We offer a wrap fee program as described in this Wrap Fee Program Brochure. A wrap fee
program is generally considered any arrangement under which clients receive investment
advisory services and the execution of client transactions for a specified fee or fees not based
upon transactions in their accounts. All our investment management clients will be offered the
wrap fee program structure that includes, as a single fee, the securities transaction costs, if any,
for trading in Client accounts along with the investment advisory fees earned by our firm. Our firm
receives a portion of the wrap fee for the services rendered. While traditional Wrap Fee Programs
are often rigid, pre-packaged investment programs, our firm customizes its investment strategies
individually for its Clients. Prior to receiving services through the Program, clients are required to
enter into a written agreement with our firm setting forth the relevant terms and conditions of
the investment advisory relationship (the “Agreement”).
OUR WRAP ADVISORY SERVICES
The Advisor Managed Portfolios (AMP) Platform is a custom-designed portfolio that is
professionally managed by our Firm to meet the client’s financial goals and objectives. We
manage advisory accounts on a discretionary basis. Once we have determined a profile and
investment plan with a client, we will execute the day-to-day transactions without seeking prior
client consent, but within the expected investment guidelines. We may accept accounts with
certain restrictions if circumstances warrant. We primarily allocate client assets among individual
stocks, bonds, exchange-traded funds (ETFs), and open-end mutual funds. Portfolios will be
designed to meet a particular investment goal, determined to be suitable to the client’s
circumstances. Once the appropriate portfolio has been determined, portfolios are continuously
and regularly monitored and, if necessary, rebalanced based upon the client’s individual needs,
stated goals, and objectives.
During the initial meeting with a client, we determine the client’s objectives, time horizon, risk
tolerance, and liquidity needs. As appropriate, we also review a client’s prior investment history,
as well as family composition and background. Based on a client needs, we develop a personal
profile and investment plan for the client. We then create and manage the client’s investments
based on that profile and plan. It is the client’s obligation to notify us immediately if circumstances
have changed with respect to their goals.
Once we have determined investments in a client’s portfolio and have allocated the assets, we
provide ongoing investment review and management services.
The advisory wrap fee is made up of several components, and could include supporting services
such as:
• Investment Planning Services: Portfolio reviews, asset allocation, time horizon planning,
withdrawal strategies, account aggregation, assistance with outside held accounts such as
401(k)’s, investment policy, stock concentration.
• Estate Planning Guidance: Wills, powers of attorney, living will, health care proxy, trusts,
irrevocable life insurance trusts, estate taxes, guardians for minor children, charities.
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• Retirement Planning Services: Retirement goal setting, social security analysis, cash flow
analysis, IRA contributions, and Roth conversions, review of employer-sponsored benefits,
annuities, and pensions, Required Minimum Distributions (RMDs) and other withdrawal
strategies, self-employed plans, bucket list items.
• Insurance Planning: Review of existing policies, life insurance analysis, long-term care
insurance analysis, health insurance review, homeowner’s or renter’s insurance review,
liability coverage, health savings accounts, Medicare advice.
• Cash Flow and Budget: Review of income sources, setting goals, expenses and budgeting,
debt management, review of one-time expenses, planned large expenses, emergency
funding, dollar cost averaging, mortgage review, and lines of credit.
• Assistance to Loved Ones: Gifting, college planning, caring for the elderly, 529 College
Savings Plans, Roth IRAs for children, UGMA/UTMA, advice on establishing trusts.
• Tax planning: Tax sensitive investing, review of cost basis, review of realized gains, carry
forward losses, tax loss harvesting, deductions, and credits, potential Roth conversions,
Health Savings and Flexible Savings accounts, tax return review.
In our discretionary relationship, we will make changes to the portfolio as we deem appropriate
to meet client financial objectives. We trade these portfolios based on the combination of our
market views and client objectives, using our investment process. We tailor our advisory services
to meet the needs of our clients and seek to ensure that our clients’ portfolios are managed in a
manner consistent with their individual needs and objectives. Clients have the option to leave
standing instructions with our Firm to refrain from investing in particular industries or invest in
limited amounts of securities.
In all cases, clients have a direct and beneficial interest in their securities, rather than an undivided
interest in a pool of securities. We have limited authority to direct the custodian to deduct our
investment advisory fees from your accounts, but only with the appropriate written authorization
from clients.
Where appropriate, we also provide advice about certain types of legacy positions held in client
portfolios. Typically, these are assets that are ineligible to be custodied at our primary custodian.
