A. Ownership/Advisory History
Mosaic Family Wealth Partners, LLC, dba Mosaic Family Wealth (“MFW” or the “Advisor”) is a
registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). MFW is
organized as a Limited Liability Company (“LLC”) under the laws of the State of Delaware. MFW
acquired the investment advisory business of Mosaic Family Wealth, LLC, which was founded in
February 2015 by Duncan (Scott) Highmark and Larry Keith Shikles.
Focus Financial Partners
MFW is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, MFW is a
wholly-owned indirect subsidiary of Focus LLC. Ferdinand FFP Acquisition, LLC is the sole
managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the
board of directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is majority-owned,
indirectly and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC
(“CD&R”). Investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect
owners of Focus LLC. Because MFW is an indirect, wholly-owned subsidiary of Focus LLC, CD&R
and Stone Point investment vehicles are indirect owners of MFW.
Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants,
insurance firms, business managers and other firms (the “Focus Partners”), most of which
provide wealth management, benefit consulting and investment consulting services to
individuals, families, employers, and institutions. Some Focus Partners also manage or advise
limited partnerships, private funds, or investment companies as disclosed on their respective
Form ADVs.
MFW is managed by Duncan (Scott) Highmark, Larry Shikles, Steve Rotello, Michelle (Missy)
Brown, Tyler Campo, and Sarah Wolk (“MFW Principals”), pursuant to a management agreement
between MFW Management Company, LLC and MFW. The MFW Principals serve as officers of
MFW and are responsible for the management, supervision and oversight of MFW.
B. Advisory Services Offered
MFW offers investment advisory services to individuals, high net worth individuals, trusts,
estates, businesses, charitable organizations, and retirement plans (each referred to as a “client”).
It is the Advisor’s mission to help its clients incorporate clear, effective, and comprehensive
strategies designed to not only facilitate their finances, but also their lives.
The Advisor serves as a fiduciary to clients, as defined under the applicable laws and regulations.
As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each client
and seeks to mitigate potential conflicts of interest. MFW’s fiduciary commitment is further
described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics,
please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading.
Wealth Management Services
MFW may provide clients with wealth management services, which generally includes
discretionary management of investment portfolios in connection with a broad range of
comprehensive financial planning services.
Investment Management Services
MFW provides customized investment advisory solutions for its clients. This is achieved
through ongoing personal client contact and interaction while providing discretionary
investment management and consulting services. MFW works with each client to identify their
investment goals and objectives as well as risk tolerance and financial situation in order to
create a portfolio strategy. MFW will then construct a portfolio, consisting of securities and
strategies described in Item 8 of this brochure and/or affiliated private investment vehicles to
achieve the client’s investment goals. Where appropriate, the Advisor may also provide advice
regarding legacy portfolio positions or other investments held by the client.
MFW’s investment approach is primarily long-term focused, but the Advisor may buy, sell or
re-allocate positions that have been held for less than one year to meet the objectives of the
client or due to market conditions. MFW will construct, implement and monitor the portfolio
to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the
client. Each client will have the opportunity to place reasonable restrictions on the types of
investments to be held in their respective portfolio, subject to acceptance by the Advisor.
MFW evaluates and selects investments for inclusion in client portfolios only after applying its
internal due diligence process. MFW may recommend, on occasion, redistributing investment
allocations to diversify the portfolio. MFW may recommend specific positions to increase
sector or asset class weightings. The Advisor may recommend employing cash positions as a
possible hedge against market movement. MFW may recommend selling positions for reasons
that include, but are not limited to, harvesting capital gains or losses, business or sector risk
exposure to a specific security or class of securities, overvaluation or overweighting of the
position[s] in the portfolio, change in risk tolerance of the client, generating cash to meet
client needs, or any risk deemed unacceptable for the client’s risk tolerance.
Clients have the right to provide the Advisor with any reasonable investment restrictions that
on the management of their portfolio, which must be in writing and sent to the Advisor.
Clients should promptly notify the Advisor in writing of any changes in such restrictions or in
the client's personal financial circumstances, investment objectives, goals and tolerance for
risk. MFW will remind clients of their obligation to inform the Advisor of any such changes or
any restrictions that should be imposed on the management of the client’s account. MFW will
also contact clients at least annually to determine whether there have been any changes in a
client's personal financial circumstances, investment objectives and tolerance for risk.
