions for a security or
its derivatives if the advisory representative possesses material, non-public information
regarding the security.
Strategic Wealth Group’s Code is based on the guiding principle that the interests of the client
are our top priority. Strategic Wealth Group’s officers, directors, advisors, and other
employees have a fiduciary duty to our clients and must diligently perform that duty to
maintain the complete trust and confidence of our clients. When a conflict arises, it is our
obligation to put the client’s interests over the interests of either employees or the company.
The Code applies to “access” persons. “Access” persons are employees who have access to
non-public information regarding any clients' purchase or sale of securities, or non-public
information regarding the portfolio holdings of any reportable fund, who are involved in
making securities recommendations to clients, or who have access to such recommendations
that are non-public.
The firm will provide a copy of the Code of Ethics to any client or prospective client upon
Investment Recommendations Involving a Material Financial Interest and Conflict of
request.
Interest
Strategic Wealth Group and its employees do not recommend to clients securities in which
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
we have a material financial interest.
Interest
Strategic Wealth Group and its employees may buy or sell securities that are also held by
clients. In order to mitigate conflicts of interest such as front running, employees are
required to disclose all reportable securities transactions as well as provide Strategic Wealth
Group with copies of their brokerage statements.
The Chief Compliance Officer of Strategic Wealth Group is George W. Mulwee. He reviews all
employee trades each quarter. The personal trading reviews ensure that the personal
trading of employees does not affect the markets and that clients of the firm receive
preferential treatment over employee transactions.
15
Client Securities Recommendations or Trades and Concurrent Advisory Firm
Securities Transactions and Conflicts of Interest
Strategic Wealth Group does not maintain a firm proprietary trading account and does not
have a material financial interest in any securities being recommended and therefore no
conflicts of interest exist. However, employees may buy or sell securities at the same time
they buy or sell securities for clients. In order to mitigate conflicts of interest such as front
running, employees are required to disclose all reportable securities transactions as well as
provide Strategic Wealth Group with copies of their brokerage statements.
The Chief Compliance Officer of Strategic Wealth Group is George W. Mulwee. He reviews all
employee trades each quarter. The personal trading reviews ensure that the personal
trading of employees does not affect the markets and that clients of the firm receive
preferential treatment over employee transactions.
Item 12: Brokerage Practices
Factors Used to Select Broker-Dealers for Client Transactions
• Directed Brokerage
Strategic Wealth Group does not have discretionary authority to determine the
broker/dealer to be used or set commission rates for transactions. Strategic Wealth Group
may recommend the use of a particular broker-dealer or may utilize a broker-dealer of the
client's choosing. Strategic Wealth Group will select appropriate brokers based on a number
of factors including but not limited to their relatively low transaction fees and reporting
ability. Strategic Wealth Group relies on its broker to provide its execution services at the
best prices available. Lower fees for comparable services may be available from other
sources. Clients pay for any and all custodial fees in addition to the advisory fee charged by
Strategic Wealth Group.
In circumstances where a client directs Strategic Wealth Group to use a certain
broker-dealer, Strategic Wealth Group still has a fiduciary duty to its clients. The
following may apply with Directed Brokerage: Strategic Wealth Group's inability to
negotiate commissions, to obtain volume discounts, there may be a disparity in
commission charges among clients and conflicts of interest arising from brokerage
• Best Execution
firm referrals.
• Soft Dollar Arrangements
Investment advisors who manage or supervise client portfolios have a fiduciary
obligation of best execution. The determination of what may constitute best
execution and price in the execution of a securities transaction by a broker involves a
number of considerations and is subjective. Factors affecting brokerage selection
include the overall direct net economic result to the portfolios, the efficiency with
which the transaction is effected, the ability to effect the transaction where a large
block is involved, the operational facilities of the broker-dealer, the value of an
ongoing relationship with such broker and the financial strength and stability of the
broker. Strategic Wealth Group does not receive any portion of the trading fees.
Strategic Wealth Group receives support services and/or products from LPL, many of
which assist the Strategic Wealth Group to better monitor and service program
accounts maintained at LPL; however, some of the services and products benefit
Strategic Wealth Group and not client accounts. These support services and/or
16
products may be received without cost, at a discount, and/or at a negotiated rate, and
o
may include the following:
o
o
o
o
o
o
o
o
investment-related research
pricing information and market data
software and other technology that provide access to client account data
compliance and/or practice management-related publications
consulting services
attendance at conferences, meetings, and other educational and/or social events
marketing support
computer hardware and/or software
other products and services used by Strategic Wealth Group in furtherance of its
investment advisory business operations
LPL may provide these services and products directly, or may arrange for third party
vendors to provide the services or products to Advisor. In the case of third party vendors,
LPL may pay for some or all of the third party’s fees.
These support services are provided to Strategic Wealth Group based on the overall
relationship between Strategic Wealth Group and LPL. It is not the result of soft dollar
arrangements or any other express arrangements with LPL that involves the execution of
client transactions as a condition to the receipt of services. Strategic Wealth Group will
continue to receive the services regardless of the volume of client transactions executed with
LPL. Clients do not pay more for services as a result of this arrangement. There is no
corresponding commitment made by the Strategic Wealth Group to LPL or any other entity
to invest any specific amount or percentage of client assets in any specific securities as a
result of the arrangement. However, because Advisor receives these benefits from LPL, there
is a potential conflict of interest. The receipt of these products and services presents a
financial incentive for Advisor to recommend that its clients use LPL’s custodial platform
Aggregating Securities Transactions for Client Accounts
rather than another custodian’s platform.
Strategic Wealth Group may aggregate orders in a block trade or trades when securities are
purchased or sold through the same broker-dealer for multiple (discretionary) accounts. If
block trades cannot be executed in full at the same price or time, the securities actually
purchased or sold by the close of each business day must be allocated in a manner that is
consistent with the initial pre-allocation or other written statement. This must be done in a
way that does not consistently advantage or disadvantage particular client accounts. For
example, a partial fill will generally be filled pro-rata among participating accounts. Prior to
entry of a block trade, a written pre-allocation will be generated which identifies the group
of client accounts participating in the order.
Strategic Wealth Group utilizes block trading with their models in the wrap program by
rebalancing models and replacing single security positions with another. The trading in the
non-wrap program accounts are generally managed individually which may result in a
timing of any orders being different. In turn, this could likely result in different execution
prices on the same day because the portfolios are designed based on the Client’s goals and
objectives. Additionally, Clients could receive different execution prices when multiple
accounts and/or strategies trade the same security on the same day.
Changes in allocation prior to final allocation may be made for good cause provided that all
client accounts receive fair and equitable treatment. A written explanation of the reason for
any material change in the allocation must be provided to and approved by the Compliance
17
Officer no later than the morning following the execution of the trade. If the change in the
allocation is the result of a condition that exists or a change in the client’s account outside of
the portfolio manager’s control, then approval by the Compliance Officer is not required.
Item 13: Review of Accounts
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved
Account reviews are performed quarterly by Investment Advisor Representatives of
Strategic Wealth Group. Account reviews are performed more frequently when market
conditions dictate. Financial planning relationships with clients are monitored on an ongoing
basis to ensure the recommendations made are within the scope of the plan remain suitable.
The advisor will meet with the clients on at least an annual basis to secure updated
Review of Client Accounts on Non-Periodic Basis
information relating to all planning clients.
Other conditions that may trigger a review of clients’ accounts are changes in the tax laws,
Content of Client Provided Reports and Frequency
new investment information, and changes in a client's own situation.
Clients receive written account statements no less than quarterly for managed accounts.
Account statements are issued by Strategic Wealth Group’s custodian. Client receives
confirmations of each transaction in account from Custodian and an additional statement
during any month in which a transaction occurs.
Item 14: Client Referrals and Other Compensation
Economic Benefits Provided to Advisory Firm from External Sources and Conflicts of
Interest
IARs associated with Strategic Wealth Group may have received payments from LPL in
connection with the transition from another broker dealer or investment adviser
firm. These payments, which may be significant, are intended to assist the IARs with the cost
associated with the transition mentioned above. These payments may be in the form of loans
to the IARs, which are repayable to LPL or are forgiven by LPL based on years of service with
LPL or the extent of their production with LPL.
Any additional payments to new or existing IARs may present a conflict of interest in that an
IAR may have a financial incentive to maintain a relationship with LPL which may include
directing clients to LPL for execution of trades. However, to the extent an IAR directs clients
to LPL for services, it is because the IAR believes that it is in that client’s best interest to do
so. Strategic Wealth Group has systems in place to review IAR managed accounts for
suitability and best execution practices over the course of the advisory relationship.
Strategic Wealth Group receives a portion of the annual management fees collected by the
Third Party Money Managers to whom Strategic Wealth Group refers clients.
