Austin Money Management Corporation was formed in May 2018 and has been registered with the U.S.
Securities & Exchange Commission as an Investment Adviser since February 2020. The principal Owner,
President and Chief Compliance Officer is Steven D. Aycock, CFP®. Mr. Aycock also serves as the single
Investment Advisor Representative.
Advisory Services
Austin Money Management Corporation’s (“AMMC” or “Advisor”) principal service is providing fee-based
investment management and consulting services and financial planning services. The Advisor practices custom
management of portfolios, on a discretionary or non-discretionary basis according to the client’s objectives. The
Advisor’s primary approach is to use an allocation strategy aimed at reducing risk and increasing performance.
While AMMC can advise on any investment asset, our recommendations are primarily related to investments in
exchange traded funds and mutual funds.
• AMMC measures and selects mutual funds by using various criteria, such as the fund manager’s tenure,
and/or overall career performance as well as the diversify the portfolio.
• AMMC uses cash positions as a hedge against adverse market movements and selling certain positions for
tax harvesting purposes.
• AMMC will tailor its advisory services to its client’s individual needs based on meetings and conversations
with the client.
• If clients wish to impose certain restrictions on investing in certain securities or types of securities, the
Advisor will address those restrictions with the client to have a clear understanding of the client’s
requirements.
AMMC offers two fee options.
1. Wrap fee Program
Wrap fee programs offer services for one all-inclusive fee, subject to limited exceptions. AMMC
sponsors and is the portfolio manager of a wrap fee program held at either National Financial Services
LLC, and Fidelity Brokerage Services LLC (together with all affiliates, "Fidelity") or Charles Schwab &
Co., Inc. (“Schwab”) herein known as the custodian(s). Both Fidelity and Schwab are independently
owned and operated, and have no affiliation with AMMC, and neither acts as a sponsor or portfolio
manager of the wrap fee program.
2. Non-Wrap Fee Program
Other or the same clients will pay a management fee to AMMC for the advisory services, and separately
pay the custodial and securities execution fees directly to the custodian and executing broker-dealer from
their brokerage account. The specific fee arrangement will be based on client circumstances and will be
defined in the investment advisory agreement between the client and AMMC.
A wrap fee program is defined as one where a fee is charged to the account that is not based directly on
transactions in the account. The total or “wrapped” fee includes both the investment advisory services and the
costs of executing the transactions in the account are “sponsored” by AMMC. Management fees for the wrap
fee pricing option are typically slightly higher than management fees where the client pays securities transaction
costs separately, to compensate for the estimated costs of trading in the account. The exact fee is negotiable and
will generally not exceed the maximum fee described in Item 5.
Assets under management are updated at least annually within 90 of the December 31st fiscal year-end.
Assets Under Management (03/01/2024)
Discretionary $139,067,254
Non-discretionary $74,758,401
Total: $213,825,655
AMMC has approximately an additional $49,144,536 of assets under advisement.
Real Estate Investments
AMMC can advise on commercial real estate, multi-family developments and land acquisition opportunities
that may be appropriate for accredited investors. Such investments may include investing in land zoned for
mixed use such as retail shopping, restaurants, schools and universities as well as medical facilities, parks and
residential properties.
There are various risks to consider such as a lack of public interest and the lack of registration with the SEC or
the securities commission of any state or country. In addition, the following, not limited, risks apply:
• Lack of Liquidity
• Zoning Restrictions and Potential Changes
• Lack of Control
• Minimal Transparency
• Changing Economic Conditions affecting Consumer Demand
• Construction Delays due to Costs of Materials or Labor Disputes
• Unexpected Environmental Complications
• Tenants/Residents Ability to make Rent/Mortgage Payments (Risk of Default)
Like other Alternative Investments and Limited Partnerships, performance can be volatile. Investments are
subject to a complete loss of the principal amount invested with extended time frames before a potential return
on capital, if any. In addition, such investments often have concentrated positions that can exaggerate
investment risk. Clients with the appropriate risk profile should only consider a portion of their total assets to
be help in high risk, volatile positions.
Private Equity
AMMC can introduce and advise qualified clients on private equity opportunities. Private equity investments
involve a higher degree of risk compared to public equity investments due to a lack of registration and
disclosure requirements, the potential for operational and managerial challenges as well as market risks, and a
potentially high debt position. However, successful private equity investments can yield significant returns for
investors.
Private equity investments are generally suitable for sophisticated investors with a high risk tolerance, a long-
term investment horizon, and the ability to sustain losses up to the entire principal amount invested. Private
equity investments are complex and are not suitable for all investors. Investments in private equity are often
illiquid, meaning that it can be challenging to sell or exit the investment before the agreed-upon holding period,
which is typically several years. This lack of liquidity can tie up capital for an extended period, limiting the
investor's ability to react to changing financial needs or market conditions.
