A. Firm Information
MGO One Seven LLC ("OneSeven" or the "Adviser") is a registered investment adviser with the U.S.
Securities and Exchange Commission ("SEC"), which is organized as a Limited Liability Company
("LLC") under the laws of the State of Delaware. OneSeven was originally founded in June 2016 as We
Are One Seven, LLC. On May 4, 2022, we changed our name to MGO One Seven LLC and merged
with a local firm operating under the name MGO Investment Advisors Inc., a registered investment
adviser with the SEC. We are now owned 100% by MGO/OS Holdings, LLC. Our executive officers
are Ronald S. Gross, Chief Executive Officer and Managing Member and Todd M. Resnick, President
and Chief Compliance Officer.
MGO Investment Advisors Inc. ("MGOIA") is no longer a registered investment adviser and all advisory
business is done under our new name of MGO One Seven, LLC. MGOIA has withdrawn its
registration with the SEC.
Certain investment adviser representatives ("IARs") of OneSeven also conduct business under the
names of:
•AIM Wealth Management Group, LLC
•Brittison Financial Group, Inc.
•Callahan Financial
•Carey Dittoe Wealth Management
•Chen Wealth Services, LLC
•ClientFirst Financial Strategies, Inc.
•Community Financial Advisors Inc.
•Everglades Parkland Advisors, Inc.
•Feldmeyer Financial Group
•Hope Financial Group, LLC
•Hyperion Wealth Group
•Ironclad Wealth Management, LLC
•JP Investments, LLC
•JRP Capital
•JTM Williams Capital Management
•Lake House Private Wealth Management, Inc.
•Life Transitions Planning, LLC
•Magnetic North Financial
•MB Wealth Management Group, LLC (also referred to as "MB Group" and "Mawby Brigeman
Wealth Management Group")
•MGO Investment Advisors, Inc. (also referred to as "MGO")
•One Seven
•Paceline Advisors
•Palm Coast Wealth Management
•Pondera Wealth
•Park City Wealth Advisors
•Pillar Wealth Group, LLC
•Romero Wealth Management
•Rosehaven Family Office
•S3 Retirement Planning
•Steadfast Wealth Strategies
•Stratos Investments Of OneSeven
•Structure Wealth Management, LLC
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•Studemont Group of One Seven
•Stone Creek Advisors, LLC
•The Fulshear Wealth Management Group
•WealthCreate Financial
The Adviser serves as a fiduciary to clients, as defined under applicable laws and regulations. As a
fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks
to mitigate potential conflicts of interest. Our fiduciary commitment is further described in our Code of
Ethics. For more information regarding our Code of Ethics, please see Item 11 Code of Ethics,
Participation or Interest in Client Transactions and Personal Trading.
This Disclosure Brochure provides information regarding the qualifications, business practices, and the
advisory services provided by OneSeven. You may contact Todd M. Resnick, the Adviser's Chief
Compliance Officer ("CCO"). Mr. Resnick can be reached at (216) 771-4242 with questions relating to
this Disclosure Brochure.
B. Advisory Services Offered
OneSeven offers investment advisory services to individuals, high net worth individuals, trusts, estates,
businesses, retirement plans and other types of investors (each referred to as a "Client"). The services
described in this Brochure are former One Seven programs and services. Services formerly offered by
MGO are described in a separate Brochure.
Investment Management Services
OneSeven primarily provides discretionary investment management services to its Clients. Based on
the needs of each Client, the Adviser will develop a portfolio that is primarily constructed with
diversified mutual funds, exchange-traded funds ("ETFs"), individual stocks and/or individual fixed
income securities (bonds). The Adviser will also utilize other types of investments, as necessary, to
meet the needs of a particular client, including but not limited to REITS, options, structured products,
private equity, variable annuities and variable insurance.
OneSeven's investment strategy is primarily long-term focused, but the Adviser may buy, sell or re-
allocate positions that have been held less than one year to meet the objectives of the Client or due to
market conditions. OneSeven will construct, implement and monitor the portfolio to ensure it meets the
goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the
opportunity to place reasonable restrictions (in writing) on the types of investments to be held in their
respective portfolio, subject to acceptance by the Adviser.
