Overview
- Headquarters
- Milwaukee, WI
- Average Client Assets
- $2.6 million
- SEC CRD Number
- 108931
Fee Structure
Primary Fee Schedule (ADV PART 2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 1.20% |
| $500,001 | $2,000,000 | 0.75% |
| $2,000,001 | $5,000,000 | 0.50% |
| $5,000,001 | and above | 0.25% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $9,750 | 0.98% |
| $5 million | $32,250 | 0.64% |
| $10 million | $44,750 | 0.45% |
| $50 million | $144,750 | 0.29% |
| $100 million | $269,750 | 0.27% |
Clients
- HNW Share of Firm Assets
- 94.02%
- Total Client Accounts
- 822
- Discretionary Accounts
- 820
- Non-Discretionary Accounts
- 2
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
Primary Brochure: ADV PART 2A (2026-03-25)
View Document Text
Item 1
Cover Page
The MilWealth Group, LLC
Form ADV Part 2A
125 South 84th Street, Suite 130
Milwaukee, WI 53214
(414) 475-1369
www.milwealth.com
March 25, 2026
This brochure provides information about the qualifications and business practices of The
MilWealth Group, LLC (The MilWealth Group). If you have any questions about the contents
of this brochure, please contact us at (414) 475-1369 or mmiler@milwealth.com. The
information in this brochure has not been approved or verified by the United States Securities
and Exchange Commission or by any state securities authority.
Additional information about The MilWealth Group also is available on the SEC’s website at
www.adviserinfo.sec.gov.
The MilWealth Group is an SEC registered investment adviser. Registration of an adviser with
the SEC does not imply a certain level of skill or training.
The MilWealth Group, LLC
Form ADV Part 2A
March 25, 2026
Item 2
Material Changes
Below is a summary of material changes made to our Form ADV Part 2A since our January 17,
2025 annual update filing.
Item 8-Methods of Analysis, Investment Strategies and Risk of Loss
We updated this item to add risks related to the use of artificial intelligence.
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The MilWealth Group, LLC
Form ADV Part 2A
March 25, 2026
Item 3
Table of Contents
Item 1 Cover Page ................................................................................................................................... 1
Item 2 Material Changes ........................................................................................................................ 2
Item 3 Table of Contents ........................................................................................................................ 3
Item 4 Advisory Business ....................................................................................................................... 4
Item 5 Fees and Compensation .............................................................................................................. 5
Item 6 Performance-Based Fees and Side-by-Side Management ....................................................... 6
Item 7 Types of Clients ........................................................................................................................... 6
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................................ 7
Item 9 Disciplinary Information .......................................................................................................... 11
Item 10 Other Financial Industry Activities and Affiliations ............................................................. 11
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ... 11
Item 12 Brokerage Practices .................................................................................................................. 12
Item 13 Review of Accounts ................................................................................................................... 14
Item 14 Client Referrals and Other Compensation ............................................................................. 14
Item 15 Custody ...................................................................................................................................... 15
Item 16 Investment Discretion ............................................................................................................... 15
Item 17 Voting Client Securities ............................................................................................................ 15
Item 18 Financial Information ............................................................................................................... 15
Other Information .................................................................................................................................... 15
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Form ADV Part 2A
March 25, 2026
Item 4
Advisory Business
The MilWealth Group, LLC was originally founded in 1995 as McCarthy Financial Management
LLC. Matt Miler and Jaqueline Schneider are the principal owners. Our legal name changed as
of January 1, 2025 from McCarthy Grittinger Financial Group, LLC to The MilWealth Group,
LLC.
The MilWealth Group is an independent, fee only, financial planning and investment advisory
firm investing primarily in Exchanged Traded Funds (“ETFs”) and mutual funds for our clients.
Our primary service offered is discretionary ongoing investment management services, utilizing
a comprehensive financial planning approach. We may also provide general counsel to clients in
the areas of financial, tax, retirement, insurance and estate planning, including tax preparation
services for select clients. We work with clients to develop and maintain a comprehensive
document reflecting their current wealth situation. After understanding the client’s situation, the
client accounts are generally invested in one of our investment models that is meant to achieve
their objectives and goals. When provided to our investment management clients, financial
planning services are offered at no additional fees. We also offer financial planning services to
non-investment management clients for a fee.