Pension Consulting Services
ERISA 3(21) – Non-Discretionary
AMMC will provide research and analysis with regard to investment advice and fiduciary due diligence
services for the Client. The goal of the investment due diligence process is to establish a logical, technical, and
prudent process that is consistently employed in the selection and ongoing monitoring of funds for plan
sponsors and individuals, accompanied by an investment policy statement (for plan sponsors only), that defines
the process utilized to recommend prudent investment actions to plan fiduciaries, or their representatives. In
providing the investment advice to the Client’s plan the AMMC will follow the investment policy statement
and undertake procedural due diligence to arrive upon, or facilitate, prudent investment-related
recommendations. However, services provided by the Adviser under this Agreement will not include any
services with respect to employer securities, company stock, or the design and monitoring of asset allocation
model glide paths or other custom asset allocation management services or solutions, whether available
through the Adviser or an affiliate thereof
The Advisor acknowledges that it is a fiduciary with respect to the Plan under Section 3(21)(A)(ii) of the
Employee Retirement Income Security Act of 1974, as amended (ERISA) and, as such, is a co-fiduciary with
the plan sponsor fiduciary(ies) of the Client’s Plan solely with respect to:
(a) the provision of investment education of the employer and/or plan participants (depending on the
specific advisory services provided);
(b) the periodic reporting on, and analysis of, the investment options available under the Plan, excluding
company stock and investments made available through a brokerage account/window or similar such
investment vehicle; and,
(c) the provision of advice to the plan sponsor fiduciary(ies) regarding the elimination or addition of
investment options available under the Plan; provided, however, that the plan sponsor fiduciary(ies)
acknowledge and agree that the plan sponsor fiduciary(ies) have the final and conclusive responsibility
for the investment options selected to be available under the Plan. The Adviser will not be responsible
for investment decisions made by the Plan participants with respect to the investment of their individual
accounts.
ERISA 3(38) – Discretionary
AMMC can be engaged on a discretionary basis for the selection, mapping, and ongoing monitoring, of
investments offered within the Plan sponsored by the Client. Upon agreement, the Client engages the Adviser
for management of Plan assets and shall delegate specified authority and discretion to AMMC for the selection,
mapping, and ongoing monitoring (including replacement, as prudent), of investments offered within the
plan. However, services provided by the AMMC under this Agreement will not include any services with
respect to employer securities, company stock, or the design and monitoring of asset allocation model glide
paths or other custom asset allocation management services or solutions.
AMMC acknowledges that it is a fiduciary with respect to the Plan under Section 3(38) of ERISA and, as such,
is a fiduciary to the Client’s Plan solely with respect to the selection, mapping, monitoring, and replacement of
plan investment options for which the it has explicit authorized discretionary control. AMMC will not be
responsible for investment decisions made by individual Plan participants with respect to the investment of
their accounts and/or investment into a model portfolio managed by Adviser, if applicable.
Participant Education (Plan and Participant Level)
AMMC can assist with developing an education and communication strategy for the Plan’s participants that
includes developing a calendar of educational meetings, determining appropriate topics, establishing meeting
dates and schedule, prioritizing group versus one-on-one meetings, and so on.
AMMC can meet with participants, regularly or as requested, to present information regarding the benefits of
Plan participation; the impact of pre-retirement withdrawals on retirement income, investment objectives, and
philosophies; and risk/return characteristics. AMMC can provide nonfiduciary
education, but not advice,
concerning the availability of withdrawals and rollovers from the Plan at any group meetings held for Plan
participants but will not discuss the advisability of withdrawals or rollovers at such meetings. AMMC may
provide written general financial information related to investment concepts such as diversification, dollar-cost
averaging, estimating future retirement income needs, and assessing risk tolerance. AMMC may furnish
investment materials, such as worksheets or questionnaires, which allow participants to estimate future income
needs and assess different asset allocation models.
Participant Advice (Participant Level)
The Adviser can either conduct in-person one-on-one meetings to be coordinated with the Client, or via
alternative means of communication (via the telephone, electronically, etc.) as requested by the Client, and
each individual participant in the Plan wishing to engage the Adviser for individual investment advice. AMMC
can determine the Plan participant’s investment return objectives, risk tolerance, time horizon, and other
preferences; recommend a suitable asset allocation model for the participant; and advise the participant to
periodically rebalance his or her asset allocation mix to maintain consistency with the asset allocation model.
For these services, and only these services described as Investment Advice (Participant Level), the Adviser
acknowledges that it will be a fiduciary to the Plan under ERISA section 3(21)(a)(i). Adviser’s fiduciary
responsibilities to the Plan, however, will be limited to the advice provided to each individual participant.
AMMC does not possess discretionary control and thus will not be responsible for actual investment elections
made by the Plan participants if not in accordance with the advice provided. AMMC assumes no other
fiduciary responsibilities under this Agreement other than those specifically outlined herein.
