This Disclosure document is being offered to you by Illumine Investment Management, LLC (“Illumine” or
“Firm”) about the investment advisory services we provide and the way those services are made available
to you, the client.
We are an investment management firm located in Poulsbo, WA. Illumine was established in 2016 and the
Firm was registered with SEC in 2021. Illumine is owned by Mark E. McComsey and Ivan Jevremovic.
Our Firm provides personalized investment advisory services for individuals, high net worth individuals,
trusts, and estates. We are committed to helping clients build, manage, and preserve their wealth, and
provide clarity and direction to help clients achieve their stated financial goals. We will offer an initial
complimentary meeting upon our discretion; however, investment advisory services are initiated only after
you and Illumine execute a signed Investment Management Agreement.
INVESTMENT AND WEALTH MANAGEMENT AND SUPERVISION SERVICES
We manage advisory accounts on a discretionary basis and non-discretionary basis. Advice is provided
through consultation with you, the client, and may include: determination of financial objectives,
identification of financial problems, cash flow management, tax planning, insurance review, investment
management, education funding, retirement planning, and estate planning.
During personal discussions with clients, we determine your investment objectives, time horizons, risk
tolerance, and liquidity needs during our initial discussions. As appropriate, we also review your prior
investment history, family composition, and background. Based on your needs, we develop a personal
profile, determine the types of investments to be included in your portfolio. Once we have determined your
profile and investment plan, we will execute the day-to-day transactions without seeking your prior
consent. We will use your customized investment plan to provide ongoing investment management
services. Account supervision is guided and reviewed by the Portfolio Manager and reviewed on at least an
annual basis.
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 our clients' needs and seek to ensure that your
portfolio is managed in a manner consistent with those needs and objectives. Clients have the ability to
leave standing instructions with us to refrain from investing in particular sectors or industries or invest in
limited or no amounts of specified securities.
Clients may engage us to manage and/or advise on certain investment products that are not maintained at
their primary Custodian, such as 529 Plans and Private Placements, and assets held in employer-sponsored
retirement plans. In these situations, our Firm directs or recommends allocating 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.
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 adversely affect an account’s performance. This could
result in capital losses in your account.
If a non-discretionary relationship is in place, calls will be placed to the client presenting the
recommendation made including a rebalancing recommendation and only upon your authorization will any
action be taken on your behalf.
APRIL 2024 | PAGE 4
FINANCIAL PLANNING
Through the financial planning process, our team strives to engage our clients in conversations around the
family’s goals, objectives, priorities, vision, and legacy – both for the near term as well as for future
generations. With the unique goals and circumstances of each family in mind, our team will offer financial
planning ideas and strategies to address the client’s holistic financial picture, including estate, income tax,
charitable, cash flow, wealth transfer, and family legacy objectives. Our team partners with our client’s
other advisors (CPAs, Enrolled Agents, Estate Attorneys, Insurance Brokers, etc.) to ensure a coordinated
effort of all parties toward the client’s stated goals. Such services include various reports on specific goals
and objectives or general investment and/or planning recommendations, guidance to outside assets, and
periodic updates.
Our specific services in preparing your plan may include:
• Review and clarification of your financial goals
• Assessment of your overall financial position including cash flow, balance sheet, investment
strategy, risk management, and estate planning
• Creation of a unique plan for each goal you have, including personal and business real estate,
education, retirement or financial independence, charitable giving, estate planning, business
succession, and other personal goals
• Development of a goal-oriented investment plan, with input from various advisors to our clients
around tax suggestions, asset allocation, expenses, risk, and liquidity factors for each goal. This
includes IRA and qualified plans, taxable, and trust accounts that require special attention
• Design of a risk management plan including risk tolerance, risk avoidance, mitigation,
and transfer,
including liquidity as well as various insurance and possible company benefits; and
• Crafting and implementation of, in conjunction with your estate and/or corporate attorneys as tax
advisor, an estate plan to provide for you and/or your heirs in the event of an incapacity or death
A written evaluation of each client's initial situation or Financial Plan is provided to you. More frequent
reviews occur but are not necessarily communicated to the client unless immediate changes are
recommended.
