A. Firm Information
The Main Street Group was formed as a corporation in 2005 by Steven G. Crawford, the current Chief Executive
Officer. In 2015, The Main Street Group was registered as an investment adviser in Virginia, Maryland, North
Carolina, New York and Texas (conditional restricted). In 2018, the firm registered with the Securities and
Exchange Commission (SEC).
• Charles Schwab Investment Advisory, Inc. (“Schwab”) and National Financial Services LLC
(NFS) serve as the qualified custodians for advisory assets.
• Investment advisor representatives of The Main Street Group offer securities through Kestra
Financial, Inc. | CRD No. 42046 in their individual capacity as registered representatives.
Advisor representatives are restricted to providing services and charging fees based in accordance with the
descriptions detailed in this document and the account agreement. However, the exact service and fees
charged to a particular client are dependent upon the representative that is working with the client. Advisors
are instructed to consider the individual needs of each client when recommending an advisory platform.
Investment strategies and recommendations are tailored to the individual needs of each client.
B. Management Team
Steven G. Crawford, Chief Executive Officer, Chief Compliance Officer, Partner
Steve has been in the financial services industry for over 35 years. He has numerous professional
designations1, including Chartered Life Underwriter (CLU), Chartered Financial Consultant (ChFC), Life
Underwriter Training Council Fellow (LUTCF) Certified Funds Specialist (CFS), Accredited Estate Planner
(AEP), Professional Plan Consultant (PCP). Steve also holds his Bachelor of Arts, cum laude, Lynchburg
College, CERTIFIED FINANCIAL PLANNER™ designation from the College for Financial Planning,
Chartered Life Underwriter designation from the American College, Chartered Financial Consultant
designation from the American College, and Certified Divorce Financial Analyst (CDFA).
Tom Love, Senior Vice President, Partner
Tom began his wealth management career in 2007 with Ameriprise Financial. He came to The Main Street
Group in order to provide more objective advice to his clients. He has a passion for investing and enjoys
sharing that passion with his clients. Tom is a CERTIFIED FINANCIAL PLANNER™, Chartered
Retirement Planning Counselor™, and Chartered Retirement Plans Specialist™. Tom uses Charles Schwab
Co., Inc. to custody assets. Tom is a deacon at Hope Church, and loves volunteering with his wife Emily. He
is a faithful volunteer, sponsor, and regional advisory council member for Comfort Zone Camp. He donates
his time as a financial counselor for Junior Achievement, volunteers with The Becky Love Foundation, which
1 The achievement of any professional designation, certification, degree or license, recognition by publications, media or other
organizations memberships in any professional organization or any amount of prior experience or success should not be construed by a
client or prospective cline as a guarantee that he/she will experience a certain level of results or satisfaction if The Main Street Group is
engaged or continues to be engaged to provide investment advisory services.
helps sponsor bereavement camps, and The Cameron K Gallagher Foundation, making presentations on
mental health to high school and middle school students. A SmartVestor Pro, Tom teaches Financial Peace
University classes – a program from Dave Ramsey. Tom is the third of six children. He loves to spend time
with family, volunteering, learning, and sports. Tom and Emily are the loving parents of two daughters, Emma
and Lydia and son Timothy.
C. Advisory Services Offered
The Main Street Group provides fee-based investment advisory services for compensation primarily to
individual clients and high-net worth individuals based on the individual goals, objectives, time horizon, and
risk tolerance of each client. Portfolio management services include, but are not limited to, the following:
Investment Strategy Personal Investment Policy
Asset Allocation Asset Selection
Risk Tolerance
Regular Portfolio Monitoring
Asset Management Services
The Main Street Group provides customized investment advisory solutions for its Clients. This is achieved
through continuous personal Client contact and interaction while providing discretionary investment
management and related advisory services.
The Main Street Group works closely with each Client to identify their investment goals and objectives as
well as risk tolerance and financial situation in order to create a portfolio strategy. The Main Street Group will
then construct a portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds
(“ETFs”) as well as equities to achieve the client’s investment goals. The Advisor may also utilize individual
stocks, bonds or options contracts to meet the needs of its Clients.
The Advisor may retain certain types of investments based on a Client’s legacy portfolio construction. The
Main Street Group’s investment strategy[ies] is primarily long-term focused, but they 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. The Main Street Group 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 on the types of investments to be held in their respective portfolio,
subject to acceptance.