OneSeven evaluates and selects investments for inclusion in client portfolios only after applying its
internal due diligence process. OneSeven recommends, on occasion, redistributing investment
allocations to diversify the portfolio. OneSeven as deemed appropriate, recommends specific
positions to increase sector or asset class weightings and recommends employing cash positions as a
possible hedge against market movement. OneSeven, as deemed appropriate, recommend selling
positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or
sector risk exposure to a specific security or class of securities, over-valuation or over-weighting of the
positions in the portfolio, a change in risk tolerance of Client, generating cash to meet Client needs, or
any risk deemed unacceptable for the Client's risk tolerance.
Our discretionary authority allows us to invest and reinvest the assets in your Accounts, potentially
including the engagement, retention and replacement of third-party portfolio managers without your
prior approval. You may limit our discretionary authority (for example, limiting the types of securities
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that can be purchased or sold for your account) by providing our firm with your reasonable restrictions
and guidelines in writing. We have the option of refusing your restrictions if they are deemed too
restrictive to manage your account(s) effectively.
We also offer non-discretionary portfolio management services. When you enter into non-discretionary
arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf
of your account. You have an unrestricted right to decline to implement any advice provided by our firm
on a non-discretionary basis.
OneSeven provides investment management and related advisory services. OneSeven generally does
not accept or maintain custody of a Client's funds or securities. Client assets will be managed within
their designated account[s] at the third-party Custodian, pursuant to the Client's investment advisory
agreement. For additional information, please see Item 12 Brokerage Practices and Item 15 Custody.
Use of Independent Managers
OneSeven, as deemed appropriate, recommends that all or a portion of their investment portfolio be
implemented by utilizing one or more unaffiliated money managers or investment platforms
(collectively "Independent Managers"). Independent Managers are sourced directly or accessed
through an investment management platform. OneSeven serves as the Client's primary Adviser and
relationship manager. However, the Independent Manager will assume discretionary authority for the
day-to-day investment management of those assets placed in their control. OneSeven will assist and
advise the Client in establishing investment objectives for their account(s), the selection of the
Independent Manager, and defining any restrictions imposed on the account(s). OneSeven will
continue to provide oversight of the Client's account(s) and ongoing monitoring of the activities of these
unaffiliated parties.
The Independent Manager will implement the selected investment strategies based on their investment
mandates. The Client is sometimes able to impose reasonable investment restrictions on these
accounts, subject to the acceptance of these third parties.
The Client, prior to entering into an agreement with an Independent Manager, will be provided with the
Form ADV Part 2A (or a brochure that makes the appropriate disclosures) of the Independent
Manager. OneSeven does not receive any compensation from these Independent Managers or
Investment Platforms, other than OneSeven's investment advisory fee (described in Item 5).
The Independent Managers also charge their own advisory fees as disclosed in their Form ADV
Part 2A.
SMArtX TAMP
We have entered into a contractual relationship with SMArtX Advisory Solutions, LLC ("SMArtX"),
which provides us access to the platform through which SMArtX offers its advisory services. Through
the SMArtX platform, we can establish and manage a unified managed account ("UMA"). SMArtX
provides access to investment strategies or models (each a "Model") through the Platforms. Each
Model is provided by either SMArtX, a traditional asset manager, a hedge fund or alternative
investment manager, OneSeven, or an index provider (each a "Model Manager"). A Model Manager
provides SMArtX with securities and weights and transactional history associated with the Model in
order for SMArtX to create and maintain the Model Portfolio. Model Managers often provide additional
content, including but not limited to commentaries on the Model and the underlying investment
strategy, general commentaries on the markets and the economy, historical performance, biographical
information on relevant members of the Model Manager's team, and descriptions of the investment
strategy or strategies utilized in the Model.
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We review the information available and direct SMArtX to implement one or more Models in the UMA.
When we select a Model for a UMA, we will provide SMArtX with the amount of funds, either in terms
of dollars or as a percent of the account's value, in the UMA to be invested in the Model. When we
invest in a Model on SMArtX, SMArtX will implement the positions and trading activity of the Model in
proportion to the amount of assets invested. The SMArtX platform will rebalance positions inside the
sleeves automatically based on the drift parameters to bring the UMA in balance with the selected
Model(s). SMArtX does not automatically rebalance the sleeves. We are responsible for determining
whether any Model or any combination of Models are appropriate and suitable for the UMA account
holder. We consider the financial situation, investment goals and objectives, time horizon, liquidity, and
risk tolerance ("Investment Considerations") of the UMA account holder to determine if the select
Model(s) are appropriate. We are responsible for reviewing any changes to the Investment
Considerations of the UMA account holder and making appropriate changes to the selected Model.