Clients will engage us to advise on certain investment products that are not maintained at their
primary custodian such as variable
life insurance, annuity contracts, and assets held in employer-
sponsored retirement plans, or qualified tuition plans (i.e., 529 plans).
You are advised and are expected to understand that our past performance is not a guarantee of
future results. Certain market and economic risks exist that may adversely affect an account’s
performance. This may result in capital losses in your account.
LPL FINANCIAL SPONSORED ADVISORY PROGRAMS
We may provide advisory services through certain programs sponsored by LPL Financial LLC (LPL),
a registered investment advisor and broker-dealer. Below is a brief description of each LPL
advisory program available to our Firm. For more information regarding the LPL programs,
including more information on the advisory services and fees that apply, the types of investments
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available in the programs, and the potential conflicts of interest presented by the programs,
please see the program account packet (which includes the account agreement and LPL Form ADV
Program Brochure), and the LPL Form ADV, Part 2A, or the applicable program.
MODEL WEALTH PORTFOLIOS PROGRAM (MWP)
MWP offers clients a professionally managed mutual fund and ETF asset allocation program. Our
Firm will obtain the necessary financial data from the client, assist the client in determining the
suitability of the MWP program, and assist the client in setting an appropriate investment
objective. We will initiate the steps necessary to open an MWP account and have discretion to
select a model portfolio designed by LPL’s Research Department consistent with the client’s
stated investment objective. LPL’s Research Department or third-party portfolio strategists are
responsible for selecting the mutual funds or ETFs within a model portfolio, and for making
changes to the mutual funds or ETFs selected.
The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds and
ETFs, and to liquidate previously purchased securities. The client will also authorize LPL to perform
rebalancing for MWP accounts.
MWP requires a minimum asset value for a program account to be managed. The minimums vary
depending on the portfolio(s) selected as well as the account’s allocation among the portfolios.
Minimums per portfolio typically range from $5,000 to $25,000. In certain instances, a lower
minimum for a portfolio is permitted.
RELATIVE COST OF THE PROGRAM
A wrap fee program allows our clients to pay a specified fee for investment advisory services and
the execution of transactions. Clients do not pay brokerage commissions, markups, or transaction
charges for execution of transactions in addition to the advisory fee. Our firm will pay the
Custodian for each trade or transaction. We do not charge our clients higher advisory fees based
on their trading activity, but you should be aware that we may have an incentive to limit our
trading activities in your account(s) because we incur the fees for executed trades when the
transaction-based option is selected. In order to mitigate this conflict of interest, we will fulfill our
fiduciary duty by always acting in the client’s best interest.
Our Firm charges a fee as compensation for providing investment management services in your
account(s). These services include advisory services, transaction costs, trade entry, investment
supervision, and other account maintenance activities. Our recommended custodian may charge
custodial fees, redemption fees, retirement plan and administrative fees, or commissions. See
the Additional Fees and Expenses section below for details.
A quarterly investment management fee is billed in advance based on the quarter-ending balance
of the previous month. Our maximum annual advisory fee is 1.50%. Please note that fees will be
adjusted for deposits and withdrawals made during the quarter. If accounts are opened during
the quarter, the pro-rata advisory fees will be deducted during the next regularly scheduled billing
cycle. The relevant fee and billing method is defined and agreed to by our Firm and the client in
the executed Investment Advisory Agreement. This fee is debited directly from your investment
account. Additional fees and expenses you may incur include United States Securities and
Exchange Commission (SEC) fees, mutual fund/ETF expense ratio fees, tax withholding on certain
foreign securities, postage fees, wire fees, bank charges, and other administration fees as
authorized by you.
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OTHER TYPES OF FEES & EXPENSES
In addition to the advisory fees paid to our Firm, you may also incur charges imposed by other
third parties such as broker-dealers, custodians, trust companies, banks, and other financial
institutions. These additional charges may include custodial fees, charges imposed by a mutual
fund or ETF as disclosed in the fund’s prospectus (e.g., fund management fees and other fund
expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and
electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions.
Neither our Firm nor any of our supervised persons accept compensation for the sale of securities
or other investment products, including asset-based sales charges or service fees from the sale of
mutual funds. Some of our Investment Adviser Representatives (IARs) of the Firm are licensed
insurance agents registered with various state(s) insurance departments. IARs receive
compensation (commissions, trails, or other compensation from the respective insurance
products) as a result of performing insurance transactions for clients of Marshall Investment.