This situation creates a conflict of interest because Strategic Wealth Group and/or its
Investment Advisor Representatives have an incentive to decide what Third Party Money
Managers to use because of the higher referral fees to be received by Strategic Wealth Group.
However, when referring clients to a third party money manager, the client’s best interest
will be the main determining factor of Advisor.
18
Strategic Wealth Group will, from time to time, enter into agreements with individuals and
organizations (“referring party”) that refer Clients to Strategic Wealth Group in exchange for
compensation. This activity will either be considered an endorsement or testimonial,
depending on if the referring party is a Client of Strategic Wealth Group. For all Clients
introduced by a referring party, Strategic Wealth Group may pay that referring party a fee
pursuant to a previously executed agreement. While the specific terms of each agreement
may differ, the compensation will be based upon Strategic Wealth Group’s engagement of
new Clients and is calculated using a fixed fee, or a varying percentage of the fees paid to
Strategic Wealth Group by such Clients. Any such fee shall be paid solely from Strategic
Wealth Group’s investment management fee and shall not result in any additional charge to
the Client. Strategic Wealth Group ensures that referring parties are registered with all
appropriate jurisdictions or exempt from registration as investment advisors or investment
advisor representatives.
Each referred Client to Strategic Wealth Group under such an arrangement will receive a
copy of this brochure and a written disclosure clearly and prominently disclosing if the
referring party is a current Client or investor, the compensation that will be paid by Strategic
Wealth Group to the referring party and any material conflicts of interest. The referring party
is required provide this disclosure at the time the endorsement or testimonial is
disseminated and will obtain the Client’s signature acknowledging receipt of Strategic
Advisory Firm Payments for Client Referrals
Wealth Group’s disclosure brochure and the written disclosure.
Strategic Wealth Group may, from time to time, enter into agreements with individuals and
organizations (“referring party”) that refer Clients to Strategic Wealth Group in exchange for
compensation. This activity will either be considered an endorsement or testimonial,
depending on if the referring party is a Client of Strategic Wealth Group. For all Clients
introduced by a referring party, Strategic Wealth Group may pay that referring party a fee
pursuant to a previously executed agreement. While the specific terms of each agreement
may differ, the compensation will be based upon Strategic Wealth Group’s engagement of
new Clients and is calculated using a fixed fee, or a varying percentage of the fees paid to
Strategic Wealth Group by such Clients. Any such fee shall be paid solely from Strategic
Wealth Group’s investment management fee and shall not result in any additional charge to
the Client. Strategic Wealth Group ensures that referring parties are registered with all
appropriate jurisdictions or exempt from registration as investment advisers or investment
adviser representatives.
Each referred Client to Strategic Wealth Group under such an arrangement will receive a
copy of this brochure and a written disclosure clearly and prominently disclosing if the
referring party is a current Client or investor, the compensation that will be paid by Strategic
Wealth Group to the referring party and any material conflicts of interest. The referring party
is required provide this disclosure at the time the endorsement or testimonial is
disseminated and will obtain the Client’s signature acknowledging receipt of Strategic
Wealth Group’s disclosure brochure and the written disclosure.
Item 15: Custody
Account Statements
All assets are held at qualified custodians, which means the custodians provide written
account statements directly to clients at their address of record at least quarterly. Clients
19
are urged to compare the account statements received directly from their custodians to the
performance report statements prepared by Strategic Wealth Group.
Strategic Wealth Group is deemed to have constructive custody solely because advisory fees
are directly deducted from client’s account by the custodian on behalf of Strategic Wealth
Group.
Item 16: Investment Discretion
Discretionary Authority for Trading
Generally, Clients grant Strategic Wealth Group complete discretion over the selection and
amount of securities to be bought or sold for their account (within the parameters
established by their Advisory Agreement) without obtaining their consent or approval.
However, these purchases may be subject to specified investment objectives and guidelines.
For example, a Client may specify that the investment in any particular stock or industry
should not exceed specified percentages of the value of the portfolio.
Discretionary authority will only be authorized upon full disclosure to the client and by that
client specifically authorizing said authority through the execution of an Investment
Advisory Agreement. All discretionary trades made by Strategic Wealth Group on behalf of
their discretionary accounts (clients) will be in accordance with that client’s investment
objectives and goals.
Our primary objective in placing orders for the purchase and sale of securities for client
accounts is to obtain the most favorable net results taking into account such factors as 1)
price, 2) size of order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the
broker. Strategic Wealth Group will execute its transactions through an unaffiliated broker-
dealer. The broker-dealer will be chosen based on the following: 1) the broker’s capital
depth, 2) the broker’s market access, 3) the broker’s transaction confirmation and account
statement practices, 4) our knowledge of negotiated commission rates and spreads currently
made available, 5) the nature and character of the markets for the security to be purchased
or sold, 6) the desired timing of the transaction, 7) the execution, 8) clearance and settlement
capabilities of the broker selected and others considered, 9) our knowledge of any actual or
apparent operational problems of a broker and 10) the reasonableness of the commission or
its equivalent for the specific transaction. We will not necessarily pay the lowest commission
or commission equivalent. Transactions may involve specialized services on the part of the
broker.
This would justify higher commissions (or their equivalent) than other transactions
requiring routine services.
Item 17: Potential Conflicts of Interest in Trading
Trading Fees
Ticket charges range from $4.95 to $26.50 depending on the custodian and type of security
being traded. Strategic Wealth Group may elect to pay for these charges within a Client’s
account in certain circumstances. In the event this happens the Client should understand that
this presents a potential conflict of interest because it could provide the Investment Advisor
Representative managing the account a disincentive to invest advisory assets in certain types
of securities due to these trading costs.
In certain situations, Strategic Wealth Group may elect to pay for transaction-related fees
within a client’s account. In the event that happens, clients should understand that this
20
presents a potential conflict of interest because Strategic Wealth Group may have a
Mutual Funds Share Class Selection
disincentive to trade the Client’s account in order to keep costs to the Advisor down.
For accounts held at LPL, there is a potential conflict of interest in the ticket charges paid on
different funds. LPL has “participating funds” which is not charged a ticket charge, but the
funds are likely not the lowest-cost share class. LPL’s “non-participating funds” do have a
ticket charge, but the client could potentially benefit from the cheaper share class.
Custodians may charge transaction fees on purchases or sales of certain mutual funds,
equities, and exchange-traded funds.
Strategic Wealth Group, in its sole discretion, may waive its minimum fee and/or charge a
lesser investment advisory fee based upon certain criteria (e.g., historical relationship, type
of assets, anticipated future earning capacity, anticipated future additional assets, dollar
amounts of assets to be managed, related accounts, account composition, negotiations with
clients, etc.).
Item 18: Voting Client Securities
Proxy Votes
Strategic Wealth Group does not vote proxies on securities. Clients are expected to vote their
own proxies. The client will receive their proxies directly from the custodian of their account
or from a transfer agent.
When assistance on voting proxies is requested, Strategic Wealth Group will provide
recommendations to the client. If a conflict of interest exists, it will be disclosed to the client.
Item 19: Financial Information
Balance Sheet
A balance sheet is not required to be provided because Strategic Wealth Group does not
serve as a custodian for client funds or securities and Strategic Wealth Group does not
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
require prepayment of fees of more than $1200 per client and six months or more in advance.
Commitments to Clients
Strategic Wealth Group has no condition that is reasonably likely to impair our ability to
Bankruptcy Petitions during the Past Ten Years
meet contractual commitments to our Clients.
Neither Strategic Wealth Group nor its management has had any bankruptcy petitions in the
last ten years.
21
S U P E R V I S E D P E R S O N B R O C H U R E
F O R M A D V P A R T 2 B
®
Tyler D. Hirth, CFP
Strategic Wealth Group
Registered Investment Advisors, LLC
Office Address:
7820 Terrey Pine Ct, #200
Eden Prairie, MN 55347
Tel: 952-843-4944
Fax: 952-666-5117
Tyler.h@strategicwg.net
F E B R U A R Y 1 4 , 2 0 2 6
This brochure supplement provides information about Tyler D. Hirth and supplements the
Strategic Wealth Group Registered Investment Advisors, LLC brochure. You should have received
a copy of that brochure. Please contact Tyler D. Hirth if you did not receive the brochure or if you
have any questions about the contents of this supplement.
Additional information about Tyler D. Hirth (CRD #5392371) is available on the SEC’s website at
www.adviserinfo.sec.gov.