We may choose to direct SMArtX to buy or sell individual securities in the UMA directly rather than
through a Model. This functionality is called Advisor as a Portfolio Manager ("APM") and allows us to
direct a portion of the UMA's assets rather than opening a separate account with a custodian. We may
choose to buy or sell stocks, ETFs, or mutual funds. Clients may provide us instructions to restrict the
purchase or sale of certain securities from the UMA. Clients can provide instructions to harvest taxable
gains or losses in the UMA. We may add or decrease leverage for any selected Model, provided that
SMArtX will limit the leverage utilized to the UMA's specified account configuration. Certain Models
may inherently apply leverage. When a Model invests in a security or other asset that does not fit with
a UMA's account configuration, SMArtX will exclude that investment from the UMA. Customizations
that are specific to a UMA may cause material performance differences
between the selected Model
and the UMA.
SMArtX maintains a limited power of attorney to direct trading of each UMA ("Trading Discretion") in
order to purchase and sell securities in the UMA's selected custodian. Trading Discretion is either
granted to SMArtX through a Sub-Advisory or Co-Advisory Agreement with OneSeven ("Adviser Sub-
Advisory Agreement"). We may choose to terminate the relationship with SMArtX and revoke the
Trading Discretion of SMArtX at any time.
Managed Assets "Held Away" from our Recommended Custodians
We use a third-party platform to facilitate discretionary management of held away assets such as
defined contribution plan participant accounts, 401(k) accounts, and HSAs. These accounts are agreed
upon between the Client and the IAR and will be managed along with your other managed account(s).
The Pontera platform ("Pontera") allows us to trade in these accounts for our clients without direct
access to the accounts, since in most cases the accounts cannot be held at our recommended
custodian. We do not have your log-in credentials. The Pontera platform is not affiliated with
OneSeven in any way and we receive no compensation from them for using their platform.
A link will be provided to the Client allowing them to connect the applicable account(s) to the platform.
Once Client account(s) are connected to the platform, Adviser will review the current account
allocations. When deemed necessary, Adviser will rebalance the account considering client investment
goals and risk tolerance, and will consider current economic and market trends. Client account(s) will
be reviewed at least quarterly and allocation changes will be made as deemed necessary.
We do charge an advisory fee for these assets so even though we do not receive compensation
directly from Pontera, we do earn fees on these assets that we would not normally earn. This is
considered a conflict of interest because we may recommend management of these accounts to
increase our advisory fees and not because it is in the client's best interest. We strive to only make
recommendations that are in our clients' best interests at all times.
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These accounts are included in the investment advisory fee listed on your client agreement and are
billed in the same manner as other accounts you may have with OneSeven.
Financial Planning Services
OneSeven will typically provide a variety of financial planning and consulting services to Clients,
pursuant to a written financial planning agreement. Services are offered in several areas of a Client's
financial situation, depending on their goals, objectives and financial situation.
Generally, such financial planning services will involve preparing a financial plan or rendering a
financial consultation based on the Client's financial goals and objectives. This planning or consulting
may encompass one or more areas of need, including, but not limited to investment planning,
retirement planning, personal savings, insurance needs, education savings and other areas of a
Client's financial situation.
A financial plan developed for or financial consultation rendered to the Client will usually include
general recommendations for a course of activity or specific actions to be taken by the Client. For
example, recommendations may be made that the Client start or revise their investment programs,
commence or alter retirement savings, establish education savings and/or charitable giving programs.
OneSeven may also refer Clients to an accountant, attorney or other specialist, as appropriate for their
unique situation. For certain financial planning engagements, the IAR will provide a written summary of
the Client's financial situation, observations, and recommendations. For consulting or ad-hoc
engagements, the IAR will not always provide a written summary in all situations. Plans or
consultations are typically completed within six months of contract date, assuming all information and
documents requested are provided promptly.
Financial planning and consulting recommendations may pose a potential conflict between the
interests of the Adviser and the interests of the Client. For example, a recommendation to engage the
Adviser for investment management services or to increase the level of investment assets with the
Adviser would pose a conflict, as it would increase the advisory fees paid to the Adviser. Clients are
not obligated to implement any recommendations made by the IAR in the financial plan or maintain an
ongoing relationship with the IAR. If the Client elects to act on any of the recommendations made by
the IAR, the Client is under no obligation to implement the transaction through the IAR.
Consulting Services
OneSeven provides Financial Consulting Services. Fees for our Financial Consulting Services are
negotiated on a case by case basis depending on the time and complexity of the service and are
outlined in your financial planning/consulting agreement.
