This Disclosure document is being offered to you by New Millennium Group, LLC (“NMG”
or “Firm”) about the investment advisory services we provide. It discloses information
about our services and the way those services are made available to you, the client.
We are an investment management firm located in Sandy, Utah. New Millennium Group,
LLC was formed on May 22, 2015. When initially founded, New Millennium Group offered
insurance products to clients and provided investment advisory services under an
unaffiliated registered investment advisory firm. In March 2019, our firm became a
Registered Investment Advisor with the following States: Utah, Arizona, California, Texas
and Idaho. The firm filed for registration with the SEC on February 1, 2021. M.S.H.
Enterprises I, LLC and Firenze Investment Group, LLC are the Managing Members of the
firm. Tyler Glazier is Chief Compliance Officer of the Firm.
We are committed to helping clients build, manage, and preserve their wealth, and to
provide guidance that helps clients to achieve their stated financial goals. We specialize
in retirement investing and income generation. We will offer an initial complimentary
meeting upon our discretion; however, investment advisory services are initiated only
after you and NMG execute an Investment Management Agreement.
Investment Management Services
We manage advisory accounts on a non-discretionary and discretionary basis. Once we
determine a client’s profile, income need, and investment plan, we execute the day-to-
day transactions with or without prior consent, depending on the client’s agreement with
our Firm. Account supervision is guided by the client’s written profile and investment
plan. We may accept accounts with certain restrictions if circumstances warrant. We
primarily allocate client assets among various equities, Exchanged Traded Funds (“ETFs”),
and debt securities in accordance with their stated investment objectives and income
needs. All of which are considered asset allocation categories for the client’s investment
strategy.
In personal discussions with clients, we determine their objectives, time horizons, risk
tolerance and liquidity and income needs. As appropriate, we also review their prior
investment history, as well as family composition and background. Based on client needs,
we develop the client’s personal profile and investment plan. We then create and manage
the client’s investments based on that policy and plan. It is the client’s obligation to notify
us immediately if circumstances have changed with respect to their goals and income
needs.
As determined through our firm’s initial due diligence with the client, we will determine
if clients are seeking an actively managed investment strategy for their account(s). Our
firm will provide ongoing investment review and management services. This approach
requires us to periodically review client portfolios.
With our discretionary relationship, we will make changes to the portfolio, as we deem
appropriate, to meet your financial objectives. We trade these portfolios based on the
combination of our market views and your objectives, using our investment philosophy
and strategies as described in Item 8 of this Brochure. We tailor our advisory services to
meet the needs of our clients and seek to ensure that your portfolio is managed in a
manner consistent with those needs and objectives. You will have the ability to leave
standing instructions with us to refrain from investing in particular industries or invest in
limited amounts of securities.
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. Our clients should note that being
in a discretionary or non-discretionary account does not affect the management of the
accounts. It is the decision of the client on what type account they elect to open with our
firm – a discretionary account without prior notification of investment trades or a non-
discretionary account as described above.
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
investor 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 sponsored 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 available 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 recommendations are reviewed by our Firm’s Chief Compliance Officer
and remains available to address any questions that a client or prospective client has
regarding the oversight.
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.
Retirement Plan Advisory Services
For employer-sponsored retirement plans with participant-directed investments, our firm
provides its advisory services as an investment adviser as defined under Section 3(21) of
the Employee Retirement Income Security Act of 1974, as amended (“ERISA”).
When serving as an ERISA 3(21) investment adviser, the Plan Sponsor and Our Firm share
fiduciary responsibility. The Plan Sponsor retains ultimate decision-making authority for
the investments and may accept or reject the recommendations in accordance with the
terms of a separate ERISA 3(21) Plan Sponsor Investment Management Agreement
between Our Firm and the Plan Sponsor. Under the 3(21) agreement, Our Firm provides
the following services to the Plan Sponsor:
• Screen investments and make recommendations.
• Monitor the investments and suggests replacement investments when
appropriate.
• Provide a quarterly monitoring report.
• Assist the plan sponsor in developing an Investment Policy Statement (“IPS”).
• Recommend QDIA alternatives.
• Recommend non-discretionary model portfolios.
We can also be engaged to provide Plan Consulting Services. Plan Consulting Services
include financial education to Plan participants, benchmarking the Plan services,
education to fiduciary committee members, and monitoring the service provider. The
scope of education provided to participants will not
constitute “investment advice” within
the meaning of ERISA and participant education will relate to general principles for
investing and information about the investment options currently in the Plan. We may
also participate in initial enrollment meetings and periodic workshops and enrollment
meetings for new participants.
When servicing as in a 3(38) fiduciary capacity, our Firm is granted full trading authority
over the Plan and have the responsibility for the selection and monitoring of all
investment options offered under the Plan in accordance with the investment policy
statement and its underlying investment objectives and strategies for the Plan. Plan
participants have the ability to exercise control over the investment selection from the
plans line up of investments, and we have no authority or discretion to direct the
investment of assets of any participant’s account under the Plan.