22
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Tyler D. Hirth, CFP®
•
Item 2 Educational Background and Business Experience
Year of birth: 1983
•
Educational Background:
Bemidji State University; Bachelor of Science in Business Administration,
Entrepreneurship/Small Business Management, emphasis; 2006
•
Business Experience:
•
Strategic Wealth Group Registered Investment Advisors, LLC; Owner; 07/2024 –
Present
o
Running Wealth Management Group MN, Inc.
o
CEO; 07/2024 – Present
•
Minority Owner; 08/2016 – 07/2024
•
Running Tax Services, LLC; Owner; 01/2021 - Present
•
•
•
•
•
•
•
Professional Designations:
Strategic Wealth Group Registered Investment Advisors, LLC; Investment Advisor
Representative; 07/2016 - Present
LPL Financial LLC; Registered Representative; 08/2016 – Present
Tyler Hirth, Sole Proprietor; Insurance Agent; 04/2015 – Present
Tyler Hirth and Morgan Hirth Partnership; Owner; 02/2007 - Present
Cetera Advisors LLC; Registered Representative/Investment Advisor
Representative; 05/2015 - 07/2016
Metlife Securities Inc.; Investment Advisor Representative; 02/2014 – 05/2015
Metlife Securities Inc.; Registered Representative; 08/2007 – 05/2015
Auto Owners; Owner; 06/2006 – 07/2007
Tyler D. Hirth has earned certifications and credentials that are required to be explained in
further detail.
®
, CFP
®
and federally registered CFP (with flame design)
marks”) are professional certification marks granted in the
®
®
®
marks, an individual must satisfactorily fulfill the
•
™
The Certified Financial Planner
marks (collectively, the “CFP
United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”).
The CFP
certification is a voluntary certification; no federal or state law or regulation
certification. It is recognized in the United States
requires financial planners to hold CFP
and a number of other countries for its (1) high standard of professional education; (2)
stringent code of conduct and standards of practice; and (3) ethical requirements that
govern professional engagements with Clients.
To attain the right to use the CFP
following requirements:
Education – Complete an advanced college-level course of study addressing the
financial planning subject areas that CFP Board’s studies have determined as
necessary for the competent and professional delivery of financial planning services,
and attain a Bachelor’s Degree from a regionally accredited United States college or
23
•
university (or its equivalent from a foreign university). CFP Board’s financial
planning subject areas include insurance planning and risk management, employee
benefits planning, investment planning, income tax planning, retirement planning,
and estate planning;
®
•
Examination – Pass the comprehensive CFP
Certification Examination. The
examination includes case studies and Client scenarios designed to test one’s ability
to correctly diagnose financial planning issues and apply one’s knowledge of financial
planning to real world circumstances;
Standards of Professional Conduct
•
Experience – Complete at least three years of full-time financial planning-related
experience (or the equivalent, measured as 2,000 hours per year); and
, a set of
®
Ethics – Agree to be bound by CFP Board’s
documents outlining the ethical and practice standards for CFP
professionals.
®
•
Individuals who become certified must complete the following ongoing education and ethics
requirements in order to maintain the right to continue to use the CFP
marks:
Standards of
Code of Ethics
Continuing Education – Complete 30 hours of continuing education hours every two
Professional Conduct
years, including two hours on the
and other parts of the
, to maintain competence and keep up with developments in the
Standards of Professional Conduct.
•
financial planning field; and
Standards
®
professionals provide financial
professionals must
Ethics – Renew an agreement to be bound by the
®
The
prominently require that CFP
planning services at a fiduciary standard of care. This means CFP
provide financial planning services in the best interests of their Clients.
®
®
certification.
None to report in the past 20 years.
professionals who fail to comply with the above standards and requirements may be
CFP
subject to CFP Board’s enforcement process, which could result in suspension or permanent
Item 3 Disciplinary Information
revocation of their CFP
Criminal or Civil Action:
Administrative Proceeding:
Self-Regulatory Proceeding:
Item 4 Other Business Activities
None to report in the past 20 years.
None to report in the past 20 years.
Tyler Hirth has a financial industry affiliated business as an insurance agent, owns an
accounting and tax firm and is also a registered representative with LPL Financial; a broker-
dealer. A majority of his time is spent on these practices. From time to time, he will offer
clients services from those activities. He may receive separate yet typical compensation in
the form of commissions for the sale of insurance products, tax services or securities.
This represents a conflict of interest because it gives an incentive to recommend products
and services based on the commission amount received. This conflict is by disclosures,
procedures, and the firm’s Fiduciary obligation to place the best interest of the client first
and the clients are not required to purchase any products or services. Clients have the option
to purchase these products or services through another insurance agent, tax provider or
registered representative of their choosing.
Additionally, Tyler Hirth owns farmland near Morris, MN that generates rental income and
is the sole owner and CEO of Running Wealth Management Group MN, Inc. a corporation
24
established for tax purposes. There is no conflict of interest because no products or services
Item 5 Additional Compensation
are provided and clients are not solicited services from this activity.
Tyler D. Hirth receives additional compensation in his capacity as an insurance agent, tax
Item 6 Supervision
provider and registered representative, but he does not receive any performance based fees.
Mr. Hirth is the Managing Member of Strategic Wealth Group therefore he is responsible for
supervision and formulation and monitoring of investment advice offered to clients. He will
adhere to the policies and procedures as described in the firm’s Compliance Manual.
25
S U P E R V I S E D P E R S O N B R O C H U R E
F O R M A D V P A R T 2 B
George W. Mulwee
Strategic Wealth Group
Registered Investment Advisor, LLC
Office Address:
7820 Terrey Pine Ct, #200
Eden Prairie, MN 55347
Tel: 952-843-4944
Fax: 952-843-4943
george.m@strategicwg.net
F E B R U A R Y 1 4 , 2 0 2 6
This brochure supplement provides information about George W. Mulwee and supplements the
Strategic Wealth Group Registered Investment Advisors, LLC brochure. You should have received
a copy of that brochure. Please contact George W. Mulwee if you did not receive the brochure or if
you have any questions about the contents of this supplement.
Additional information about George W. Mulwee (CRD #4144139) is available on the SEC’s website
at www.adviserinfo.sec.gov.
26
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
George W. Mulwee
•
Item 2 Educational Background and Business Experience
Year of birth: 1978
•
Educational Background:
No post-secondary education
•
Business Experience:
•
Strategic Wealth Group Registered Investment Advisor, LLC; Chief Compliance
Officer/Investment Advisor Representative; 07/2017 - Present
•
LPL Financial, LLC; Registered Representative; 07/2017 – Present
•
Cetera Advisors LLC; Director Supervision; 05/2014 - 07/2017
•
Cetera Financial Specialists LLC; Director Supervision; 01/2015 - 02/2015
•
Summit Brokerage Services, Inc.; Director Supervision; 01/2015 - 02/2015
•
Legend Equities Corporation; Director Supervision; 01/2015 - 02/2015
•
J.P. Turner & Company, L.L.C.; Director Supervision; 01/2015 - 02/2015
•
Investors Capital Corp; Director Supervision; 01/2015 - 02/2015
•
Cetera Advisor Networks LLC; Director Supervision; 01/2015 - 02/2015
•
Cetera Investment Services LLC; Director Supervision; 01/2015 - 02/2015
•
First Allied Securities, Inc.; Registered Representative; 01/2015 - 02/2015
•
First Allied Securities, Inc.; Director Supervision; 01/2015 - 02/2015
•
Woodbury Financial Services, Inc.; Registered Representative; 07/2011 - 05/2014
•
Ameriprise Financial Services, Inc.; Investigator; 09/2010 – 07/2011
Woodbury Financial Services, Inc.; Brokerage Operations; 06/2002 – 09/2010
None to report in the past 20 years.
Item 3 Disciplinary Information
Criminal or Civil Action:
Administrative Proceeding:
Self-Regulatory Proceeding:
Item 4 Other Business Activities
None to report in the past 20 years.
None to report in the past 20 years.
George W. Mulwee has a financial industry affiliated business as a registered representative
with LPL, a broker-dealer. A majority of his time is spent on this practice. From time to time,
he will offer clients services from this activity. He may receive separate yet typical
compensation in the form of commissions for the sale of securities.
This represents a conflict of interest because it gives an incentive to recommend products
and services based on the commission amount received. This conflict is mitigated by
disclosures, procedures, and the firm’s Fiduciary obligation to place the best interest of the
client first and the clients are not required to purchase any products or services. Clients have
the option to purchase these products or services through another registered representative
of their choosing.
27
Item 5 Additional Compensation
George W. Mulwee receives additional compensation in his capacity as a registered
Item 6 Supervision
representative, but he does not receive any performance-based fees.
George W. Mulwee is the Chief Compliance Officer of Strategic Wealth Group and therefore
he is solely responsible for all supervision and formulation and monitoring of investment
advice offered to clients. He will adhere to the policies and procedures as described in
Strategic Wealth Group compliance manual.
