Description of Services and Fees
We are a registered investment adviser based in Plantation, Florida. We are organized as a sub-
Chapter S corporation under the laws of the State of Florida. We have been providing investment
advisory services since 1989. Todd Battaglia is the principal owner. Currently, we offer the following
investment advisory services, which are personalized to each individual client:
•Financial Planning Services
•Investment Management Services
The following paragraphs describe our services and fees. Please refer to the description of each
investment advisory service listed below for information on how we tailor our advisory services to your
individual needs. As used in this brochure, the words "we," "our" and "us" refer to MG&A Wealth and
the words "you," "your" and "client" refer to you as either a client or prospective client of our firm. Also,
you may see the term Associated Person throughout this Brochure. As used in this Brochure, our
Associated Persons are our firm's officers, employees, and all individuals providing investment advice
on behalf of our firm.
Financial Planning Services
We offer broad-based and one-time consultative financial planning services. Financial planning will
typically involve providing a variety of advisory services to clients regarding the management of their
financial resources based upon an analysis of their individual needs. If you retain our firm for financial
planning services, we will meet with you to gather information about your financial circumstances and
objectives. Once we specify those long-term objectives (both financial and non-financial), we will
develop shorter-term, targeted objectives. Once we review and analyze the information you provide to
our firm, we will deliver a written plan to you, designed to help you achieve your stated financial goals
and objectives.
Financial plans are based on your financial situation at the time we present the plan to you, and on the
financial information you provide to our firm. You must promptly notify our firm if your financial
situation, goals, objectives, or needs change.
You are under no obligation to act on our financial planning recommendations. Should you choose to
act on any of our recommendations, you are not obligated to implement the financial plan through any
of our other investment advisory services. Moreover, you may act on our recommendations by placing
securities transactions with any brokerage firm.
Investment Management Services
We offer non-discretionary and discretionary investment management services as described below.
SEI Program
We may recommend that our clients allocate investment assets among the various mutual fund asset
allocation models, underlying mutual funds, and/or independent investment manager programs offered
through SEI Investments Company ("SEI"). SEI is a global asset management company and sponsor
of its own proprietary mutual funds. SEI Trust Company, a subsidiary of SEI, serves as custodian for
each SEI account, and provides each client with reporting services, including consolidated monthly
statements, quarterly performance reports, and year-end tax reports. SEI enables investment advisers
such as our firm to offer these programs that are not otherwise available to the general public. As part
of its overall investment management program, SEI offers monthly rebalancing of each client's
investment assets for the purpose of maintaining the assets in accordance with the client's previously
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designated percentage (%) asset allocations for the SEI account. Our management services through
SEI is offered on a non-discretionary basis; therefore, your approval must be obtained
before transactions are executed on behalf of your account.
UMA/SMA Program
Through arrangements with third-party service providers, we have access to third-party investment
models, third-party investment managers, mutual funds, exchange traded funds, portfolio maintenance
tools and portfolio trade order processing services as needed to achieve your financial and investment
objectives.
As part of these discretionary management services, we will assist you in selecting a third-party
investment program in which to invest after gathering information about your financial situation and
objectives. Once you have selected an investment program, we will be responsible for the continuous
monitoring and ongoing management of your investment account based on the most recent statement
of investment objectives you have provided us in writing.
We will grant the active discretionary management of all or part of your investment account to one or
more independent investment managers and/or investment management programs ("Independent
Managers") based on your stated investment objectives. Discretionary authorization will permit the
Independent Managers to buy, sell, exchange, convert or otherwise trade in any securities and to
further delegate such discretionary authority to other Independent Managers.
You will have the opportunity to place reasonable restrictions on the management of your account(s),
or modify existing restrictions. You must provide these restrictions and/or modifications to us in writing.
Adviser as Portfolio Manager Program (APM)
Under this program, we will establish various model investment portfolios that consist of exchange
traded funds, mutual funds, individual stocks, or a combination thereof (collectively "securities"). We
will determine the universe of securities and asset allocations included in the model portfolios. Each
model portfolio represents an asset allocation designed to accommodate a different investment
objective. Based upon the written information provided in your statement of investment objectives, we
will determine the suitability of the model portfolio(s) and establish an asset allocation policy. We shall
have discretionary authority to reallocate your portfolio to maintain adherence to the model portfolio(s)
and to change asset allocation policy if deemed necessary to meet your long term objectives. We
retain the absolute authority to and may change the asset allocation and securities in the models. Such
changes in the assets within a given model will generally be effected on a quarterly basis. You agree
and acknowledge that there is no guarantee that following a strategic asset allocation strategy will
produce favorable results.