Held-Away Accounts - Pontera Order Management System
MFW implements investment advice on behalf of certain clients in held-away accounts that are
maintained at independent third-party custodians. These held-away accounts are often 401(k)
accounts, 529 plans and other assets that are not held at our primary custodian(s). The order
management system that we use for held-away accounts is provided by Pontera Solutions, Inc.
MFW reviews, monitors, and manages these held-away accounts in an integrated way with
client accounts held at our clients’ primary custodian(s).
The platform allows MFW to avoid being considered to have custody of client funds since we
do not have direct access to client log-in credentials to effect trades. MFW is not affiliated with
the platform in any way and receives no compensation from them for using their platform. A
link will be provided to the client allowing them to connect an account(s) to the platform.
Once client account(s) is connected to the platform, MFW will review the current account
allocations. When deemed necessary, MFW will rebalance the account considering client
investment goals and risk tolerance, and any change in allocations will consider current
economic and market trends. The goal is to improve account performance over time, minimize
loss during difficult markets, and manage internal fees that harm account performance. Client
account(s) will be reviewed at least quarterly and allocation changes will be made as deemed
necessary.
MFW may provide these services or, alternatively, may arrange for the plan’s other providers
to offer these services, as agreed upon between MFW and the client.
Retirement Accounts
When the Advisor provides investment advice to clients regarding ERISA retirement accounts
or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title
I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code
(“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in
the client’s best interest, the Advisor will provide investment advice to a client regarding a
distribution from an ERISA retirement account or to roll over the assets to an IRA, or
recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g.
commission-based account to fee-based account). Such a recommendation creates a conflict
of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the
transaction. No client is under any obligation to roll over a retirement account to an account
managed by the Advisor.
Family Office Services
MFW also offers family office bill pay services to certain clients as part of its wealth
management program, pursuant to the wealth management agreement.
UPTIQ Treasury & Credit Solutions, LLC
MFW offers clients the option of obtaining certain financial solutions from unaffiliated third-
party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with
UPTIQ, Inc. and its affiliates, “UPTIQ”). Please see Items 5 and 10 for additional information on
these services and other important information.
Insurance Solutions
MFW helps clients obtain certain insurance solutions from unaffiliated, third-party insurance
brokers by introducing clients to MFW’s affiliate,
Focus Risk Solutions, LLC (“FRS”), a wholly
owned subsidiary of MFW’s parent company, Focus Financial Partners, LLC. Please see Items 5
and 10 for a fuller discussion of these services and other important information.
Related Private Fund Manager
MFW has a business arrangement with SCS Capital Management LLC (“SCS”), who is an
indirect, wholly owned subsidiary of Focus LLC, under which certain clients of MFW have the
option of investing in certain private investment vehicles managed by SCS. MFW is an affiliate
of SCS by virtue of being under common control with it. Please see Items 5, 10, and 11 of this
Brochure for further details.
Use of Separate Account Managers
MFW will recommend that clients utilize one or more affiliated or unaffiliated third-party
separate account managers or investment platforms for managing all or a portion of a client’s
investment portfolio. Clients may be required to authorize and enter into an investment
management agreement with a separate account manager that defines the terms in which the
manager will provide its services. The Advisor will perform initial and ongoing oversight and
due diligence over each separate account manager to ensure the strategy remains aligned
with clients’ investment objectives and overall best interests. The Advisor will also assist the
client in the development of the initial policy recommendations and managing the ongoing
client relationship. The client, prior to entering into an agreement with a separate account
manager, will be provided with the separate account manager’s Form ADV Part 2A - Disclosure
Brochure (or a brochure that makes the appropriate disclosures).
Financial Planning Services
As part of the wealth management services, MFW will typically provide a variety of financial
planning and consulting services, which are offered in several areas of a client’s financial
situation, depending on their goals, objectives and financial situation. Generally, such financial
planning services involve preparing a formal financial plan or rendering a specific financial
consultation based on the client’s financial goals and objectives. This planning or consulting
may encompass one or more areas of need, including but not limited to, Investment
management, retirement planning, education savings, cash flow planning, tax planning
analysis and coordination, estate planning analysis and coordination, and other areas of a
client’s financial situation.
A financial plan developed for the client will usually include general recommendations for a
course of activity or specific actions to be taken by the client. For example, recommendations
may be made that the client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs. MFW may
also refer clients to an accountant, attorney or other specialist, as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a written
summary of client’s financial situation, observations, and recommendations. For consulting or
ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations
are typically completed within six months of contract date, assuming all information and
documents requested are provided promptly.