28
Additional Brochure: WRAP BROCHURE SUPPLEMENT (2026-02-14)
View Document Text
W R A P F E E P R O G R A M B R O C H U R E
( P A R T 2 A A P P E N D I X O F F O R M A D V )
Strategic Wealth Group Registered
Investment Advisor, LLC
Office Address:
7820 Terrey Pine Ct, #200
Eden Prairie, MN 55347
Tel: 952-843-4944
Fax: 952-666-5117
Tyler.h@strategicwg.net
F E B R U A R Y 1 4 , 2 0 2 6
This wrap fee program brochure provides information about the qualifications and business
practices of Strategic Wealth Group Registered Investment Advisor, LLC Being registered as a
registered investment adviser does not imply a certain level of skill or training. If you have any
questions about the contents of this brochure, please contact us at 952-955-7865. 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 Strategic Wealth Group Registered Investment Advisor, LLC
(IARD#284430) is available on the SEC’s website at www.adviserinfo.sec.gov
i
Strategic Wealth Group Registered Investment Advisor, LLC
Item 2: Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material
Material Changes since the Last Update
changes occur since the previous release of the Firm Brochure.
Since the last update on February 4, 2025, there have been no material changes.
ii
Strategic Wealth Group Registered Investment Advisor, LLC
Item 3: Table of Contents
Form ADV – Part 2A Appendix 1 – Firm Brochure
Item 1: Cover Page
Item 2: Material Changes ...................................................................................................................... ii
Annual Update ................................................................................................................................................ ii
Item 3: Table of Contents ..................................................................................................................... 1
Material Changes since the Last Update ............................................................................................... ii
Item 4: Services, Fees and Compensation ...................................................................................... 3
Firm Description ............................................................................................................................................ 3
Program Services ........................................................................................................................................... 3
Item 5: Account Requirements and Types of Clients.................................................................. 5
Program Fees .................................................................................................................................................. 4
Account Minimum ......................................................................................................................................... 5
Item 6: Portfolio Manager Selection and Evaluation .................................................................. 5
Types of Clients .............................................................................................................................................. 5
Portfolio Manager .......................................................................................................................................... 5
Conflicts of Interest ....................................................................................................................................... 5
Advisory Business ......................................................................................................................................... 6
Sharing of Capital Gains .............................................................................................................................. 7
Methods of Analysis ...................................................................................................................................... 8
General Investment Strategy ..................................................................................................................... 8
Security Specific Material Risks ............................................................................................................... 8
Item 7: Client Information Provided to Portfolio Managers.................................................... 9
Proxy Voting .................................................................................................................................................... 9
Item 8: Client Contact with Portfolio Managers ........................................................................... 9
Description ....................................................................................................................................................... 9
Item 9: Additional Information ........................................................................................................ 10
Restrictions ...................................................................................................................................................... 9
Disciplinary Information .......................................................................................................................... 10
Criminal or Civil Actions ........................................................................................................................... 10
Administrative Enforcement Proceedings ......................................................................................... 10
Self-Regulatory Organization Enforcement Proceedings ............................................................ 10
Other Financial Industry Activities and Affiliations ....................................................................... 10
Broker-Dealer or Representative Registration ................................................................................ 10
- 1 -
Strategic Wealth Group Registered Investment Advisor, LLC
Futures or Commodity Registration .................................................................................................... 10
Material Relationships Maintained by this Advisory Business and Conflicts of Interest 10
Code of Ethics Description ....................................................................................................................... 10
Investment Recommendations Involving a Material Financial Interest and Conflict of
Interest ............................................................................................................................................................ 11
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest ............................................................................................................................................................ 11
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Transactions and Conflicts of Interest ................................................................................................. 11
Review of Accounts ..................................................................................................................................... 12
Schedule for Periodic Review of Client Accounts and Advisory Persons Involved ........... 12
Review of Client Accounts on Non-Periodic Basis .......................................................................... 12
Content of Client Provided Reports and Frequency ....................................................................... 12
Client Referrals and Other Compensation ......................................................................................... 12
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of
Interest ............................................................................................................................................................ 12
Advisory Firm Payments for Client Referrals ................................................................................... 13
Financial Information ................................................................................................................................ 13
Balance Sheet ................................................................................................................................................ 13
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
Commitments to Clients ............................................................................................................................ 13
Bankruptcy Petitions during the Past Ten Years ............................................................................ 13
Brochure Supplement (Part 2B of Form ADV)............................................................................ 15
®
Tyler D. Hirth, CFP
.................................................................................................................................... 15
Item 2 Educational Background and Business Experience ......................................................... 15
Professional Designations: ....................................................................................................................... 15
Item 3 Disciplinary Information ............................................................................................................ 16
Item 4 Other Business Activities ............................................................................................................ 16
Item 5 Additional Compensation ........................................................................................................... 17
Brochure Supplement (Part 2B of Form ADV)............................................................................ 19
Item 6 Supervision ...................................................................................................................................... 17
George W. Mulwee ....................................................................................................................................... 19
Item 2 Educational Background and Business Experience ......................................................... 19
Item 3 Disciplinary Information ............................................................................................................ 19
Item 4 Other Business Activities ............................................................................................................ 19
Item 5 Additional Compensation ........................................................................................................... 20
Item 6 Supervision ...................................................................................................................................... 20
- 2 -
Strategic Wealth Group Registered Investment Advisor, LLC
Item 4: Services, Fees and Compensation
Firm Description
Strategic Wealth Group Registered Investment Advisor, LLC (“Strategic Wealth Group”) is an
investment advisor registered with the Securities and Exchange Commission. Strategic
Wealth Group offers investment advice to clients through the Wrap Fee Program (Program)
based on the individual needs of the client. Strategic Wealth Group is the sponsor of the
Program. In July of 2024 the ownership changed from Nathaniel H. Running to Running
Wealth Management Group MN, Inc. which is owned by Tyler Hirth. Tyer Hirth is responsible
for management of the Program accounts.
This disclosure brochure is limited to describing the Program and other information that
client should consider prior to establishing an account in the Program. For a complete
description of other programs and services offered by Strategic Wealth Group, clients should
refer to Strategic Wealth Group’s Form ADV Part 2A, a copy of which will be provided by
Program Services
Strategic Wealth Group to the client upon request.
Strategic Wealth Group provides continuous and regular supervisory services on a
discretionary and non-discretionary basis. Strategic Wealth Group will offer clients ongoing
portfolio management services through determining individual investment goals, time
horizons, objectives, and risk tolerance. Investment strategies, investment selection, assets
allocation, portfolio monitoring and the overall investment program will be based on the
Discretionary:
above factors.
When the client provides Strategic Wealth Group discretionary authority the
client will sign a limited trading authorization or equivalent. Strategic Wealth Group will have
the authority to execute transactions in the account without seeking client approval on each
Non-discretionary:
transaction.
When the client elects to use Strategic Wealth Group on a non-
discretionary basis, Strategic Wealth Group will determine the securities to be bought or sold
and the amount of the securities to be bought or sold. However, Strategic Wealth Group will
obtain prior client approval on each and every transaction before executing any transactions.
Through a multiple step discovery process, Strategic Wealth Group obtains the necessary
financial data from the client and assists the client in setting appropriate investment
objectives for the Program account. Strategic Wealth Group obtains updated information
from the client during regularly scheduled client performance reviews, as necessary in order
to provide personalized investment advice to the client.
The client will be required to enter into a written agreement with Strategic Wealth Group in
order to establish a Program account. The client will also be required to complete an
application with the broker/dealer that will act as custodian for Program account assets.
A Wrap Fee Program is an investment advisory program in which clients pay one fee for both
investment advisory services and the transaction costs in the account(s). The fee is bundled
with Strategic Wealth Group’ costs for executing transactions in the account(s). This may
result in a higher advisory fee to the client. Strategic Wealth Group does not charge clients
higher advisory fees based on the trading activity, but clients should be aware that Strategic
Wealth Group may have an incentive to limit the trading activities in the account(s) because
Strategic Wealth Group is charged for executed trades. By participating in a wrap fee
program, clients may end up paying more or less than they would through a non-wrap fee
- 3 -
Strategic Wealth Group Registered Investment Advisor, LLC
program where a lower advisory fee may be charged, but trade execution costs are passed
directly through to the client by the executing broker.
The Program Fee is not based directly upon the actual transaction or execution costs for the
transactions within the account(s). Depending on the underlying investments in the Program
and how much trading activity occurs, clients may pay more or less than if they chose another
advisory program that does not have a wrap fee, or if clients chose to pay separately for all of
the transaction costs (e.g., pay the advisory fee plus all transaction charges). Strategic Wealth
Group offers both a Wrap Fee Program and a Non-Wrap Fee Program, therefore Strategic
Wealth Group will review the investment options with clients to determine the best offering.
