MWM offers a variety of advisory services through a comprehensive wealth management relationship with
clients. As an investment adviser, MWM is subject to a fiduciary duty to its clients. Wealth management
includes financial planning, consulting, and investment management services. Prior to MWM rendering
any of the foregoing advisory services, clients are required to enter into one or more written agreements
with MWM setting forth the relevant terms and conditions of the advisory relationship (the “Advisory
Agreement”).
MWM filed for registration as an investment adviser in August 2020 and is wholly owned by Charles
Marks. As of November 2023, MWM has $ 376,279,011.00 in assets under management,
$376,279,011.00 of which are discretionary and $0.00 of which are non-discretionary.
While this brochure generally describes the business of MWM, 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 or other persons who provide investment advice
on MWM’s behalf and are subject to the Firm’s supervision or control.
Financial Planning and Consulting Services
MWM offers clients a broad range of financial planning and consulting services, which include any or all
of the following functions:
•
Business Planning
• Cash Flow Forecasting
•
Trust and Estate Planning
• Financial Reporting
• Investment Consulting
•
Insurance Planning
•
Retirement Planning
• Risk Management
•
Charitable Giving
• Distribution Planning
• Tax Planning
•
Education Planning
These services are rendered in conjunction with investment portfolio management as part of a
comprehensive wealth management engagement (described in more detail below).
In performing these services, MWM 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. MWM recommends certain clients engage the Firm for additional related services
and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest
exists for the Firm to recommend that clients engage MWM or its affiliates to provide (or continue to
provide) additional services for compensation, including investment management services. Clients retain
absolute discretion over all decisions regarding implementation and are under no obligation to act upon any
of the recommendations made by MWM under a financial planning or consulting engagement. Clients are
advised that it remains their responsibility to promptly notify the Firm of any change in their financial
situation or investment objectives for the purpose of reviewing, evaluating or revising MWM’s
recommendations and/or services.
Investment Management Services
MWM manages client investment portfolios on a discretionary basis. As described above, MWM provides
clients with wealth management services
which include a broad range of financial planning and consulting
services in addition to the investment management services.
MWM primarily allocates client assets among various exchange-traded funds (“ETFs”) in accordance with
their stated investment objectives. The Firm will also utilize mutual funds and individual debt and equity
securities in limited circumstances.
Where appropriate, the Firm also provides advice about any type of legacy position or other investment
held in client portfolios, but clients should not assume that these assets are being continuously monitored
or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage MWM to manage
and/or advise on certain 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, MWM directs or recommends the allocation of
client assets among the various investment options available with the product. These assets are generally
maintained at the underwriting insurance company or the custodian designated by the product’s provider.
MWM tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a
continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives.
MWM consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time
horizon, liquidity constraints and other related factors relevant to the management of their portfolios.
Clients are advised to promptly notify MWM if there are changes in their financial situation or if they wish
to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions
or mandates on the management of their accounts if MWM 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.
Written Acknowledgement of Fiduciary Status
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 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.