A. Compass Financial Management LLC (“Compass”) was formed on January 13, 2011, in the
State of Delaware and became an SEC-registered investment advisory (RIA) firm on April
13, 2011. Compass transitioned to state registration in July 2012. As of March 6, 2020,
Compass transitioned from state to federal registration. Compass is owned and managed
by:
Matthew Markowski Partner
Date of Birth: August 26, 1976
Practice: 20 Years Professional Experience
Education: Bachelors in Math & Economics from Hamilton
College and MBA from Seton Hall University in
Finance
Licenses: Series 63, and CFP®
Business: July 2018 – Partner Compass
Michael Markowski Partner
Date of Birth: March 17, 1973
Practice: 20 Years Professional Experience
Education: Bachelors in Business from Hardwick College
Licenses: Series 63, and Series 65
Business: July 2018 – Partner Compass
Christopher Markowski Partner
Date of Birth: June 26, 1971
Practice: 20 Years Professional Experience
Education: Bachelors in Political Science from Syracuse
University
Licenses: Series 65
Business: July 2018 – Partner Compass
Joshua Markowski is actively involved in portfolio construction and back-office support. He is
responsible for execution of trades, money movements, client and advisor support among other
things
B. As d i s c u s s e d below, Compass offers to its clients (individuals, high net worth
individuals, banking or thrift institutions, pension and profit sharing plans, trusts, estates,
etc.): discretionary investment advisory services and retirement plan consulting services on
a fee basis.
INVESTMENT ADVISORY SERVICES
The client can engage Compass to provide discretionary investment advisory services on
a fee basis. Compass’ annual investment advisory fee is generally based upon a percentage
(%) of the market value of the assets placed under Compass’ management. Compass’
annual investment advisory fee shall include investment advisory services, and, to the
extent specifically requested by the client and agreed by Compass, consulting services.
Prior to engaging Compass to provide investment advisory services, clients are required to
enter into an Investment Management Agreement with Compass setting forth the terms and
conditions of the engagement (including termination), describing the scope of the services
to be provided, and the fee that is due from the client.
Compass provides investment advisory services specific to the needs of each client. Before
providing investment advisory services, an investment advisor representative will ascertain
each client’s investment objective(s), financial situation and time frame. Thereafter,
Compass will allocate investment assets consistent with the designated investment
objective(s), financial situation, and time frame. Compass primarily allocates client
investment assets among various individual equity (stocks), debt (bonds) and fixed
income securities, mutual funds and/or exchange traded funds (“ETFs”) on a discretionary
basis. Once allocated, Compass provides ongoing monitoring and review of account
performance, asset allocation and client investment objectives.
RETIREMENT PLAN CONSULTING SERVICES
Compass also provides non-discretionary pension consulting services, pursuant to which
it assists sponsors of self-directed retirement plans with the selection and/or monitoring
of investment alternatives (generally open-end mutual funds) from which plan
participants shall choose in self-directing the investments for their individual plan
retirement accounts.
In addition, to the extent requested by the plan sponsor, Compass shall also provide
participant education designed to assist participants in identifying the appropriate
investment strategy for their retirement
plan accounts. The terms and conditions of the
engagement shall generally be set forth in a 401(k) Consulting Agreement between Compass
and the plan sponsor. Compass’ annual investment consulting fee for 401(k) Plans shall be
prorated and paid quarterly, in arrears, based upon the market value of the plan assets on
the last day of the previous quarter, as valued by the broker-dealer or custodian of the assets.
There may be an exception to the methodology used by the custodian.
MISCELLANEOUS
Non-Investment Consulting/Implementation Services. To the extent requested by the client,
C om p a ss m ay pr ov i d e co n su l t i ng servi ces r eg ar di ng non-investment r e l a t ed
matters, such as estate planning, tax planning, insurance, etc. Neither Compass, nor any of its
representatives, serves as an attorney, accountant, or licensed insurance agent, and no portion
of Compass’ services should be construed as same. To the extent requested by a client, Compass
may recommend the services of other professionals for certain non- investment implementation
purposes (i.e. attorneys, accountants, insurance, etc.). 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 Compass. Please Note: If the client engages any such recommended
professional, and a dispute arises thereafter relative to such engagement, the client agrees to
seek recourse exclusively from and against the engaged professional. Please Also Note: It
remains the client’s sole responsibility to promptly notify Compass if there is ever any change
in his/her/its financial situation, investment objectives or time frame for the purpose of
reviewing/evaluating/revising Compass’ previous and/or current recommendations and/or services.
Trade Error Policy. Compass shall reimburse accounts for losses resulting from Compass’
trade errors but shall not credit accounts for such errors if resulting in market gains. The
gains and losses are reconciled within Compass’ custodian firm account and Compass retains
the net gains and losses.
Client Obligations. In performing its services, Compass 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 is advised that it remains his/her/its sole
responsibility to promptly notify Compass if there is ever any change in his/her/its financial
situation, investment objectives or time frame for the purpose of reviewing/evaluating/revising
Compass’ previous and/or recommendations and/or services.
Disclosure Statement. A copy of Compass’ written Brochure as set forth on Part 2A of Form
ADV shall be provided to each client prior to, or contemporaneously with, the execution of the
Investment Management Agreement.
C. Compass shall provide investment advisory services specific to the needs of each client. Before
providing investment advisory services, an investment advisor representative will ascertain
each client’s investment objective(s), financial situation, or time frame. Thereafter, Compass
shall allocate and/or recommend that the client allocate investment assets consistent
with the designated investment objective(s), financial situation, or time frame. The client may,
at any time, impose reasonable restrictions, in writing, on Compass’ services. Additional
financial consulting services shall be provided to the client at no extra charge.
D. Compass does not offer or participate in a wrap fee program.
E. As of December 31, 2023, Compass has the following assets under management:
Discretionary: $409,358,131