Investment Management of Model Portfolios (Plan Level)
AMMC can manage asset allocation model portfolios (the “Models”) for the Client. Client grants Adviser
discretion or non-discretionary authority regarding asset allocation design, investment selection, and weighting
of investment options within each of the Models. Discretionary authority is limited to management of the
Models and does not apply to any other aspect of the Client’s account or Plan.
For these services, and only these services described as Investment Management of Model Portfolios (Plan
Level), AMMC acknowledges that it will be a fiduciary to the Plan under ERISA section 3(21)(a)(i) or ERISA
section 3(38). The fiduciary responsibilities to the Plan, however, will be limited to the management of the
Models. AMMC will not be responsible for investment decisions made by the Plan participants about the
investment of their accounts into the Models. AMMC assumes no other fiduciary responsibilities under this
Agreement other than those specifically outlined herein.
Services Offered
Investment Advisor Representatives perform one or more of the following services, as selected by the Client in
the client agreement:
• Investment Policy Statement. Advisor Representative will assist the Plan in the preparation or review of
an investment policy statement (“IPS”) for the plan based upon consultation with Client
• Ongoing Investment Recommendations. Advisor Representative will recommend, 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. Advisor
Representative will recommend for consideration and selection by Client, investment replacements if an
existing investment is determined by the Client to no longer be suitable as an investment option.
• Ongoing Investment Monitoring. Advisor Representative will perform ongoing monitoring of
investment options in relation to the criteria provided by the Client to the Advisor Representative.
• Qualified Default Investment Alternative Assistance. Advisor Representative may assist Client with
selecting investment products or managed accounts offered by third parties in connection with the
definition of a “Qualified Default Investment Alternative” (“QDIA”) under ERISA (for plans subject to
ERISA).
• Non-Discretionary Model Portfolios. Advisor Representative will recommend, for consideration and
approval by Client: 1. asset allocation target-date or risk-based model portfolios for the Plan to make
available to Plan participants and 2. funds from the line-up of investment options chosen by the Client to
include in such model portfolios.
• Performance Reports. Advisor Representative will prepare periodic reports reviewing the performance
of all Plan investment options, as well as comparing the performance thereof to benchmarks with Client.
The information used to generate the reports will be derived directly from information such as statements
provided by Client, investment providers and/or third parties.
• Service Provider Liaison. Advisor Representative shall assist the Plan by acting as a liaison between the
Plan and service providers, product sponsors or vendors. In such cases, Advisor Representative shall act
only in accordance with instructions from Client or Plan administration matters and shall not exercise
judgement or discretion on such matters.
• Education Services to Plan Committee. Advisors Representative will provide training for the members
of the Plan Committee with regard to their service on the Committee, including education and consulting
with respect to fiduciary responsibilities.
• Participant Education. Advisors Representative will design an education plan and policy statement that
may include information about the investment options under eh Plan (e.g. investment objectives,
risk/return characteristics and historical performance, investment concepts *e.g. diversification, asset
classes and risk and return), the determination of investment time horizons and the assessment of risk
tolerance. Such information shall not include specific investment advice about investment options under
the Plan as being appropriate for a particular participant.
• Participant Enrollment. Advisors Representative will assist Client in enrolling participants in the Plan,
including conducting an agreed-upon number of enrollment meetings. As part of such meetings, Advisor
Representative will 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
preretirement withdrawals on retirement income, the terms of the Plan and the operation of the Plan.
• Plan Search Support/Vendor Analysis. Advisor Representatives will assist with the preparation,
distribution, and evaluation of Requests for Proposal, finalist interviews and conversion support.
• Benchmarking Services. Advisor Representative will provide Client with comparisons of Plan data (e.g.
regarding fees and services and participant enrollment and contributions) to data from the Plan’s prior
years and/or a benchmark group of similar plans.
• Assistance Identifying Plan Fees. Advisor Representative will assist Client in identifying the fees and
other costs borne by the Plan, as specified by Client, for investment management, recordkeeping,
participant education, participant communication and/or other services provided with respect to the Plan.
Publicly Traded Employer Stock
If the Plan makes available publicly traded employer stock (“company stock”) as an investment option under
the Plan, 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 invest
the assets in their accounts through individual brokerage accounts, a mutual fund window, or other similar
arrangement, or obtain participant loans. AMMC does not provide individualized advice or recommendations
to the participants regarding such decisions.
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
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
(ERISA) 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.
AMMC also provides educational services pertaining to retirement plan assets that could potentially be rolled-
over to an IRA managed by AMMC. Education is based on a particular client’s financial circumstances.
AMMC 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
Financial planning is generally incorporated into the larger asset management agreement but it is available as a
stand-alone services. The Financial Planning services will be tailored to the specific needs of clients, but
generally include recommendations for investment portfolio customization based on investment objectives,
goals and financial situation, recommendations relating to investment strategies as well as tailored investment
advice. Financial planning can include specific topic advice non-investment issues such as developing
strategies to achieve retirement or other financial goals, tax optimization strategies, cash flow and budgeting
analysis and recommendations, financing and financial education, estate planning, and asset protection
strategies.