The Main Street Group evaluates and selects investments for inclusion in each client portfolio only after
applying its internal due diligence process. The Main Street Group may recommend, on occasion,
redistributing investment allocations to diversify the portfolio. The Main Street Group may recommend
specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash
positions as a possible hedge against market movement. The Main Street Group may 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, overvaluation or overweighting of the position[s] in
the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed
unacceptable for the Client.
If the appropriate disclosure statement was not delivered to the client at least 48 hours prior to the client
entering into any written or oral advisory contract with this investment adviser, then the client has the right to
terminate the contract without penalty within five business days after entering into the contract. For the
purposes of this provision, a contract is considered entered into when all parties to the contract have signed the
contract, or, in the case of an oral contract, otherwise signified their acceptance, any other provisions of this
contract notwithstanding.
• Under certain circumstances, The Main Street Group may be considered to have custody of Client’s
funds or securities. Please see Item 15 for more information.
Automated Investment Platform
The Main Street Group offers portfolio management services through Institutional Intelligent Portfolios™, an
automated, online investment management platform for use by independent investment advisors and
sponsored by Schwab Wealth Investment Advisory, Inc. (the “program” and "SWIA," respectively). Through
the Program, we offer clients a range of investment strategies we have constructed and manage, each
consisting of a portfolio of exchange traded funds ("ETFs") and a cash allocation. The client may instruct us to
exclude up to three ETFs from their portfolio. The client's portfolio is held in a brokerage account opened by
the client at SWIA's[ affiliate, Charles Schwab & Co., Inc. ("CS&Co"). We are independent of and not owned
by, affiliated with, or sponsored or supervised by SWIA, CS&Co or their affiliates (together, "Schwab").The
Main Street Group (not Schwab) is the client's investment advisor and primary point of contact with respect to
the Program.
• The Main Street Group (not Schwab), is solely responsible for determining the appropriateness of
the Program, choosing a suitable investment strategy and portfolio for the client's investment needs
and goals, and managing that portfolio on an ongoing basis. SWIA's role is limited to delivering
the Program Disclosure Brochure to clients and administering the Program so that it operates as
described in the Program Disclosure Brochure.
We have contracted with SWIA to provide us with the technology platform and related trading and account
management services for the Program. This platform enables us to make the Program available to clients
online and includes a system that automates certain key parts of our investment process (the "System"). The
System includes an online questionnaire that helps The Main Street Group determine the client's investment
objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note
that we will recommend a portfolio via the System in response to the client's answers to the online
questionnaire. The client may then indicate an interest in a portfolio that is one level less or more conservative
or aggressive than the recommended portfolio, but we then make the final decision and select a portfolio based
on all the information we have about the client. The System also includes an automated investment engine
through which we manage the client's portfolio on an ongoing basis through automatic rebalancing and tax-
loss harvesting (if the client is eligible and elects).
Retirement Plan Rollovers
An employee generally has four (4) options for their retirement plan when they leave an employer:
1. Leave the money in his/her former employer’s plan, if permitted
2. Rollover the assets to his/her new employer’s plan if one is available and permitted
3. Rollover to an Individual Retirement Account (IRA), or
4. Cash out the account value, which has significant tax considerations
Each of these options has advantages and disadvantages and before making a change we encourage you to
speak with your CPA and/or tax attorney. If you are considering rolling over your retirement funds to an IRA
for us to manage here are a few points to consider before you do so:
• Determine whether the investment options in your employer's retirement plan address your needs
or whether you might want to consider other types of investments.
• Employer retirement plans generally have a more limited investment menu than IRAs.
• Employer retirement plans may have unique investment options not available to the public such as
employer securities, or previously closed funds.
• Your current plan may have lower fees than our fees.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based
fee as set forth in the agreement you executed with our firm. This practice presents a conflict of interest
because Investment Advisor Representatives have an incentive to recommend a rollover to you for the
purpose of generating fee-based compensation rather than solely based on your needs. You are under no
obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover,
you are under no obligation to have the assets in an IRA managed by our firm.