As noted in Item 12, Schwab Institutional (“Schwab”) and Transamerica– (collectively our
clients’ “Primary Custodians”) provide custodial services to our clients, with Schwab providing
custody services for the majority of our clients’ assets. However, at the discretion of our client,
we may consider accounts and assets held outside of these custodians’ accounts when providing
advisory services to the client.
Retirement Plan Advisory Services
We manage on a non-discretionary basis certain retirement accounts through Tamarac using the
Yodlee aggregator. This allows clients to give us view only access to these types of accounts. It
is the responsibility of the client(s) to place the trades as recommended by The MilWealth
Group, as we do not have any direct access to these accounts. These accounts are considered
managed accounts and are included in non-discretionary assets under management.
Assets Under Management as of December 31, 2025
Non-Discretionary: $ 8,535,712
Discretionary: $ 488,364,912
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Form ADV Part 2A
March 25, 2026
Item 5
Fees and Compensation
Fee Information for Investment Management Clients
We charge clients an investment advisory fee based on a percentage of assets under
management. We use a tiered fee schedule with breakpoints that result in decreasing fee rates as
assets under management rise.
Investment advisory fees are calculated using security prices provided by the client’s custodian
and are billed quarterly in arrears based on the market value of the client’s account on the last
day of the quarter. We may aggregate accounts for related members of the same family for fee
billing purposes. Based on written client authorization, fees are deducted automatically from the
client’s custodial accounts at the end of the quarter and fully disclosed on quarterly client
account statements.
When entering into a new investment advisory agreement with us, a client’s initial fee will be
calculated as follows:
•
•
•
•
If the first deposit is made to any account that is part of the client relationship in the first
month of a quarter, the client will be charged a full investment advisory fee on all assets
received during the quarter.
If the first deposit is made to any account that is part of the client relationship in the
second month of a quarter, the client will pay 67% of the investment advisory fee for all
assets received during the quarter.
If the first deposit is made to any account that is part of the client relationship in the first
two weeks of the third month of a quarter, the client will pay 33% of the investment
advisory fee for all assets received during the quarter.
If the first deposit is made to any account that is part of the client relationship in the final
two weeks of the third month of a quarter, the client will not pay a fee for that quarter.
• A full investment advisory fee will be assessed thereafter.
Clients separately incur custody and fund fees and expenses imbedded within mutual funds and
ETFs. Clients also pay fees on any Retirement Plan Advisory Services accounts held within The
MilWealth Group managed accounts. Please see Item 12 for additional information on our
brokerage practices and courtesy trades.
New clients pay investment advisory fees according to the fee schedule noted below and The
MilWealth Group does not negotiate fees with new clients.
Clients of The MilWealth Group retained prior to March 2020 pay investment advisory fees
based on a lower standard fee schedule.
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Standard New Client Account Fee Schedule (effective March 2020)
Market Value
First $500,000
$500,001 - $2,000,000
$2,000,001 - $5,000,000
Over $5,000,001
Annual Fee
1.20%
.75%
.50%
.25%
Fee Information for Financial Planning Clients
We offer financial planning services to clients who do not utilize our investment management
services. Clients using this service will be charged a flat fee based on the complexity of the
planning to be performed.
Account Valuation Practices
The MilWealth Group uses pricing information provided by the client’s custodian for purposes
of valuing client portfolios, whether for fee billing or investment performance calculations.
Prices of securities we routinely recommend to clients are widely available through financial
publications, and do not generally require us to independently determine a value.
We maintain account valuation (including fair valuation) policies and procedures designed to
provide reasonable assurance the prices we use for fee billing and investment performance
calculation purposes are accurate.
Item 6
Performance-Based Fees and Side-by-Side Management
We do not charge our clients performance-based fees (fees based on a share of capital gains or
capital appreciation of the assets in a client’s account).