Similar services to those offered in the Program may be purchased from another unaffiliated
Program Fees
financial services provider.
The annual investment advisory fee will be based on a percentage of Assets Under
Management. The annual fees will be no more than 2.0%. The annual fee may be negotiable.
Accounts within the same household may be combined for a reduced fee. Fees are billed
quarterly in advance based on the amount of assets managed as of the opening of business on
the first business day of each quarter. Clients must consent in advance to direct debiting of
their investment account for the quarterly asset management fees. Quarterly advisory fees
deducted from the clients' account by the custodian will be reflected in the client statements.
Lower fees for comparable services may be available from other sources.
Clients may terminate their account within five (5) business days of signing the Investment
Advisory Agreement for a full refund. Clients may terminate advisory services with thirty (30)
days written notice. For accounts closed mid-quarter, the client will be entitled to a pro rata
refund for the days service was not provided in the final quarter. Client shall be given thirty
(30) days prior written notice of any increase in fees, and client will acknowledge, in writing,
any agreement of increase in said fees.
Additional deposits and withdrawals will be added or subtracted from account assets, as the
case may be, which may lead to an adjustment of the Annual Fee. All Annual Fees are deducted
from the account by the custodian unless other arrangements have been made in writing. The
Annual Fee is paid to and retained by Strategic Wealth Group and the advisory
representatives.
In addition to the Annual Fee, clients may also incur certain charges imposed by third parties
in connection with investments made through Program accounts, including those imposed by
the custodian. These may include, but are not limited to, the following: mutual fund or money
market 12b-1 fees, sub-transfer agent fees, certain deferred sales charges on previously
purchased mutual funds transferred into the account, other transaction charges and service
fees, IRA and qualified retirement plan fees, alternative investment administrative fees,
administrative servicing fees for trust accounts, creation and development fees or similar fees
imposed by unit investment trust sponsors, managed futures investor servicing fees, and
other charges required by law. Strategic Wealth Group does not receive any portion of these
fees. Further information regarding charges and fees assessed by a mutual fund or variable
annuity are available in the appropriate prospectus.
Mutual funds may also charge a redemption fee if a redemption is made within a specific time
period following the investment. The terms of any redemption fee are disclosed in the fund’s
prospectus. Transactions in mutual fund shares (e.g., for rebalancing, liquidations, deposits
or tax harvesting) may be subject to a fund’s frequent trading policy.
- 4 -
Strategic Wealth Group Registered Investment Advisor, LLC
Client should be aware that margin borrowing involves additional risks. Margin borrowing
will result in increased gain if the value of the securities in the account go up, but will result
in increased losses if the account value decreases. The custodian will charge margin interest
on any margin debt within the client’s account if a client elects to utilize margin. Margin rates
change and are based on prevailing interest rates at the time of use. Since Strategic Wealth
Group will receive 100% of the fees paid for management of the wrap program, this may
create an incentive to recommend that clients participate in a wrap fee program rather than
a non-wrap fee program (where clients would pay for trade execution costs) or brokerage
account where commissions are charged. This is because, in some cases, Strategic Wealth
Group may stand to earn more compensation from advisory fees paid through a wrap fee
program arrangement if clients’ accounts are not actively traded. As an investment
philosophy, Strategic Wealth Group practices a nimble trading strategy that seeks to grow
client assets in up trends and protect principal during down trends.
Item 5: Account Requirements and Types of Clients
Account Minimum
Types of Clients
Strategic Wealth Group does not require an account minimum to open an account.
Strategic Wealth Group generally provides investment advice to individuals and business
entities. Client relationships vary in scope and length of service.
Item 6: Portfolio Manager Selection and Evaluation
Portfolio Manager
Strategic Wealth Group’s model portfolios are managed by an in-house Committee made up
of seven affiliated advisors including Managing Member Tyler Hirth with assistance from
Horizon Investments. The in-house Committee makes any final decisions.
The Firm’s Investment Committee meets regularly to discuss economic trends as well as to
review investment performance within the Firm’s models.
Since no other persons, affiliated or unaffiliated will manage the wrap program, there are no
additional processes for selections or review of manager. Clients make the decision to select
Strategic Wealth Group as their portfolio manager.
Since all programs are managed by affiliated persons, there is no conflict of interest regarding
Conflicts of Interest
portfolio managers.
Strategic Wealth Group may receive support services and/or products from LPL Financial,
Inc. (“LPL”), which assist Strategic Wealth Group to better monitor and service Program
accounts maintained at LPL. These support services and/or products may be received
without cost, at a discount, and/or at another negotiated rate, and may include investment-
related research, pricing information and market data, software and other technology that
provide access to client account data, compliance and/or practice management-related
publications, consulting services, attendance at conferences, meetings, and other educational
and/or social events, marketing support, computer hardware and/or software and/or other
products used by Strategic Wealth Group in furtherance of its investment advisory business
operations. Clients do not pay more for services as a result of this arrangement. There is no
corresponding commitment made by the Strategic Wealth Group to LPL or any other entity
- 5 -
Strategic Wealth Group Registered Investment Advisor, LLC
to invest any specific amount or percentage of client assets in any specific securities as a result
of the arrangement.
Strategic Wealth Group and advisory representatives may receive additional non-cash
compensation from product sponsors. Compensation may include such items as gifts valued
at less than $100 annually, an occasional dinner or ticket to a sporting event, or
reimbursement in connection with educational meetings or marketing or advertising
initiatives.
The Program may cost the client more or less than purchasing Program services separately.
Factors that bear upon the cost of the Program account in relation to the cost of the same
services purchased separately include: the type and size of the account, the historical and/or
expected size or number of trades for the account, and the number and range of
supplementary advisory and client related services provided to the account.
The annual fee is an ongoing fee for investment advisory services and may cost the client
more than if the assets were held in a traditional brokerage account. In a brokerage account,
a client is charged a commission for each transaction and the representative has no duty to
provide ongoing advice with respect to the account. If the client plans to follow a buy and hold
strategy for the account or does not wish to purchase ongoing investment advice or
management services, the client should consider opening a brokerage account rather than a
Program account.
Strategic Wealth Group receives compensation as a result of the client’s participation in the
Program. The amount of this compensation may be more or less than what Strategic Wealth
Group would receive if the client participated in other programs or paid separately for
investment advice, brokerage and other client services. Therefore, Strategic Wealth Group
may have a financial incentive to recommend the Program account over other programs and
services. Strategic Wealth Group acts as the portfolio manager for the Program and retains
the management fee less execution costs.
Owner Tyler Hirth is dually registered with LPL as registered representative. In such
capacities, he receives normal and customary commissions as a result of securities sales
Advisory Business
outside of Program account.
Strategic Wealth Group offers clients an asset management account through the Program in
which Strategic Wealth Group directs and manages Program assets for client. Strategic
Wealth Group also offers Asset Management services offered as a Non Wrap Program
described in detail in Form ADV Part 2A. By offering both a Wrap Fee Program and a Non
Wrap Fee Program creates a conflict of interest as Strategic Wealth Group may receive higher
fees under the Wrap Fee Program. To mitigate this conflict, Strategic Wealth Group and client
will determine which Program is best suited for the client. Strategic Wealth Group will use
the Non Wrap Fee Program for accounts not utilizing the firm’s portfolio programs and the
Wrap Fee Program for accounts that will be invested in the firm’s model portfolios. Strategic
Wealth Group has a fiduciary duty to act in the best interest of the client and will act according
to those duties.
The goals and objectives for each client are documented in our client files. Investment
strategies are created that reflect the stated goals and objective. Clients may impose
restrictions on investing in certain securities or types of securities.
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Strategic Wealth Group Registered Investment Advisor, LLC
In establishing a Program account, client elects to appoint LPL as the sole and exclusive
broker/dealer and custodian with respect to processing securities transactions for the
Program account. Strategic Wealth Group does not maintain custody of client assets.
Securities transactions for Program account are effected without commissions being charged
to client. While Strategic Wealth Group makes every attempt to obtain the best execution
possible, there is no assurance that it will be obtained. Clients should consider whether or not
the appointment of LPL as the sole broker/dealer and custodian may or may not result in
certain costs or disadvantages to the client as a result of possibly less favorable executions. In
considering whether or not to restrict the execution of transactions through LPL, Strategic
Wealth Group considered the capabilities of LPL.