Many employers permit former employees to keep their retirement assets in their company plan. Also, current
employees can sometimes move assets out of their company plan before they retire or change jobs. In
determining whether to complete the rollover to an IRA, and to the extent the following options are available,
you should consider the costs and benefits of each. An employee will typically be investing only in mutual
funds, you should understand the cost structure of the share classes, available in your employer's retirement
plan and how the costs of those share classes compare with those available in an IRA. Clients should
understand the various products and services they might take advantage of at an IRA provider and the
potential costs of those products and services.
• Our strategy may have higher risk than the option(s) provided to you in your plan.
• Your current plan may also offer financial advice.
• If you keep your assets titled in a 401k or retirement account, participants could potentially delay their
required minimum distribution beyond age.
• A 401(k) may offer more liability protection than a rollover IRA; each state may vary.
• Participants may be able to take out a loan on your 401k, but not from an IRA.
• IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may
also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability,
higher education expenses or the purchase of a home.
• If company stock is owned in a plan, participants may be able to liquidate those shares at a lower capital
gains tax rate.
• Plans may allow Advisor to be hired as the manager and keep the assets titled in the plan name.
Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been
generally protected from creditors in bankruptcies. However, there can be some exceptions to the general
rules so you should consult with an attorney if you are concerned about protecting your retirement plan assets
from creditors.
It is important to understand the differences between these types of accounts and to decide whether a rollover
is the best option. Prior to proceeding, if you have questions contact your Investment Adviser Representative,
or call our main number as listed on the cover page of this brochure.
When The Main Street Group provides 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.
The Main Street Group also provides educational services to retirement plan participants with assets that could
potentially be rolled-over to an IRA advisory account. Education is based on a particular Client’s financial
circumstances and best interests. Again, Advisor has an incentive to recommend such a rollover based on the
compensation received, which is mitigated by the fiduciary duty to act in a Client’s best interest and acting
accordingly.
Financial Planning Services
As part of our financial planning services, The Main Street Group, through its investment advisor
representatives, may provide personal financial planning tailored to the individual needs of the client. A
particular client’s financial plan will include the relevant types of planning specific to their needs and
objectives such as:
• Retirement – Planning an investment strategy and reviewing current plans, including 401K plans,
to provide inflation-adjusted income for life.
• College / Education – Planning to pay the future college / education expenses of a child or
grandchild.
• Major Purchase – Evaluating the pros and cons of home ownership verses renting, as well as
buying or leasing a car, for example.
• Divorce – Planning for the financial impact of divorce such as change in income, retirement
benefits and tax considerations. Providing alternatives to collaborative divorce attorneys to
reapportion joint assets
• Insurance Needs – Planning for the financial needs of survivors to satisfy such financial
obligations as housing, dependent childcare, spousal arrangements and education.
• Final Expenses – Planning to leave assets to cover final expenses such as funeral, debts and
potential business continuity. Assisting executors and trustees with the probate and estate
settlement process.
• Estate Planning – Focusing on the most efficient and tax friendly option to pass on an estate to a
spouse, other family members or a charity.
• Cash Flow/ Budget Planning – Managing expenses against current and projected income.
• Wealth Accumulation – Planning to build wealth within a portfolio that takes into consideration
risk tolerance and time horizon.
• Business Succession – Planning for the continuation of a business in as smooth a transition as
possible with the use of buy-sell agreements, key-person insurance, engaging independent legal
counsel as needed.
• Tax Planning – Planning a tax-efficient investment portfolio to maximize deductions and offsetting
losses.
• Investment Planning – Planning an investment strategy consistent with particular objectives, time
horizons and risk tolerances.
• Age Wave Planning – Assisting with the design of long-term care plans, providing an educational
resource for caregivers and assisting with downsizing, senior living arrangements, LTC insurance
claims and other age-appropriate planning.
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 should also be aware that our financial plans may contain
certain assumptions with respect to interest and inflation rates, along with past trends and performance of the
market and economy. Past performance is in no way an indication of future performance. You must promptly
notify our firm if your financial situation, goals, objectives, or needs change. The services take into account
information collected from the client such as financial status, investment objectives and tax status, among
other data. Fees for such services are negotiable and detailed in the client agreement.
The financial plan may include generic recommendations as to general types of investment products or
specific securities
which may be appropriate for the Client to purchase given his/her financial situation and
objectives. The Client is under no obligation to act upon the investment adviser’s recommendation or purchase
such securities through The Main Street Group and the IAR. However, if the Client desires to purchase
securities or advisory services in order to implement his/her financial plan, The Main Street Group may make
a variety of products and services available through its IARs. This may result in the payment of normal and
customary commissions, advisory fees or other types of compensation to The Main Street Group and the IAR.