Financial Consulting Services
MFW provides a variety of ongoing financial consulting services to clients, pursuant to a written
financial consulting services agreement. Services offered are related to the client’s investment
portfolio and other areas of need. Services are tailored to the client based on the client’s
financial situation, goals, and objectives.
Generally, such consulting services involve preparing a specific financial consultation based on
the client’s financial goals and objectives. This consulting may encompass one or more areas of
need, which may include the following services:
▪ General investment plan
▪ Ongoing investment consulting
▪ Risk analysis
▪ Overlap analysis
▪ Portfolio analysis
▪ Correlation analysis, and/or
▪ Fee analysis of underlying investments
The client may engage the Advisor for other services not listed above. A financial consultation
rendered to the client will usually include general recommendations for a course of activity or
specific actions to be taken by the client. Through the creation of an investment proposal
outlining the client’s previously stated investment considerations, the Advisor may advise on
best trading and investment practices including security selection, commission costs,
alternatives, liquidity, methods of investing, sell criteria (if any), dollar cost averaging and timing.
MFW may also refer clients to an accountant, attorney or other specialist, as appropriate for
their unique situation. Consultations are typically ongoing, where recommendations will occur
periodically, assuming all information and documents requested are provided promptly.
Consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the client. For example, the Advisor has an incentive to recommend that clients
engage the Advisor for investment management services or to increase the level of investment
assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor.
clients are not obligated to implement any recommendations made by the Advisor or maintain
an ongoing relationship with the Advisor. If the client elects to act on any of the
recommendations made by the Advisor, there is no guarantee of returns and the client is under
no obligation to implement the transaction through the Advisor.
Retirement Plan Advisory Services
MFW provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”)
and the company (the “Plan Sponsor”), pursuant to the terms of the retirement plan advisory
agreement. The Advisor’s retirement plan advisory services are designed to assist the Plan
Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each
engagement is customized to the needs of the Plan and Plan Sponsor. Services generally
include:
▪ Vendor analysis
▪ Plan Participant enrollment and education tracking
▪ Investment Policy Statement (“IPS”) design and monitoring
▪ Performance Reporting
▪ Investment due diligence and oversight (ERISA 3(28))
▪ Ongoing investment recommendation and assistance
▪ ERISA 404(c) Assistance
▪ Benchmarking Services
MFW is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”) with respect to investment management services and investment advice provided to
ERISA plans and ERISA plan participants. MFW is also a fiduciary under section 4975 of the
Internal Revenue Code of 1986, as amended (the “IRC”) with respect to investment management
services and investment advice provided to individual retirement accounts (“IRAs”), ERISA plans,
and ERISA plan participants. As such, MFW is subject to specific duties and obligations under
ERISA and the IRC, as applicable, that include, among other things, prohibited transaction rules
which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary
gives advice, the fiduciary must either avoid certain conflicts of interest or rely upon an
applicable prohibited transaction exemption (a “PTE”).
As a fiduciary, MFW has duties of care and of loyalty to you and is subject to obligations
imposed on us by the federal and state securities laws. As a result, you have certain rights that
you cannot waive or limit by contract. Nothing in MFW’s agreement with you should be
interpreted as a limitation of our obligations under the federal and state securities laws or as a
waiver of any non-waivable rights you possess.
C. Client-Tailored Services and Client-Imposed Restrictions
Prior to engaging MFW to provide investment advisory services, each client is required to enter
into one or more agreements with the Advisor that define the terms, conditions, authority and
responsibilities of the Advisor and the client. These services may include:
▪ Establishing an Investment Strategy – MFW, in connection with the client, will develop a
strategy that seeks to achieve the client’s investment goals and objectives.
▪ Asset Allocation – MFW will develop a strategic asset allocation that is targeted to meet
the investment objectives, time horizon, financial situation and tolerance of risk for each
client.
▪ Portfolio Construction – MFW will develop a portfolio for the client that is intended to
meet the stated goals and objectives of the client.
▪ Wealth management and Supervision – MFW will provide wealth management and
ongoing oversight of the client’s investment portfolio.
Each client’s account will be managed on the basis of the client’s financial situation and
investment objectives and in accordance with any reasonable restrictions imposed by the client
on the management of the account—for example, restricting the type or amount of security to
be purchased in the portfolio.
D. Wrap Fee Programs
MFW does not participate in wrap fee programs, where brokerage commissions and transaction
costs are included in the asset-based fee charged to the client.
E. Client Assets Under Management
As of December 31, 2023, MFW managed a total of 1,436,354,560 in client assets comprising
$998,175,370 in discretionary assets and $438,179,190 in non-discretionary assets.