Although client will not be charged a transaction charge for transactions through LPL, client
should be aware that Strategic Wealth Group will be required to pay transaction charges to
LPL. The transaction charges borne by Strategic Wealth Group vary based on the type of
transactions (e.g., mutual fund, equity or fixed income security) and for mutual funds based
on whether or not the mutual fund pays 12b-1 fees and/or sub-transfer agent fees that are
retained by the custodian in amounts sufficient to cover the majority of trading costs. Client
should understand that the cost to Strategic Wealth Group of transaction charges may be a
factor the Strategic Wealth Group considers when deciding which securities to select and
whether or not to place transactions in a Program account.
No agency-cross transactions or principal transactions are effected by Strategic Wealth Group
in Program accounts.
Strategic Wealth Group may aggregate transactions for a client with other clients to improve
the quality of execution. When transactions are so aggregated, the actual prices applicable to
the aggregated transactions will be averaged, and the client will be deemed to have purchased
or sold its proportionate share of the securities involved at the average price obtained.
Strategic Wealth Group utilizes block trades to rebalance investment models or to swap one
security position for another. Non-block trades are conducted when a Client requests a
change to a different model or wishes to make a withdrawal from their account and it is found
necessary to sell one or more positions to raise sufficient cash to accommodate the Client’s
request.
Strategic Wealth Group offers clients an asset management account through the Program in
which Strategic Wealth Group directs and manages Program assets for clients. Strategic
Wealth Group also offers Financial Planning services and Asset Management services offered
as a Non Wrap Program described in detail in Form ADV Part 2A. By offering both a Wrap Fee
Program and a Non Wrap Fee Program this creates a conflict of interest as Strategic Wealth
Group may receive higher fees under the Wrap Fee Program. To mitigate this conflict,
Strategic Wealth Group and client will determine which Program is best suited for the client.
Strategic Wealth Group has a fiduciary duty to act in the best interest of the client and will act
according to those duties.
The goals and objectives for each client are documented in our client files. Investment
strategies are created that reflect the stated goals and objectives. Clients may impose
Sharing of Capital Gains
restrictions on investing in certain securities or types of securities.
Fees are not based on a share of the capital gains or capital appreciation of managed
securities.
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Strategic Wealth Group Registered Investment Advisor, LLC
Strategic Wealth Group does not use a performance-based fee structure because of the
potential conflict of interest. Performance-based compensation may create an incentive for
Methods of Analysis
the adviser to recommend an investment that may carry a higher degree of risk to the client.
Security analysis methods may include fundamental analysis and technical analysis. Investing
in securities involves risk of loss that clients should be prepared to bear. Past performance is
not a guarantee of future returns.
Fundamental analysis involves evaluating a stock using real data such as company revenues,
earnings, return on equity, and profits margins to determine underlying value and potential
growth. Technical analysis involves evaluating securities based on past prices and volume.
When creating a financial plan, Strategic Wealth Group utilizes fundamental analysis to
provide review of insurance policies for economic value and income replacement. Technical
analysis is used to review mutual funds and individual stocks. The main sources of
information include Morningstar, client documents such as tax returns and insurance policies.
In developing a financial plan for a client, Strategic Wealth Group’s analysis may include cash
flow analysis, investment planning, risk management, tax planning and estate conservation.
Based on the information gathered, a detailed strategy is tailored to the client’s specific
situation.
The main sources of information include Morningstar, client documents such as tax returns,
financial newspapers, and magazines, annual reports, prospectuses, and filings with the
General Investment Strategy
Securities and Exchange Commission.
The investment strategy for a specific client is based upon the objectives stated by the client
during consultations. The client may change these objectives at any time. Each client executes
an Investment Policy Statement, Risk Tolerance or similar form that documents their
objectives and their desired investment strategy.
Security Specific Material Risks
Other strategies may include long-term purchases and short-term purchases.
All investment programs have certain risks that are borne by the investor. Fundamental
analysis may involve interest rate risk, market risk, business risk, and financial risk. Risks
involved in technical analysis are inflation risk, reinvestment risk, and market risk.
Interest-rate Risk
Our investment approach constantly keeps the risk of loss in mind. Investors face the
following investment risks and should discuss these risks with Strategic Wealth Group:
Market Risk
: Fluctuations in interest rates may cause investment prices to
fluctuate. For example, when interest rates rise, yields on existing bonds become less
attractive, causing their market values to decline.
Inflation Risk
: The price of a security, bond, or mutual fund may drop in reaction to
tangible and intangible events and conditions. This type of risk is caused by external
factors independent of a security’s particular underlying circumstances. For example,
political, economic and social conditions may trigger market events.
: When any type of inflation is present, a dollar today will buy more than a
dollar next year, because purchasing power is eroding at the rate of inflation.
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Strategic Wealth Group Registered Investment Advisor, LLC
Reinvestment Risk
Business Risk
: This is the risk that future proceeds from investments may have to be
reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates
to fixed income securities.
Financial Risk
: These risks are associated with a particular industry or a particular
company within an industry. For example, oil-drilling companies depend on finding oil
and then refining it, a lengthy process, before they can generate a profit. They carry a
higher risk of profitability than an electric company which generates its income from a
steady stream of customers who buy electricity no matter what the economic
environment is like.
Trading on Margin:
: Excessive borrowing to finance a business’ operations increases the risk
of profitability, because the company must meet the terms of its obligations in good
times and bad. During periods of financial stress, the inability to meet loan obligations
may result in bankruptcy and/or a declining market value.
Proxy Voting
In a cash account, the risk is limited to the amount of money that has
been invested. In a margin account, risk includes the amount of money invested plus the
amount that has been loaned. As market conditions fluctuate, the value of marginable
securities will also fluctuate, causing a change in the overall account balance and debt
ratio. As a result, if the value of the securities held in a margin account depreciates, the
client will be required to deposit additional cash or make full payment of the margin loan
to bring account back up to maintenance levels. Clients who cannot comply with such a
margin call may be sold out or bought in by the brokerage firm.
Strategic Wealth Group does not vote proxies on securities. Clients are expected to vote their
own proxies. The client will receive their proxies directly from the custodian of their account
or from a transfer agent.
When assistance on voting proxies is requested, Strategic Wealth Group will provide
recommendations to the client. If a conflict of interest exists, it will be disclosed to the client
Item 7: Client Information Provided to Portfolio Managers
Description
Strategic Wealth Group obtains the necessary financial data from the client and assists the
client in setting appropriate investment objectives for the Program account. Strategic Wealth
Group obtains updated information from the client as necessary in order to provide
personalized investment advice to the client. It is the client’s responsibility to inform Strategic
Wealth Group of any changes in their stated objectives, financial situation, life circumstances
or risk tolerance.
Client will be required to enter into a written agreement with Strategic Wealth Group in order
to establish a Program account. Client will also be required to complete an application with
the broker/dealer that will act as custodian for Program account assets.
Item 8: Client Contact with Portfolio Managers
Restrictions
There are no restrictions placed on clients’ ability to contact and consult with the portfolio
managers since Tyler Hirth is the portfolio manager.
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Strategic Wealth Group Registered Investment Advisor, LLC
Item 9: Additional Information
Disciplinary Information
Criminal or Civil Actions
Strategic Wealth Group and its management have not been involved in any criminal or civil
action.
Administrative Enforcement Proceedings
Strategic Wealth Group and its management have not been involved in administrative
enforcement proceedings.
Self-Regulatory Organization Enforcement Proceedings
Strategic Wealth Group and its management have not been involved in legal or disciplinary
Other Financial Industry Activities and Affiliations
events related to past or present investment clients.
Broker-Dealer or Representative Registration
Strategic Wealth Group is not a broker-dealer nor does the firm have an application pending
to become one. The owner of the firm is a registered representative of a broker-dealer (LPL
Financial, Inc.).
Futures or Commodity Registration
Strategic Wealth Group does not have an application pending to register as a futures
commission merchant, commodity pool operator, or a commodity trading advisor.
Material Relationships Maintained by this Advisory Business and Conflicts of Interest
Certain associated persons of Strategic Wealth Group are licensed as insurance agents for
various insurance companies, as well as registered representatives of LPL Financial.
Approximately 5% of their time is spent in their insurance practices and greater than 50% in
their capacities with LPL Financial, Inc. As a result of this relationship, LPL Financial may have
access to certain confidential information (e.g., financial information, investment objectives,
transactions and holdings) about Strategic Wealth Group’s clients, even if client does not
establish any account through LPL. If you would like a copy of the LPL Financial privacy
policy, please contact your advisor. From time to time, associated persons will offer clients
services from those activities.
This represents a conflict of interest because it gives an incentive to recommend products and
services based on the commission amount received. This conflict is mitigated by disclosures,
procedures, and the firm’s Fiduciary obligation and to place the best interest of the client first
and the clients are not required to purchase any products or services. Clients have the option
to purchase these products or services through another insurance agent or registered
Code of Ethics Description
representative of their choosing.