The Main Street Group may refer Clients to an accountant, attorney or other specialists, as appropriate for
their unique situation. For certain financial planning engagements, the Advisor will provide a written
summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc
engagements, the Advisor may or may not provide a written summary. 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 conflict between the interests of the Advisor
and the interests of the Client. For example, a recommendation to engage the Advisor for investment
management services or to increase the level of investment assets with the Advisor would pose a conflict, as it
would potentially increase the advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or to maintain an ongoing relationship with the Advisor. If the Client
elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to effect
the transaction through the Advisor.
Hourly Consulting Services
The Main Street Group, through its investment advisor representatives, may provide consulting services
including, as selected by the client in the consulting agreement, advice regarding tax planning, investment
planning, retirement planning, estate planning, cash flow/budget planning, business planning, education
planning, and personal financial planning. The services take into account information collected from the client
such as financial status, investment objectives and tax status, among other data. The investment advisor
representatives may or may not deliver to the client a written analysis or report as part of the services. The
investment advisor representatives tailor the hourly consulting services to the individual needs of the client
based on the investment objective chosen by the client. The engagement terminates upon final consultation
with the client. Fees for such services are negotiable and detailed in the client agreement.
Retirement Plan Consulting
Investment advisor representatives of The Main Street Group may assist clients who are trustees or other
fiduciaries to retirement plans (“Plans”) by providing fee-based consulting and/or advisory services.
Investment advisor representatives may perform one or more of the following services, as selected by the
client in the client agreement:
• Assisting in the preparation or review of an investment policy statement (“IPS”) for the Plan based
upon consultation with client to ascertain Plan’s investment objectives and constraints.
• Acting as a liaison between the Plan and service providers, product sponsors or vendors.
• Monitoring of investment manager(s) or investments in relation to the criteria specified in the
Plan’s IPS or other written guidelines provided by the client to IAR.
• Preparing reports describing the performance of Plan investment manager(s) or investments, as
well as comparing the performance to benchmarks.
• Recommending, for consideration and selection by client, specific investments to be held by the
Plan or, in the case of a participant-directed defined contribution plan, to be made available as
investment options under the Plan.
• Educating or training the members of the Plan investment committee with regard to various
matters, including plan features, retirement readiness matters, service on the committee, and
fiduciary responsibilities.
• Assisting in enrolling Plan participants in the Plan, including conducting an agreed upon number of
enrollment meetings. As part of such meetings, IARs may provide participants with information
about the Plan, which may include information on the benefits of Plan participation, the benefits of
increasing Plan contributions, the impact of pre- retirement withdrawals on retirement income, the
terms of the Plan and the operation of the Plan.
If the Plan makes available publicly traded employer stock (“company stock”) as an investment option under
the Plan, investment advisor representatives do not provide investment advice regarding company stock and
are not responsible for the decision to offer company stock as an investment option. In addition, if participants
in the Plan may invest the assets in their accounts through individual brokerage accounts, a mutual fund
window, or other similar arrangement, or may obtain participant loans, investment advisor representatives do
not provide any individualized advice or recommendations to the participants regarding these decisions.
Furthermore, investment advisor representatives do not provide individualized investment advice to Plan
participants regarding their Plan assets.
D. Client Account Management
Prior to engaging The Main Street Group to provide investment advisory services, each Client is required to
enter into an agreement with the Advisor that defines the terms, conditions, authority and responsibilities of
the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – The Main Street Group, in connection with the Client, may
establish a strategy that seeks to achieve the Client’s goals and destinations. The strategy is
designed to address the Client’s personal goals, investment goals, and both long-term and short-
term objectives.
• Asset Allocation – The Main Street Group will develop a strategic asset allocation that is targeted to
meet the investment objectives, time horizon, financial situation and risk tolerance of risk for each
Client.
• Portfolio Construction – The Main Street Group will develop a portfolio intended to meet the stated
goals and objectives of the Client.
• Investment Management and Supervision – The Main Street Group will provide investment
management and ongoing oversight of the Client’s relationship’s investment portfolio.