Private Investments (PI)
Private Investments are generally considered to be a financial asset that does not fall into one of the
conventional investment categories. Conventional categories include stocks, bonds, and cash. Most
private investment assets are held by institutional investors or accredited, high-net-worth individuals
because of their complex nature, lack of regulation, and degree of risk relative to other investments.
PI's include a wide range of investments, including but not limited to, hedge funds, private debt, private
equity, private real estate or venture capital vehicles. PI opportunities generally have minimum dollar
commitments, are generally considered illiquid
and are less regulated than more traditional
investments. PI investments are made pursuant to an offering document which include a subscription
agreement and investor questionnaire. These documents provide greater detail regarding the particular
risks associated with the investment as well as the qualifications for purchase.
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Under this program, we will identify PI opportunities for you, including but not limited to PI opportunities
sponsored our firm or an affiliated entity, and if after we complete our own review and investigation, an
identified PI opportunity is deemed appropriate for you, documents, including an offering document,
subscription agreement and questionnaire will be required for you to participate. If you approve an
allocation of assets to pursue PI opportunities and such assets are placed in a fund sponsored by our
firm, we will have discretion within the fund to allocate in its best judgment in an effort to maximize
returns.
Sub-Advisory Services
With respect to client investments in the UMA/SMA and/or PI programs, we may deem it appropriate
to allocate (and with respect to a PI opportunity, recommend that) a portion of a clients' assets in a
sub-advisory (or private investment fund) relationship with an affiliated entity. While clients will incur
additional fees from investments managed by sub-adviser and third party managers, because we will
receive an additional fee as sub-adviser, we have an incentive to select our affiliated entity to manage
these funds. To ameliorate this conflict, we will utilize our reasonable best efforts to ensure that, to the
extent the particular investment strategy is deemed appropriate for client, if a lower cost option for the
same or substantially similar investment discipline is available from an unaffiliated third party, to charge
client at the lowest cost option available. In the case of a recommendation of a PI, while such
recommendations are non-discretionary, we will utilize our reasonable best efforts to ensure that, to
the extent an unaffiliated third party offers a PI opportunity that is the same or substantially similar to
the PI opportunity offered by our firm at a lower cost than our firm's PI offering, to charge clients at the
lowest cost option available if an investment is selected by the client.
General - Advisory Services to Retirement Plans and Plan Participants
We offer advisory services to employee benefit plans ("Plan") and to the participants of such plans
("Participants"). The services are designed to assist plan sponsors in meeting their management and
fiduciary obligations to Participants under the Employee Retirement Income Securities Act ("ERISA").
Pursuant to adopted regulations of the U.S. Department of Labor, we are required to provide the Plan's
responsible plan fiduciary (the person who has the authority to engage us as an investment adviser to
the Plan) with a written statement of the services we provide to the Plan, the compensation we receive
for providing those services, and our status (which is described below).
The services we provide to your Plan are described in the service agreement that you have previously
signed. Our compensation for these services is described below, at Item 5, and also in the service
agreement. We do not reasonably expect to receive any other compensation, direct or indirect, for the
services we provide to the Plan or Participants, unless the plan sponsor directs us to deduct our fee
from the plan or directs the plan record-keeper to issue payment for our fee out of the plan. If we
receive any other compensation for such services, we will (i) offset the compensation against our
stated fees, and (ii) we will promptly disclose the amount of such compensation, the services rendered
for such compensation and the payer of such compensation to you.
Status
In providing services to the Plan and Participants, our status is that of an investment adviser registered
under the Investment Advisers Act of 1940, and we are not subject to any disqualifications under
Section 411 of ERISA. In performing fiduciary services, we are acting either as a non-discretionary
fiduciary of the Plan as defined in Section 3(21) under ERISA, or as a discretionary fiduciary of the
plan as defined in Section 3(38) under ERISA.
Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's
Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the
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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
•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.
Types of Investments
We primarily recommend mutual funds and exchange traded funds; however, we may also offer advice
on equity securities, warrants, corporate debt securities, certificates of deposit, municipal securities,
U.S. Government securities, and interest in partnerships investing in real estate, oil, and gas interests.
Additionally, we may advise you on any type of investment that we deem appropriate based on your
stated goals and objectives. We may also provide advice on any type of investment held in your
portfolio at the inception of our advisory relationship.
You may request that we refrain from investing in particular securities or certain types of securities.
You must provide these restrictions to our firm in writing.
Assets Under Management
As of December 31, 2023, we provide continuous management services for $683,751,961 in client
assets on a discretionary basis, and $34,760,637 in client assets on a non-discretionary basis. We also
manage $7,851,355 in client assets on a non-continuous basis.