Item 7
Types of Clients
The MilWealth Group provides investment management services to individuals, high-net worth
individuals and corporations. All clients are required to enter into an investment advisory
agreement with us prior to us providing any services. We do not have a minimum account size
requirement.
We manage separate accounts for family members and friends. These clients receive standard
client reporting and are not involved in our day-to-day operations. They also have no knowledge
of our trading or investment activities and do not receive a reduction in fees. In addition, if the
employee who serves as the primary contact is the client’s relative or friend then we will assign
another employee to be the secondary contact to perform periodic reviews of the account.
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Either you or we may terminate the investment advisory agreement at any time by giving 30 days
written notice. Termination of an advisory agreement by you will not affect transactions we
have initiated on your behalf prior to the effective date of such termination.
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss
Analyses and Strategies
We make specific investment recommendations utilizing the broadly accepted investment theory
of asset allocation. Asset allocation focuses on designing well-diversified investment portfolios
covering multiple “asset classes” or types of investments utilizing mostly open-end mutual
funds, ETFs, US Treasury debt, variable annuities and brokered certificates of deposit
(“Brokered CDs”). We work with clients to develop and maintain a comprehensive document
reflecting their current wealth situation. After understanding the client’s situation, the client
accounts are generally invested in one of our investment models that is meant to achieve their
objectives and goals. The mutual funds and ETFs recommended by The MilWealth Group
primarily invest in U.S. stocks of any market capitalization, foreign stocks including emerging
markets, fixed income securities, U.S. Government and Government Agency securities,
corporate debt and municipal securities. The MilWealth Group receives no fees or compensation
from any mutual fund or ETF. Like all marketable securities, clients face a risk of the value of
these securities fluctuating, both up and down. While we cannot control market and economic
factors which influence the price of these securities, we utilize an Investment Committee to
monitor and perform due diligence on investment options. When providing advisory services to
accounts held outside of the Primary Custodians, our advice may be limited by a menu of options
established by an unaffiliated entity (such as a retirement plan’s trustees). In such cases, we will
advise the clients with respect to the securities available for investment, and we do not actively
monitor the investment merits of such securities.
The MilWealth Group's main sources of information include, but are not limited to, financial
newspapers and magazines, research subscriptions, annual reports, prospectuses, public filings
and company press releases and fund company notifications.
General Risks
We do not offer any products or services that guarantee rates of return on investments for any
time period to any client. All clients assume the risk that investment returns may be negative or
below the rates of return of other investment advisers, market indices or investment products.
Security Risks
Client accounts may be subject to the following risks:
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• Market Risk. Clients should have a long-term perspective and be able to tolerate
potentially sharp declines in market value. Market risks, including but not limited to
political, regulatory, economic and social developments, and developments that impact
specific economic sectors, industries or segments of the market, can affect the prices of
securities held by mutual funds or ETFs in which clients invest which impacts the value
of client accounts. In addition, turbulence in financial markets and reduced liquidity in
equity, credit and/or fixed income markets may negatively affect many companies, which
could adversely affect client accounts. These risks may be magnified if certain events or
developments adversely interrupt the global supply chain. In these and other
circumstances, such risks might affect companies on a worldwide scale. Recent examples
include risks related to the coronavirus pandemic and the implementation of broad-based
tariffs.
• Allocation Risk. At times, our judgments as to the asset classes in which client accounts
should invest may prove to be wrong, as some asset classes may perform worse than
others or the equity markets generally from time to time or for extended periods of time.
• Mutual Fund Risk. Mutual funds vary in risk depending on their investments, with
aggressive growth funds being more risky than conservative, income-oriented funds.
Mutual funds are subject to investment advisory, transactional, operating, and other
expenses. The value of mutual funds’ investments and the net asset value of the funds’
shares will fluctuate in response to changes in market and economic conditions, as well
as the financial condition and prospects of companies in which the funds invest. The
performance of each fund will depend on whether the fund’s investment adviser is
successful in pursuing the fund’s investment strategy.