E. Wrap Fee Programs
Certain accounts include the trading costs along with the asset management fees. Combining these costs into a
single fee is considered a “Wrap Fee Program”. The Main Street Group does not sponsor or serve as portfolio
manager for a wrap fee account.
However, the Advisor may cover limited ticket charges on certain accounts. In such instances the advisory fee
is unaffected.
F. Assets Under Management
Assets under manager are updated at least annual within 90 days of the December 31st fiscal year-end.
Assets Under Management (02/09/2024)
Discretionary $324,929,396
Non-discretionary $0.00
Total $324,929,396
Clients may request more current information at any time by contacting their Advisor.
G. Miscellaneous
Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent
requested by the client, The Main Street Group will generally provide financial planning and related consulting
services regarding non-investment related matters, such as tax and estate planning, insurance, etc. The Main
Street Group will generally provide such consulting services per the terms and conditions of a separate fee and
agreement, exclusive of its advisory fee set forth at Item 5 below. (Exceptions do occur, generally based upon
assets under management and/or the representative providing the services.)
Please Note: The Main Street Group does not serve as an attorney, accountant, or insurance agent, and no
portion of our services should be construed as same. Accordingly, The Main Street Group does not prepare legal
documents, prepare tax returns, or sell insurance products. To the extent requested by a client, we may
recommend the services of other professionals for non-investment implementation purpose (i.e. attorneys,
accountants, insurance, etc.), including some Main Street Group representatives in their separate individual
capacities as registered representatives of Kestra Investment Services, LLC (“Kestra”), an SEC registered and
FINRA member broker-dealer, and as licensed insurance agents. The client is under no obligation to engage the
services of any such recommended professional. The client retains absolute discretion over all such
implementation decisions and is free to accept or reject any recommendation from The Main Street Group and/or
its representatives.
Please Also Note: If the client engages any recommended unaffiliated professional, and a dispute arises
thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the
engaged professional. At all times, the engaged licensed professional[s] (i.e. attorney, accountant, insurance
agent, etc.), and not The Main Street Group, shall be responsible for the quality and competency of the services
provided.
Please Further Note-Conflict of Interest: The recommendation by a Main Street Group representative that a
client purchase a securities or insurance commission product from a representative of The Main Street Group in
his/her individual capacity as a representative of Kestra and/or as an insurance agent, presents a conflict of
interest, as the receipt of commissions may provide an incentive to recommend investment and/or insurance
products based on commissions to be received, rather than on a particular client’s need. No client is under any
obligation to purchase any securities or insurance commission products from a representative of The Main Street
Group. Clients are reminded that they may purchase securities and insurance products recommended by a
representative of The Main Street Group through other, non-affiliated broker-dealers and/or insurance agents.
Custodian Charges-Additional Fees: As discussed below at Item 12 below, when requested to recommend a
broker-dealer/custodian for client accounts, The Main Street Group generally recommends that Schwab and/or
National Financial Services (“NFS”) serve as the broker-dealer/custodian for client investment management
assets. Broker-dealers such as Schwab and NFS generally charge transaction fees for effecting securities
transactions (i.e. including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for
fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other
type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian (while
certain custodians, including Schwab and NFS, do not currently charge fees on individual equity transaction,
other do). When beneficial to the client, individual fixed-income and/or equity transactions can be effected
through broker-dealers with whom The Main Street Group and/or the client have entered into arrangements for
prime brokerage clearing services, including effecting certain client transaction through other SEC registered and
FINRA/SIPC member broker-dealers (in which event, the client generally will incur both transaction fees charged
by the executing broker-dealer and a “trade-away” fee charged by Schwab and/or NFS). These fees/charges are in
addition to the advisory fees disclosed in Item 5 below. The Main Street group does not have any portion of these
fees/charges. The Chief Compliance Officer, Steven G. Crawford, is available to address any questions that a
client or prospective client has regarding fees.
Please Note-Use of Mutual and Exchange Traded Funds: Most mutual funds and exchange traded funds are
available directly to the public. Thus, a prospective client can obtain many of the funds that may be utilized by
The Main Street Group independent of engaging The Main Street Group as an investment advisor. However, if
a prospective client determines to do so, he/she will not receive The Main Street Group’s initial and ongoing
investment advisory services.