The employees of Strategic Wealth Group have committed to a Code of Ethics (“Code”). The
purpose of our Code is to set forth standards of conduct expected of Strategic Wealth Group
employees and addresses conflicts that may arise. The Code defines acceptable behavior for
employees of Strategic Wealth Group. The Code reflects Strategic Wealth Group and its
supervised persons’ responsibility to act in the best interest of their client.
One area the Code addresses is when employees buy or sell securities for their personal
accounts and how to mitigate any conflict of interest with our clients. We do not allow any
employees to use non-public material information for their personal profit or to use internal
research for their personal benefit in conflict with the benefit to our clients.
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Strategic Wealth Group Registered Investment Advisor, LLC
Strategic Wealth Group’s policy prohibits any person from acting upon or otherwise misusing
non-public or inside information. No advisory representative or other employee, officer or
director of Strategic Wealth Group may recommend any transaction in a security or its
derivative to advisory clients or engage in personal securities transactions for a security or
its derivatives if the advisory representative possesses material, non-public information
regarding the security.
Strategic Wealth Group’s Code is based on the guiding principle that the interests of the client
are our top priority. Strategic Wealth Group’s officers, directors, advisors, and other
employees have a fiduciary duty to our clients and must diligently perform that duty to
maintain the complete trust and confidence of our clients. When a conflict arises, it is our
obligation to put the client’s interests over the interests of either employees or the company.
The Code applies to “access” persons. “Access” persons are employees who have access to
non-public information regarding any clients' purchase or sale of securities, or non-public
information regarding the portfolio holdings of any reportable fund, who are involved in
making securities recommendations to clients, or who have access to such recommendations
that are non-public.
The firm will provide a copy of the Code of Ethics to any client or prospective client upon
request.
Investment Recommendations Involving a Material Financial Interest and Conflict of
Interest
Strategic Wealth Group and its employees do not recommend to clients securities in which
we have a material financial interest.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest
Strategic Wealth Group employees may buy or sell securities that are also held by clients. In
order to avoid conflicts of interest such as front running of client trades, employees are
required to disclose all reportable securities transactions as well as provide Strategic Wealth
Group with copies of their brokerage statements.
The Chief Compliance Officer of Strategic Wealth Group is George W. Mulwee. He reviews all
employee trades each quarter. The personal trading reviews ensure that the personal trading
of employees does not affect the markets and that clients of the firm receive preferential
treatment over employee transactions.
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Transactions and Conflicts of Interest
Strategic Wealth Group does not maintain a firm proprietary trading account and does not
have a material financial interest in any securities being recommended and therefore no
conflicts of interest exist. However, employees may buy or sell securities at the same time
they buy or sell securities for clients. In order to mitigate conflicts of interest such as front
running, employees are required to disclose all reportable securities transactions as well as
provide Strategic Wealth Group with copies of their brokerage statements.
The Chief Compliance Officer of Strategic Wealth Group is George W. Mulwee. He reviews all
employee trades each quarter. The personal trading reviews ensure that the personal trading
of employees does not affect the markets and that clients of the firm receive preferential
treatment over employee transactions.
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Strategic Wealth Group Registered Investment Advisor, LLC
Review of Accounts
Schedule for Periodic Review of Client Accounts and Advisory Persons Involved
Account reviews are performed at least quarterly depending on the nature of the account and
client relationship. All reviews are conducted by the Investment Advisor Representative of
the account. Account reviews are performed more frequently when market conditions
dictate.
Review of Client Accounts on Non-Periodic Basis
Other conditions that may trigger a review of clients’ accounts are changes in the tax laws,
new investment information, and changes in a client's own situation.
Content of Client Provided Reports and Frequency
Clients receive written account statements usually on a monthly basis, but no less than
quarterly for managed accounts. Strategic Wealth Group will also provide clients with
Client Referrals and Other Compensation
quarterly performance reports.
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of
Interest
Strategic Wealth Group utilizes the services of custodial broker dealers. Economic benefits
are received by Strategic Wealth Group which would not be received if Strategic Wealth
Group did not give investment advice to clients. These benefits include the following products
and services (provided without cost or at a discount): receipt of duplicate Client statements
and confirmations; research related products and tools; consulting services; access to a
trading desk serving Strategic Wealth Group participants; access to block trading (which
provides the ability to aggregate securities transactions for execution and then allocate the
appropriate shares to Client accounts); the ability to have advisory fees deducted directly
from Client accounts; access to an electronic communications network for Client order entry
and account information; access to mutual funds with no transaction fees and to certain
institutional money managers; and discounts on compliance, marketing, research,
technology, and practice management products or services provided to Strategic Wealth
Group by third party vendors.
As part of its fiduciary duties to clients, Strategic Wealth Group endeavors at all times to put
the interests of its clients first. Clients should be aware, however, that the receipt of economic
benefits by Strategic Wealth Group or its related persons in and of itself creates a conflict of
interest and may indirectly influence the Strategic Wealth Group’s choice of LPL for custody
and brokerage services.
Strategic Wealth Group will, from time to time, enter into agreements with individuals and
organizations (“referring party”) that refer Clients to Strategic Wealth Group in exchange for
compensation. This activity will either be considered an endorsement or testimonial,
depending on if the referring party is a Client of Strategic Wealth Group. For all Clients
introduced by a referring party, Strategic Wealth Group may pay that referring party a fee
pursuant to a previously executed agreement. While the specific terms of each agreement may
differ, the compensation will be based upon Strategic Wealth Group’s engagement of new
Clients and is calculated using a fixed fee, or a varying percentage of the fees paid to Strategic
Wealth Group by such Clients. Any such fee shall be paid solely from Strategic Wealth Group’s
investment management fee and shall not result in any additional charge to the Client.
Strategic Wealth Group ensures that referring parties are registered with all appropriate
jurisdictions or exempt from registration as investment advisors or investment advisor
representatives.
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Strategic Wealth Group Registered Investment Advisor, LLC
Each referred Client to Strategic Wealth Group under such an arrangement will receive a copy
of this brochure and a written disclosure clearly and prominently disclosing if the referring
party is a current Client or investor, the compensation that will be paid by Strategic Wealth
Group to the referring party and any material conflicts of interest. The referring party is
required provide this disclosure at the time the endorsement or testimonial is disseminated
and will obtain the Client’s signature acknowledging receipt of Strategic Wealth Group’s
disclosure brochure and the written disclosure.
Advisory Firm Payments for Client Referrals
Financial Information
Strategic Wealth Group does compensate for client referrals.
Balance Sheet
A balance sheet is not required to be provided because Strategic Wealth Group does not serve
as a custodian for client funds or securities and Strategic Wealth Group does not require
prepayment of fees of more than $500 per client and six months or more in advance.
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
Commitments to Clients
Strategic Wealth Group has no condition that is reasonably likely to impair our ability to meet
contractual commitments to our clients.
Bankruptcy Petitions during the Past Ten Years
Neither Strategic Wealth Group nor its management has had any bankruptcy petitions in the
last ten years.
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Strategic Wealth Group Registered Investment Advisor, LLC
S U P E R V I S E D P E R S O N B R O C H U R E
F O R M A D V P A R T 2 B
®
Tyler D. Hirth, CFP
Strategic Wealth Group
Registered Investment Advisors, LLC
Office Address:
7820 Terrey Pine Ct, #200
Eden Prairie, MN 55347
Tel: 952-843-4944
Fax: 952-666-5117
Tyler.h@strategicwg.net
F E B R U A R Y 1 4 , 2 0 2 6
This brochure supplement provides information about Tyler D. Hirth and supplements the
Strategic Wealth Group Registered Investment Advisors, LLC brochure. You should have received
a copy of that brochure. Please contact Tyler D. Hirth if you did not receive the brochure or if you
have any questions about the contents of this supplement.
Additional information about Tyler D. Hirth (CRD #5392371) is available on the SEC’s website at
www.adviserinfo.sec.gov.
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Strategic Wealth Group Registered Investment Advisor, LLC
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Tyler D. Hirth, CFP®
•
Item 2 Educational Background and Business Experience
Year of birth: 1983
•
Educational Background:
Bemidji State University; Bachelor of Science in Business Administration,
Entrepreneurship/Small Business Management, emphasis; 2006
•
Business Experience:
•
Strategic Wealth Group Registered Investment Advisors, LLC; Owner; 07/2024 –
Present
o
Running Wealth Management Group MN, Inc.