• ETF Risk. You may lose money investing in an ETF if the value of securities owned by
the ETF declines. You could pay more to purchase ETF shares, or receive less in a sale of
shares, than the actual net asset value of the shares. In addition, when you invest in an
ETF, you will bear additional expenses based on your pro rata share of the ETF’s
operating expenses. The risk of owning an ETF generally reflects the risks of the
underlying securities that the ETF is designed to track and the investment strategies
employed by such ETF. The ETF may not track the underlying index.
• Equity Securities Risk. Mutual funds and ETFs in which clients invest may invest in
common stocks and other equity securities. Stocks generally increase or decrease in value
based on the earnings of a company and based on general industry and market conditions.
The value of a company’s share price may decline as a result of poor decisions made by
management, lower demand for the company’s services or products or if the company’s
revenues fall short of expectations. There are also risks associated with the stock market
overall. The stock market may experience periods of turbulence and instability.
• Fixed Income Risk. Mutual funds and ETFs in which clients invest may invest in bonds.
A bond’s market value is affected significantly by changes in interest rates – generally,
when interest rates rise, the bond’s market value declines and when interest rates decline,
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Form ADV Part 2A
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its market value rises. Generally, a bond with a longer maturity will entail greater interest
rate risk but may have a higher yield. Conversely, a bond with a shorter maturity will
entail less interest rate risk but may have a lower yield. An additional risk is reinvestment
risk that future cash flows will need to be invested in lower yielding securities. A bond’s
value may also be affected by changes in its credit quality rating or the issuer’s financial
condition.
• Foreign Securities Risk. Mutual funds and ETFs in which clients invest may invest in
foreign securities. Foreign securities are subject to additional risks not typically
associated with investments in domestic securities. These risks may include, among
others, currency risk, country risks (political, diplomatic, regional conflicts, terrorism,
war, social and economic instability, currency devaluations and policies that have the
effect of limiting or restricting foreign investment or the movement of assets), different
trading practices, less government supervision, less publicly available information,
limited trading markets and greater volatility. To the extent that the mutual funds or ETFs
invest in issuers located in emerging markets, the risk may be heightened by political
changes, changes in taxation, or currency controls that could adversely affect the values
of these investments. Emerging markets have been more volatile than the markets of
developed countries with more mature economies.
• Municipal Securities. Funds in which clients invest may invest in municipal securities.
Municipal securities carry different risks than other fixed income securities described
above. These risks include the municipality’s ability to raise additional tax revenue or
other revenue (in the event the bonds are revenue bonds) to pay interest on its debt and to
retire its debt at maturity. Municipal bonds are generally tax-free at the federal level, but
may be taxable in individual states other than the state in which both the investor and
municipal issuer are domiciled.
• Brokered CDs Risk. Brokered CDs are certificates of deposit purchased through a
brokerage firm, not a bank. A Brokered CD is subject to interest rate risk if the CD would
need to be sold before maturity, a client could receive less proceeds than the purchase
price if interest rates have risen since purchase.
• Longevity Risk. This is the risk of outliving your savings. This risk is particularly
relevant for people who are retired or are nearing retirement.
• Environmental, Social and Governance (“ESG”) Risk. ESG mutual funds and ETFs in
which clients invest in companies that have an ESG focus. This may result in the funds
investing in securities or industry sectors that underperform the market as a whole or
underperform other funds screened for ESG standards.
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Cybersecurity Risk
We rely on information technology and electronic communications to conduct business,
which subjects us and our clients to the risk of cyber incidents. While we have controls we
believe are reasonably designed to protect against cyber incidents resulting in unauthorized
access to confidential information or business disruptions, not all cyber incidents are
preventable. Should a cyber incident occur, it would likely have a negative impact on our
firm and its clients.