Financial Planning
All of our investment management clients receive financial planning services. 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 offers financial
planning ideas and strategies to address the client’s holistic financial picture, including
estate, income tax, charitable, cash flow and retirement income, wealth transfer and
family legacy objectives. Our team partners with our client’s other advisors (CPA, estate
attorney, insurance broker, 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 a client’s formal financial plan may include:
● Review and clarification of financial goals;
● Assessment of overall financial position including cash flow and income, balance
sheet, investment strategy, risk management and estate planning;
● Creation of a unique plan for each goal, including personal and business real
estate, education, retirement, financial independence, charitable giving, estate
planning, business succession and other personal goals;
● Development of a goal-oriented investment and income plan, with input from
various advisors to our clients around tax strategy, asset allocation, asset
location, expenses, risk and liquidity factors for each goal. This includes IRA and
qualified plans, taxable and trust accounts that require special attention.
When both investment management or plan implementation and investment
management services are offered, there is a conflict of interest since there is an incentive
for us offering investment management services to recommend products or services for
which our Firm receives compensation. However, our Firm will make all
recommendations independent of such considerations and based solely on our
obligations to consider your objectives and needs. As an investment management client,
you have the right not to act upon any of our recommendations and not affect the
transaction(s) through us if you decide to follow the recommendations.
Consulting Services
We provide investment advice on isolated areas of concern such as estate planning, real
estate, retirement planning, or any other specific topic. Additionally, we provide non-
securities advice related to estate planning, insurance, real estate, and annuity. We also
provide advisory & consulting services for equity or debt investments in privately held
businesses. In these cases, you will be required to select your own investment managers,
Custodian, and insurance companies to implement consulting recommendations. If you
need brokerage and/or other financial services, we will recommend one of several
investment managers, brokers, banks, Custodian, insurance companies or other financial
professionals ("Firms"). You must independently evaluate these Firms before opening an
account or transacting business, and have the right to effect business through any firm
you choose. You have the right to choose whether to follow the consulting advice that we
provide.
Sub-Advisory Services
Our firm may determine that engaging the expertise of an independent sub-advisor is best
suited for your account. Our firm will have discretion to utilize independent third- party
investment adviser to aid in the implementation of investment strategies for your
portfolio. In certain circumstances, we may allocate a portion of a portfolio to an
independent third-party investment adviser (“Manager”) for separate account
management based upon your individual circumstances and objectives, including, but not
limited to, your account size and tax circumstances. Upon the recognition of such
situations, in coordination with you, we will hire a Manager for the management of those
assets. These advisers shall assist our Firm in managing the day‐to‐day investment
operations of the various allocations, shall determine the composition of the investments
comprising the allocation, shall determine what securities and other assets of the
allocation will be acquired, held, disposed of or loaned in conformity with the written
investment objectives, policies and restrictions and other statements of each client
comprising the allocation, or as instructed by our Firm.
Managers selected for your investments need to meet several quantitative and
qualitative criteria established by us. Among the criteria that may be considered are the
Manager’s experience, assets under management, performance record, client retention,
the level of client services provided, investment style, buy and sell disciplines,
capitalization level, and the general investment process.
You are advised and should understand that:
● A Manager’s past performance is no guarantee of future results;
● There is a certain market and/or interest rate risk which may adversely
affect any Manager’s objectives and strategies, and could cause a loss in a
Client's account(s); and
● Client risk parameters or comparative index selections provided to our firm
are guidelines only and there is no guarantee that they will be met or not
be exceeded.
Managers may take discretionary authority to determine the securities to be purchased
and sold for the client. As stated in the Discretionary Advisory Agreement, our Firm and
its associated persons will have discretionary authority to hire and fire the Manager. Our
firm will work with the sub-advisor to communicate any trading restrictions or standing
instructions to refrain from a particular industry requested by the Client. In all cases,
trading restrictions will depend on the sub-advisor and their ability to accommodate such
restrictions.
All performance reporting will be the responsibility of the respective Manager. Such
performance reports will be provided directly to you and our firm. Disclosures will
indicate what firm is providing the reporting.
Our Firm has entered into agreements with various independent Managers. All third-
party Managers to whom we will refer clients will be licensed as registered investment
advisors by their resident state and any applicable jurisdictions or registered investment
advisors with the Securities and Exchange Commission. A complete description of the
Manager’s services, fee schedules and account minimums will be disclosed in the
Manager’s Form ADV or similar Disclosure Brochure.
We review the performance of our Managers on at least a quarterly basis. More frequent
reviews may be triggered by changes in Manager’s management, performance or
geopolitical and macroeconomic specific events.
Our Firm only enters into only a select number of relationships with Managers. We have
agreed to pay a portion of the overall advisory fee charged to our clients to the Manager.
Wrap Fee Programs
Our firm does not offer a Wrap Fee Program.
Assets
As of December 31, 2023, our firm manages $144,462,410 in total assets under
management. Our Firm manages $144,462,410 on a discretionary basis and $0 on a non-
discretionary basis.