SUB-ADVISORY SERVICES PROVIDED TO INDEPENDENT REGISTERED INVESTMENT ADVISERS
Our Firm enters into a relationship with unaffiliated registered investment advisers (hereafter referred to
as “Independent RIA”) to offer sub-advisory services whereby our Firm manages some or all of these Inde-
pendent RIA’s client (“Adviser Client”) assets according to the investment strategy chosen by the Independ-
ent RIA. In these situations, the Adviser Client remains a client of the Independent RIA. The decision as to
what investment strategy(s) Adviser Client assets are invested in is based on suitability information gath-
ered and reviewed by the Independent RIA. Our Firm will manage these assets based on its investment
strategies and not based on overall Adviser Client suitability.
Through the Independent RIA’s Agreement and authorization by the Independent RIA’s client, our Firm will
be given access to the Adviser Client accounts the Independent RIAs would like our Firm to manage. We
will facilitate all the trading and rebalancing through the Custodian platform in which our Firm is approved
to act as a sub-advisor to the Adviser Client account. We will determine when existing positions will be
liquidated to facilitate investing in our models. Our Firm will not tailor our models to accommodate for any
limitations or restrictions in the Adviser Client portfolios however on a case-by-case basis accommodations
may be made for legacy positions as outlined and confirmed in writing to our Firm. We will not have direct
APRIL 2024 | PAGE 5
contact with individual Adviser Client, only communication with and direction by the Independent RIA. Our
Firm will provide an online portal for both Adviser Clients and Independent RIAs through an arrangement
with an unaffiliated third-party accounting software. This portal will give access to reporting that details
current positions and balances, asset allocation, transaction history and performance.
DISCLOSURE REGARDING ROLLOVER RECOMMENDATIONS
A client or prospect leaving an employer typically has four options regarding an existing retirement plan
(and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if
permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted,
(iii) rollover to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could,
depending upon the client’s age, result in adverse tax consequences). Our Firm may recommend an inves-
tor roll over plan assets to an IRA for which our Firm provides investment advisory services. As a result, our
Firm and its representatives may earn an asset-based fee. In contrast, a recommendation that a client or
prospective client leave their plan assets with their previous employer or roll over the assets to a plan spon-
sored by a new employer will generally result in no compensation to our Firm. Our Firm therefore has an
economic incentive to encourage a client to roll plan assets into an IRA that our Firm will manage, which
presents a conflict of interest. To mitigate the conflict of interest, there are various factors that our Firm
will consider before recommending a rollover, including but not limited to: (i) the investment options avail-
able in the plan versus the investment options available in an IRA, (ii) fees and expenses in the plan versus
the fees and expenses in an IRA, (iii) the services and responsiveness of the plan’s investment professionals
versus those of our Firm, (iv) protection of assets from creditors and legal judgments, (v) required minimum
distributions and age considerations, and (vi) employer stock tax consequences, if any. All rollover recom-
mendations are also reviewed by our Firm’s Chief Compliance Officer in a best effort to determine that the
recommendation to a client was reasonable or that the client has determined to make the rollover after
being provided ample information about their options. No client is under any obligation to roll over plan
assets to an IRA advised by our Firm or to engage our Firm to monitor and/or advise on the account while
maintained with the client's employer. Our Firm’s Chief Compliance Officer remains available to address
any questions that a client or prospective client has regarding this disclosure.
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to
you regarding your retirement plan account or individual retirement account, we are also 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. We have to act in your best interest and not
put our interest ahead of yours. At the same time, the way we make money creates some conflicts with
your interests.
WRAP FEE PROGRAM
We do not sponsor a Wrap Fee Program.
ASSETS
As of December 31, 2023, total discretionary assets under management are $188,724,469. Non-
discretionary assets under management are $0.
APRIL 2024 | PAGE 6