Natural Disaster/Epidemic/Pandemic Risk
Natural or environmental disasters, such as severe weather and widespread disease, including
pandemics and epidemics, have been and can be highly disruptive to economies and markets,
adversely impacting individual companies, sectors, industries, markets, currencies, interest
and inflation rates, credit ratings, investor sentiment, and other factors affecting the value of
client accounts. Given the increasing interdependence of global economies and markets,
conditions in one country, market, or region are increasingly likely to adversely affect
markets, issuers, and/or foreign exchange rates in other countries, including the U.S. These
disruptions could prevent The MilWealth Group from executing advantageous investment
decisions in a timely manner and negatively impact The MilWealth Group’s ability to
achieve the investment objectives of its asset allocations. These disruptions could also
prevent The MilWealth Group and its vendors or service providers from maintaining normal
business operations or could result in the loss of services of key personnel on a temporary or
long-term basis due to illness or other reasons. Any such event(s) could have a significant
adverse impact on the value of client accounts and the risk profile of clients’ asset
allocations.
Artificial Intelligence Risk
The MilWealth Group currently utilizes certain Artificial Intelligence (“AI”) programs,
software, and vendors for the purposes of enhancing an employee’s productivity or
efficiency. The MilWealth Group’s Managing Partner oversees the use of AI. Given the
rapidly evolving nature of AI tools, The MilWealth Group may begin using AI for other
purposes in the future. Use of AI can result in enhanced productivity and efficiency,
however use of such technology also leads to additional risk to The MilWealth Group and its
clients. AI tools could potentially rely on outdated, inaccurate, incomplete or biased data
which could create inaccurate output. Use of AI tools creates risk around security, privacy
and confidentiality of data entered into AI tools. Additionally, because of the evolving
nature of AI technology and common uses by businesses in the financial service industry, AI
use could be subject to rapidly evolving regulatory environment which may impact if and
how The MilWealth Group is able to use AI in the future. Finally, The MilWealth Group’s
service providers may utilize AI tools, potentially without The MilWealth Group’s
knowledge, despite efforts to oversee such service providers, leading to additional AI risk
exposure. The MilWealth Group maintains an Artificial Intelligence Policy to govern the use
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of AI which aims to ensure any risks or conflicts of interest associated with such tools are
evaluated and mitigated. The Artificial Intelligence Policy includes provisions for the review
and approval of AI tools prior to their use, a requirement for human oversight of the output of
any AI tool, controls around maintaining the confidentiality of data associated with AI tools
and a requirement that The MilWealth Group employees be appropriately trained on AI use
and related risks.
Item 9
Disciplinary Information
We have no disciplinary events to disclose.
Item 10
Other Financial Industry Activities and Affiliations
We have no other financial industry activities or affiliations.
Item 11
Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
We maintain a Code of Ethics and Personal Trading Policy (the “Code”), which applies to all
employees and principals. As a fiduciary, we have a duty of utmost good faith to act solely in the
best interests of each of our clients. We strive to foster a healthy culture of compliance within all
aspects of our business. Further, we expect our employees to avoid potential conflicts of interest
or even the appearance of such conflicts. These principles represent the expected basis of all
dealings with clients.
Our Code outlines the standards of conduct expected of our employees and includes limitations
on personal trading, giving and accepting gifts, serving as a director or trustee for an external
organization, participating in external investment organizations and engaging in outside business
activities. In addition, employees are prohibited from using nonpublic inside information to trade
in personal accounts or on behalf of our clients.
We require all employees to obtain preapproval for trading certain types of securities. In
addition, our Code requires all employees to report certain transactions quarterly and security
holdings initially upon employment and on an annual basis thereafter.
Employees are permitted to buy and sell securities they also recommend for purchase and sale to
our clients. This may create an incentive for employees to place their own interests ahead of our
clients. To mitigate this risk, our Code requires employees to obtain preapproval for certain types
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Form ADV Part 2A
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of securities and to routinely report personal transactions and holdings. However, due to the
immaterial nature of our employee’s ownership interests in these securities and the size and
nature of the individual securities managed by the employee, we believe our employees’ personal
trading activity has a negligible impact on the value of these securities.
A copy of our Code is available upon request.
Item 12
Brokerage Practices
Selection of Brokers
To efficiently service our clients’ accounts, we have established custodial and brokerage
relationships with two organizations: Schwab and Transamerica. Schwab provides custody
services for the majority of our clients’ assets. Our clients who choose an alternative
custodian may pay additional advisory or custodial fees.
