MBM offers a variety of advisory services, which include financial planning, consulting, and investment
management services.
Prior to the rendering of any of the foregoing advisory services, clients are required to enter into one or more written
agreements with MBM setting forth the relevant terms and conditions of the advisory relationship (the
“Agreement”).
MBM has been an independent registered investment adviser since November 2013, originally registered with the
State of Missouri, and as of April 2018, MBM transitioned from State registration to SEC registration. As of
December 31, 2023, MBM had $334,977,061 of assets under management, all of which were managed on a
discretionary basis. MBM is wholly owned by MBM Wealth Group, LLC.
While this brochure generally describes the business of MBM, certain sections also discuss the activities of its
Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar
status or performing similar functions), employees (including -independent contractors), or any other person who
provides investment advice on MBM’s behalf and is subject to the Firm’s supervision or control.
Financial Planning and Consulting Services
MBM offers clients a range of financial planning and consulting services, which may include, but are not limited to
the following services:
• Business Planning
• Cash Flow Forecasting
• Asset Allocation
• Retirement Planning
• Estate Planning
• Financial Reporting
• Distribution Planning
• Investment Consulting
• Insurance Needs Analysis
In performing these services, MBM is not required to verify any information received from the client or from the
client’s other professionals (e.g., attorneys, accountants, etc.) and is expressly authorized to rely on such
information.
MBM may recommend the services of itself, its Supervised Persons in their individual capacities as insurance
agents or registered representatives of a broker-dealer and other professionals to implement its recommendations.
Clients are advised that a conflict of interest exists if clients engage MBM to provide additional fee-based services.
Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act
upon any of the recommendations made by MBM under a financial planning or consulting engagement or to engage
the services of any such recommended professionals, including MBM itself. Clients are advised that it remains their
responsibility to promptly notify MBM of any changes in their financial situation or investment objectives for the
purpose of reviewing, evaluating, or revising MBM’s previous recommendations and/or services.
• Retirement Plan Analysis
• Charitable Giving
• Trust Consulting & Trustee Services
• Risk Management
• Social Security Planning
• Tax Planning and Coordination
• Education Funding Strategies & Coordination
• Retirement Plan Investment Consulting - 3(21)
• Retirement Plan Investment Management - 3(38)
•
Investment Management Services
MBM manages client investment portfolios on a discretionary or a non-discretionary basis.
The Firm primarily allocates client assets among individual debt and equity securities, options, and exchange-traded
funds (“ETFs”), in accordance with the investment objectives of its individual clients. On a more limited basis, the
Firm allocates client assets among mutual funds and various independent investment managers (“Independent
Managers”). In addition, MBM may also recommend that clients who qualify as accredited investors, as defined by
Rule 501 of the Securities Act of 1933, invest in privately placed securities, which may include debt, equity and/or
interests in pooled investment vehicles (e.g., hedge funds).
Clients may also engage MBM to advise on investment products that are not maintained at their primary custodian,
such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and
qualified tuition plans (i.e., 529 plans). In these situations, MBM directs or recommends the allocation of client
assets among the various investment options available for the product type. These assets are generally maintained
at the underwriting insurance company, or the custodian designated by the product provider. Where appropriate,
MBM may also provide advice about any type of legacy positions or other investments held in client portfolios.
MBM tailors its advisory services to meet the needs of its individual clients and continuously seeks to ensure that
client portfolios are managed in a manner consistent with their specific investment profiles. MBM consults with
clients on an initial and ongoing basis to determine their specific risk tolerance, time horizon, liquidity constraints
and other qualitative factors relevant
to the management of their portfolios. Clients are advised to promptly notify
MBM if there are changes in their financial situation or if they wish to place any limitations on the management of
their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if
MBM determines, in its sole discretion, the conditions would not materially impact the performance of a
management strategy or prove overly burdensome to the Firm’s management efforts.
Retirement Plan Consulting Services
MBM offers discretionary investment management services to qualified retirement plan clients under Section 3(38)
of the Employee Retirement Income Security Act (“ERISA”). MBM develops an Investment Policy Statement (“IPS”)
to be approved by the plan fiduciaries; the IPS outlines how MBM will select, monitor, and replace the assets in the
plan. MBM is solely responsible for determining the appropriate investment options available to plan participants
and/or the plan, as applicable. MBM works with the plan’s third-party administrator and qualified custodian to
ensure the selected investment options are available within the plan. MBM is responsible for the ongoing
monitoring of investment options and implementing changes as necessary. Consent of the plan for investment
option changes is not required. MBM will continue to work with the plan fiduciaries to monitor plan investments,
provide fiduciary plan advice, including regular considerations of the goals and objectives of the plan, and provide
participant education services to the plan.
Use of Independent Managers
As mentioned above, MBM may select or recommend certain Independent Managers to actively manage a portion
of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager are
set forth in a separate written agreement between the designated Independent Manager and either MBM or the
client. In addition to this brochure, clients also receive the written disclosure documents of the designated
Independent Managers engaged to manage their assets.
MBM evaluates various information about the Independent Managers it chooses to manage client portfolios, which
may include the Independent Managers’ public disclosure documents, materials supplied by the Independent
Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks
to assess the Independent Managers’ investment strategies, past performance, and risk results in relation to its
clients’ individual portfolio allocations and risk exposure. MBM also takes into consideration each Independent
Manager’s management style, returns, reputation, financial strength, reporting, pricing, and research capabilities,
among other factors.
MBM continues to provide services relative to the discretionary or non-discretionary selection of the Independent
Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by
Independent Managers. MBM seeks to ensure the Independent Managers’ strategies and target allocations remain
aligned with its clients’ investment objectives and overall best interests.
IRA Rollover Recommendations
In complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02"), when applicable, MBM is
providing the following acknowledgment to clients. When MBM provides investment advice to clients regarding
their retirement plan account or individual retirement account, MBM is a fiduciary 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 MBM makes money creates some conflicts with the clients’ interests, so
MBM operates under an exemption that requires MBM to act in the clients’ best interest and not put MBM’s interests
ahead of the clients. Under this exemption, MBM must:
• Meet a professional standard of care when making investment recommendations (give prudent advice),
• Never put MBM’s financial interests ahead of the clients when making recommendations (give loyal
advice),
• Avoid misleading statements about conflicts of interest, fees, and investments,
• Follow policies and procedures designed to ensure that MBM gives advice that is in the clients’ best
interest,
• Charge no more than is reasonable for MBM’s services, and
• Give the clients basic information about conflicts of interest.
MBM benefits financially from the rollover of the clients’ assets from a retirement account to an account that MBM
manages or provides investment advice, because the assets increase MBM’s assets under management and, in
turn, MBM’s advisory fees. As a fiduciary, MBM only recommends a rollover when MBM believes it is in the clients’
best interest.