Educational Seminars and Speaking Engagements
OneSeven provides educational seminars for a fee. Details are outlined in your educational
engagement agreement.
Leverage
When requested by clients, OneSeven assists clients in working with outside institutions to obtain
loans through pledged borrowing. We do not get paid directly for this service. However, the leverage
allows accounts for which we provide investment advisory services to retain a larger balance than if
assets were withdrawn to pay directly for the goods and services the loan is used for. This presents a
conflict of interest as we get paid for assets under management and have an incentive to recommend
the use of pledged borrowing in place of withdrawal of assets. See Item 8 for leverage risk.
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Private Placements or Private Equity
A securities offering exempt from registration with the SEC is sometimes referred to as a private
placement or an unregistered offering. Under the federal securities laws, a company may not offer or
sell securities unless the offering has been registered with the SEC or an exemption from registration
is available.
Private placements are used to raise funds from investors and have fewer disclosure obligations than
other investments you may be familiar with. Because they are illiquid investments and may be difficult
or impossible to re-sell, you should be comfortable holding the investment indefinitely. You should also
ask your IAR questions such as:
•Are the claims and expectations reasonable?
•Who are the issuer's competitors?
•What is the experience and background of management?
•How does the issuer plan to use the money raised?
Clients that meet the definition of accredited investor and other suitability requirements of the selected
private placement may have the opportunity to purchase a private placement through OneSeven. The
firm offering the private placement will receive a placement fee, along with marketing and due diligence
fees, and OneSeven will charge an advisory fee in lieu of the selling commission. Private placements
are exempt from registration pursuant to Rule 506(D) of Regulation D of the Securities Act of 1933.
Private placements are illiquid and lack marketability. Private placements are long-term investments
and not intended for trading or short-term ownership.
Accredited investors are defined by the SEC and a variety of individuals and institutions may be able to
meet the definition. The typical accredited investor working with OneSeven meets one of the following:
•An individual with a net worth or joint net worth with a spouse (or spousal equivalent) of at least
$1 million, not including the value of your primary residence, or
•An individual with income of at least $200,000 in each of the two most recent calendar years or
joint income with a spouse (or spousal equivalent) of at least $300,000 in each of the two most
recent calendar years and a reasonable expectation of an equivalent income in the coming
year.
IRA Rollover Recommendations
For purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02")
where applicable, we are providing the following acknowledgment to you. When we provide
investment advice to you regarding your retirement plan account or individual retirement account, we
are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the
Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we
make money creates some conflicts with your interests, so we operate under a special rule that
requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's
provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent
advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
•Charge no more than is reasonable for our services; and
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•Give you basic information about conflicts of interest.
We benefit financially from the rollover of your assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our assets under management
and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in
your best interest.
C. Client Account Management
Prior to engaging OneSeven to provide investment advisory services, each Client is required to enter
into one or more agreements with the Adviser that define the terms, conditions, authority and
responsibilities of the Adviser and the Client. Services we offer include:
•Establishing Investment Strategy – OneSeven, in connection with the Client, develops a
strategy designed to work toward the Client's investment goals and objectives.
•Asset Allocation – OneSeven develops a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and risk tolerance for each Client.
•Portfolio Construction – OneSeven develops a portfolio for the Client that is intended to work
toward the stated goals and objectives of the Client.
•Investment Management and Supervision – OneSeven provides investment management and
ongoing oversight of the Client's investment portfolio.
Since our investment strategies and advice are based on each Client's specific financial situation, the
investment advice IARs provide to you may be different or conflicting with the advice other IARs give to
their Clients regarding the same security or investment.
D. Wrap Fee Programs
For some Clients, OneSeven includes the securities transaction fees together with investment advisory
fees to provide the Client with a single, bundled fee structure. This combination of fees is typically
referred to as a "Wrap Fee Program." OneSeven customizes its investment management services for
its clients. This Wrap Fee Program is described in the Form ADV, Part 2A, Appendix 1 (Wrap Fee
Program Brochure) to this Disclosure Brochure. OneSeven may also recommend the implementation
of investment management through unaffiliated third-party money managers and investment portfolios,
which may deliver services through a wrap fee structure. Please see Form ADV, Part 2A, Appendix 1.
E. Assets Under Management
As of December 31, 2023, we provide continuous management services for $2,571,181,892 in client
assets. $2,545,977,875 in assets are managed on a discretionary basis while $25,204,017 in assets
are managed on a non-discretionary basis.