From time to time, a client may hold an annuity, and The MilWealth Group generally
recommends our client hold that annuity through Transamerica (variable annuities). The
choice of the underlying insurance company is determined by Transamerica.
Our determining factors in choosing brokers include but are not limited to: quality of
execution; record-keeping and reporting; servicing capabilities; custody fees; and
transaction costs. Our clients may pay additional trading costs if we place transactions
through a broker not affiliated with the client’s custodian. For this reason, we take into
consideration these additional trading costs when placing trades for client portfolios, and
this consideration typically results in placing trades through the client custodian’s affiliated
broker. In rare instances, we may believe the broker we normally use to execute trades is
not suitable for a specific trade. In such situations, we will attempt to locate a more suitable
broker.
Research & Other Soft Dollar Benefits
We participate in Schwab’s institutional adviser program. There is no direct link between
our participation in the Program and the investment advice we give to our clients, although
we receive economic benefits through our participation in the Program that are typically not
available to Schwab retail investors but are available to all investment advisers who
participate in the Program. We use standard technology and research services provided by
Schwab to service client accounts which includes services related to trade execution,
clearance and settlement functions, trading software and general economic commentary and
analyses. Other 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; electronic document signing software; consulting services; access to a
trading desk serving our clients; access to block trading (which provides the ability to
aggregate securities transactions for execution and then allocate the appropriate shares to
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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 The MilWealth Group by third-party
vendors. Schwab also may provide complementary conference registration fees to The
MilWealth Group. All services provided by Schwab are available to all participating
advisors and may be used to service all of The MilWealth Group’s accounts.
Trade Aggregation
Due to the nature of the securities in which we actively trade (specifically, mutual funds, ETFs
and US Treasury bonds) and the firm’s investment philosophy to consider each client’s needs
and objectives, securities held in client accounts are generally traded on an individual basis.
When we decide it is in our clients’ best interest, we will aggregate (or “block”) ETF trades. This
will generally occur when we buy or sell an ETF across multiple client accounts. If a block order
is filled (full or partial fill) at several prices through multiple trades, an average price will be
calculated for all trades executed by the broker for the block, and all participants in the block
trade will receive the average price. Only trades executed within the block on the single day may
be combined for purposes of calculating the average price. On the rare occasion where the firm
receives a partial fill, the partial fill may be allocated on a pro rata basis, subject to rounding and
reasonable efforts to minimize trading costs.
Trade Errors
It is our policy to ensure clients are made whole following any trade error. When we cause a
trade error to occur in a client account that results in a loss, we will reimburse the client, unless
the executing broker’s policy is to absorb de minimis losses (e.g., under $100). If a trade error
results in a gain, the client shall keep the gain, unless the executing broker’s or other third party’s
(responsible for processing errors) policy is to: a) offset the gain against losses within a certain
number of days; b) retain; or c) donate to charity. We maintain policies and controls surrounding
trade errors, designed to provide reasonable assurance trade errors are properly addressed.
Courtesy Trades
We may, at times, execute trades within the client’s custodial account upon receipt of written or
verbal direction from a client as a courtesy. While we discourage the extensive use of such
“courtesy trades” we provide reports on such assets and include all assets held within the client’s
custodian account (including assets purchased via courtesy trades) within our fee calculation.
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Item 13
Review of Accounts
Nature and Frequency of Reviews
We provide an initial investment review for all of our new clients, and our advisors conduct an
ongoing review at least annually. Significant market events, changes in client circumstances,
requests by our clients, or at the suggestion of a client service professional may trigger an
advisor to review.
Client Reports
All of our clients receive regular account statements from their respective custodians.
Transamerica sends quarterly account statements that provide quarter-end investment balances as
well as details of all account activity during the quarter. Schwab sends monthly account
statements for accounts with qualifying activities of deposits, withdrawals, trades, stock dividend
distributions and reinvestments that provide month-end investment balances as well as details of
all account activity during the month. If a Schwab account does not have qualifying activities,
then Schwab sends quarterly account statements that provide quarter-end investment balances as
well as details of all account activity during the quarter.