•
CEO; 07/2024 – Present
•
Minority Owner; 08/2016 – 07/2024Running Tax Services, LLC; Owner; 01/2021 -
Present
•
•
•
•
•
•
•
Professional Designations:
Strategic Wealth Group Registered Investment Advisors, LLC; Investment Advisor
Representative; 07/2016 - Present
LPL Financial LLC; Registered Representative; 08/2016 – Present
Tyler Hirth, Sole Proprietor; Insurance Agent; 04/2015 – Present
Tyler Hirth and Morgan Hirth Partnership; Owner; 02/2007 - Present
Cetera Advisors LLC; Registered Representative/Investment Advisor Representative;
05/2015 - 07/2016
Metlife Securities Inc.; Investment Advisor Representative; 02/2014 – 05/2015
Metlife Securities Inc.; Registered Representative; 08/2007 – 05/2015
Auto Owners; Owner; 06/2006 – 07/2007
Tyler D. Hirth has earned certifications and credentials that are required to be explained in
further detail.
®
, CFP
®
and federally registered CFP (with flame design)
marks”) are professional certification marks granted in the
®
®
®
marks, an individual must satisfactorily fulfill the following
•
™
The Certified Financial Planner
marks (collectively, the “CFP
United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”).
certification is a voluntary certification; no federal or state law or regulation
The CFP
requires financial planners to hold CFP
certification. It is recognized in the United States
and a number of other countries for its (1) high standard of professional education; (2)
stringent code of conduct and standards of practice; and (3) ethical requirements that govern
professional engagements with Clients.
To attain the right to use the CFP
requirements:
Education – Complete an advanced college-level course of study addressing the
financial planning subject areas that CFP Board’s studies have determined as
necessary for the competent and professional delivery of financial planning services,
and attain a Bachelor’s Degree from a regionally accredited United States college or
university (or its equivalent from a foreign university). CFP Board’s financial planning
- 15 -
Strategic Wealth Group Registered Investment Advisor, LLC
•
subject areas include insurance planning and risk management, employee benefits
planning, investment planning, income tax planning, retirement planning, and estate
planning;
®
•
Examination – Pass the comprehensive CFP
Certification Examination. The
examination includes case studies and Client scenarios designed to test one’s ability to
correctly diagnose financial planning issues and apply one’s knowledge of financial
planning to real world circumstances;
Standards of Professional Conduct
•
Experience – Complete at least three years of full-time financial planning-related
experience (or the equivalent, measured as 2,000 hours per year); and
, a set of
®
Ethics – Agree to be bound by CFP Board’s
documents outlining the ethical and practice standards for CFP
professionals.
®
•
Individuals who become certified must complete the following ongoing education and ethics
requirements in order to maintain the right to continue to use the CFP
marks:
Standards of
Code of Ethics
Continuing Education – Complete 30 hours of continuing education hours every two
Professional Conduct
years, including two hours on the
and other parts of the
, to maintain competence and keep up with developments in the
Standards of Professional Conduct.
•
financial planning field; and
Standards
®
®
professionals provide financial planning
professionals must provide
Ethics – Renew an agreement to be bound by the
The
prominently require that CFP
services at a fiduciary standard of care. This means CFP
financial planning services in the best interests of their Clients.
®
®
certification.
None to report in the past 20 years.
professionals who fail to comply with the above standards and requirements may be
CFP
subject to CFP Board’s enforcement process, which could result in suspension or permanent
Item 3 Disciplinary Information
revocation of their CFP
Criminal or Civil Action:
Administrative Proceeding:
Self-Regulatory Proceeding:
Item 4 Other Business Activities
None to report in the past 20 years.
None to report in the past 20 years.
Tyler Hirth has a financial industry affiliated business as an insurance agent, owns an
accounting and tax firm and is also a registered representative with LPL Financial; a broker-
dealer. A majority of his time is spent on these practices. From time to time, he will offer
clients services from those activities. He may receive separate yet typical compensation in the
form of commissions for the sale of insurance products, tax services or securities.
This represents a conflict of interest because it gives an incentive to recommend products and
services based on the commission amount received. This conflict is by disclosures,
procedures, and the firm’s Fiduciary obligation to place the best interest of the client first and
the clients are not required to purchase any products or services. Clients have the option to
purchase these products or services through another insurance agent, tax provider or
registered representative of their choosing.
Additionally, Tyler Hirth owns farmland near Morris, MN that generates rental income and is
the sole owner and CEO of Running Wealth Management Group MN, Inc. a corporation
established for tax purposes. There is no conflict of interest because no products or services
are provided and clients are not solicited services from this activity.
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Strategic Wealth Group Registered Investment Advisor, LLC
Item 5 Additional Compensation
Tyler D. Hirth receives additional compensation in his capacity as an insurance agent, tax
Item 6 Supervision
provider and registered representative, but he does not receive any performance based fees.
Mr. Hirth is the Managing Member of Strategic Wealth Group therefore he is responsible for
supervision and formulation and monitoring of investment advice offered to clients. He will
adhere to the policies and procedures as described in the firm’s Compliance Manual.
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Strategic Wealth Group Registered Investment Advisor, LLC
S U P E R V I S E D P E R S O N B R O C H U R E
F O R M A D V P A R T 2 B
George W. Mulwee
Strategic Wealth Group
Registered Investment Advisor, LLC
Office Address:
7820 Terrey Pine Ct, #200
Eden Prairie, MN 55347
Tel: 952-843-4944
Fax: 952-843-4943
george.m@strategicwg.net
F E B R U A R Y 1 4 , 2 0 2 6
This brochure supplement provides information about George W. Mulwee and supplements the
Strategic Wealth Group Registered Investment Advisors, LLC brochure. You should have received
a copy of that brochure. Please contact George W. Mulwee if you did not receive the brochure or if
you have any questions about the contents of this supplement.
Additional information about George W. Mulwee (CRD #4144139) is available on the SEC’s website
at www.adviserinfo.sec.gov.
- 18 -
Strategic Wealth Group Registered Investment Advisor, LLC
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
George W. Mulwee
•
Item 2 Educational Background and Business Experience
Year of birth: 1978
•
Educational Background:
No post-secondary education
•
Business Experience:
•
Strategic Wealth Group Registered Investment Advisor, LLC; Chief Compliance
Officer/Investment Advisor Representative; 07/2017 - Present
•
LPL Financial, LLC; Registered Representative; 07/2017 – Present
•
Cetera Advisors LLC; Director Supervision; 05/2014 - 07/2017
•
Cetera Financial Specialists LLC; Director Supervision; 01/2015 - 02/2015
•
Summit Brokerage Services, Inc.; Director Supervision; 01/2015 - 02/2015
•
Legend Equities Corporation; Director Supervision; 01/2015 - 02/2015
•
J.P. Turner & Company, L.L.C.; Director Supervision; 01/2015 - 02/2015
•
Investors Capital Corp; Director Supervision; 01/2015 - 02/2015
•
Cetera Advisor Networks LLC; Director Supervision; 01/2015 - 02/2015
•
Cetera Investment Services LLC; Director Supervision; 01/2015 - 02/2015
•
First Allied Securities, Inc.; Registered Representative; 01/2015 - 02/2015
•
First Allied Securities, Inc.; Director Supervision; 01/2015 - 02/2015
•
Woodbury Financial Services, Inc.; Registered Representative; 07/2011 - 05/2014
•
Ameriprise Financial Services, Inc.; Investigator; 09/2010 – 07/2011
Item 3 Disciplinary Information
Woodbury Financial Services, Inc.; Brokerage Operations; 06/2002 – 09/2010
None to report in the past 20 years.
Criminal or Civil Action:
Administrative Proceeding:
Self-Regulatory Proceeding:
Item 4 Other Business Activities
None to report in the past 20 years.
None to report in the past 20 years.
George W. Mulwee has a financial industry affiliated business as a registered
representative with LPL Financial; a broker-dealer. A majority of his time is spent on this
practice. From time to time, he will offer clients services from this activity. He may receive
separate yet typical compensation in the form of commissions for the sale of securities.
This represents a conflict of interest because it gives an incentive to recommend products
and services based on the commission amount received. This conflict is mitigated by
disclosures, procedures, and the firm’s Fiduciary obligation to place the best interest of the
client first and the clients are not required to purchase any products or services. Clients
have the option to purchase these products or services through another registered
representative of their choosing.
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Strategic Wealth Group Registered Investment Advisor, LLC
Item 5 Additional Compensation
Item 6 Supervision
George W. Mulwee receives additional compensation in his capacity as a registered
representative, but he does not receive any performance based fees.
George W. Mulwee is the Chief Compliance Officer of Strategic Wealth Group and therefore
he is solely responsible for all supervision and formulation and monitoring of investment
advice offered to clients. He will adhere to the policies and procedures as described in
Strategic Wealth Group compliance manual.
- 20 -
Strategic Wealth Group Registered Investment Advisor, LLC