Please Note-Use of DFA Mutual Funds: The Main Street Group utilizes mutual funds issued by Dimensional
Fund Advisors (“DFA”). DFA funds generally are available only through registered investment advisers
approved by DFA. Thus, if the client were to terminate The Main Street Group’s services, and transition to
another adviser who has not been approved by DFA to utilize DFA funds, restrictions regarding additional
purchases of, or reallocation among other DFA funds, will generally apply.
Please Also Note: In addition to The Main Street Group’s investment advisory fee described below, and
transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and
exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund
expenses).
Please Note: Use of Leverage Funds. Advisers of The Main Street Group can utilize Leveraged mutual funds
and/or exchange traded funds. These funds use leverage to increase their returns, seeking to deliver multiples
of the index or benchmark they track. Leverage seeks to magnify investment returns, shortening the time it
takes to achieve a desired return. However, leverage can also magnify investment losses. There can be no
assurance that a leveraged strategy will prove profitable or successful. In light of these enhanced risks/rewards,
a client may direct the Registrant, in writing, not to employ any or all such strategies for their accounts.
Independent Managers. The Main Street Group may allocate a portion of a client’s investment assets among
unaffiliated independent investment managers in accordance with the client’s designated investment objective(s).
In such situations, the Independent Manager[s] shall have day-to- day responsibility for the active discretionary
management of the allocated assets. The Main Street Group shall continue to render investment supervisory
services to the client relative to the ongoing monitoring and review of account performance, asset allocation and
client investment objectives. Factors that The Main Street Group shall consider in recommending Independent
Manager[s] include the client’s designated investment objective(s), management style, performance, reputation,
financial strength, reporting, pricing, and research.
Please Note: The investment management fee charged by the Independent Manager is separate from, and in
addition to, The Main Street Group’s advisory fee as set forth in the fee schedule at Item 5 below.
Please Note: Cash Positions. The Main Street Group treats cash as an asset class. As such, unless determined
to the contrary, all cash positions (money markets, etc.) shall be included as part of assets under management
for purposes of calculating the advisory fee. At any specific point in time upon perceived or anticipated
market conditions/events (there being no guarantee that such anticipated market conditions/events will occur)
The Main Street Group, may maintain cash positions for defensive purposes. Assets maintained in cash
amounts could miss market advances. Depending upon current yields, fees can exceed interest earned.
Please Note: Social Responsible Investing. Socially responsible investing involves the incorporation of
Environmental, Social and Governance considerations into the investment due diligence process ("ESG”).
There are potential limitations associated with allocating a portion of an investment portfolio in ESG securities
(i.e., securities that have a mandate to avoid investments in such products as alcohol, tobacco, firearms, oil
drilling, gambling, etc.). The number of these securities may be limited when compared to those that do not
maintain such a mandate. ESG securities could underperform broad market indices. Investors must be willing
to accept this possible limitations. Correspondingly, the number of ESG mutual funds and exchange traded
funds are few when compared to those that do not maintain such a mandate. As with any type of investment
there can be no assurance that investment in ESG securities will be profitable.
Please Note: Scope of Services to be Provided. The scope of investment advisory, financial planning and
consulting services to be provided and the corresponding fees to be charged depends upon the terms of the
engagement, the specific requests and needs of the client and the individual professional providing
the services.
Portfolio Activity. The Main Street Group has a fiduciary duty to provide services consistent with the client’s
best interest. As part of its investment advisory services, The Main Street Group will review client portfolios on
an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited
to, investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals,
and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods
of time when The Main Street Group determines that changes to a client’s portfolio are neither necessary nor
prudent. Clients are still subject to the fees described in Item 5 below, even during periods of account inactivity.
Of course, as indicated below, there can be no assurance that investment decisions made by The Main Street
Group will be profitable or equal any specific performance level(s).
Client Obligations. In performing our services, The Main Street Group shall not be required to verify any
information received from the client or from the client’s other professionals and is expressly authorized to rely
thereon. Moreover, each client remains responsible for promptly notifying The Main Street Group if there is ever
any change in his/her/its financial situation or investment objectives for the purpose of
reviewing/evaluating/revising our previous recommendations and/or services.
Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and it should
not be assumed that future performance of any specific investment or investment strategy (including the
investments and/or investment strategies recommended or undertaken by The Main Street Group) will
be profitable or equal any specific performance level(s).