We periodically send a communication piece which is primarily an educational tool for clients.
Item 14
Client Referrals and Other Compensation
We receive consulting services and invitations to investor symposiums from sponsors of mutual
funds and ETFs we use in client accounts. We understand these benefits are part of the sponsors’
standard offerings. We do not receive any compensation for utilizing any fund or ETF in a client
portfolio. We may invite clients to attend the symposiums with us. These services provide an
incentive for us to continue to place client assets in these products. We employ a disciplined
investment process which results in utilizing those funds and ETFs we believe are in the best
interest of our clients. Further, we maintain policies and procedures to address such conflicts of
interest.
Financial professionals are compensated with a salary and may receive a discretionary bonus.
Compensation is based on how well they service our clients, individual performance and firm
performance. Owners of the firm share in firm profits.
Any recommendation to manage assets creates some conflicts with your interests as the
recommendation leads to revenue for the firm.
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Item 15
Custody
We do not maintain custody of client assets, except as a consequence of our ability to withdraw
our advisory fee directly from client accounts and our ability to direct transactions to third parties’
contingent upon a signed standing letter of authorization from a client and certain other
requirements being met. We have written authority from these clients to engage in these
transactions and comply with the appropriate regulatory guidance. In addition, all transactions are
fully disclosed on client account statements sent by the qualified custodian. We encourage you to
review these statements carefully. We send statements to clients on an as needed or by request
basis. We also maintain policies and procedures designed to provide reasonable assurance our
client’s qualified custodian is sending monthly and quarterly statements to our clients and that we
do not inadvertently obtain further custody over client assets. We encourage clients to compare
information in our reports to reports provided by the client’s qualified custodian. We have no
affiliated qualified custodians.
Item 16
Investment Discretion
We provide portfolio management services on a discretionary and non-discretionary basis. All
accounts are subject to a written investment advisory agreement which describes investment
authority, fees and other matters.
Item 17
Voting Client Securities
We do not vote proxies on behalf of its clients. We or the custodian send all proxy materials
directly to our clients, who are responsible for voting proxies. Upon our client’s request, we will
provide advice and information to clients to assist you in making a determination of how to vote
a specific proxy. The final decision of how to vote a proxy, however, rests with our client.
Item 18
Financial Information
We have no financial conditions to disclose which would impair our ability to meet our
contractual commitments to our clients.
Other Information
We do not participate in legal proceedings, including class actions, on behalf of our clients.
Our CCO, Matt Miler, serves as Managing Partner and Advisor which could result in competing
priorities. The MilWealth Group maintains policies, procedures and controls to assist in
mitigating this conflict, and does not believe it results in unfair treatment of its clients.
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Form ADV Part 2A
March 25, 2026
Privacy Notice
Our Commitment to You
When you become a client of The MilWealth Group you entrust us with not only your financial
assets but also with personal information about you. We treat this information as confidential and
recognize the importance of protecting access to it.
The Type of Information We Collect About You
In the course of doing business with our clients, we collect nonpublic information about you. You
typically provide personal information when you become a client or when you request a transaction
that involves The MilWealth Group. This nonpublic information may include information
regarding your name and address, social security number, assets, income, account balance, bank
account information, personal tax information and investment activity.
What We Do With Your Personal Information
We do not sell information about our current or former clients to third parties, and we do not
disclose it to third parties unless requested by our client or necessary to process a transaction,
service an account, or as permitted by law. We may share information with companies that
perform administrative services for us. However, our contracts restrict the companies from using
our client information for any other purpose than that for which they have been hired.
How We Safeguard Your Personal Information
To protect your personal information, we maintain physical, electronic and procedural safeguards
to guard your personal information. Our Privacy Policy, which applies to all our employees,
restricts the use of client information and requires that it be held in strict confidence.
We’ll Keep You Informed
If we change our Privacy Policy with regard to disclosing your confidential information, we are
required by law, to notify you and provide you a revised notice.
Should you have any questions regarding our privacy policy, please contact us at 414-475-1369.
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