A. Advisory Services Offered
Discretionary Portfolio Management Services
MPWS provides investment management services exclusively on a wrap fee basis as a wrap
program sponsor. Under our wrap program, clients will receive investment advisory services and
the execution of securities brokerage transactions for a single specified fee.
Our investment advice is tailored to meet our clients’ needs and investment objectives. This
program allows you to choose an investment option that employs a risk-based and tax
advantaged model portfolio or a multi-sleeve model portfolio diversified among different
investment styles. We will use the information we gather to develop a strategy that enables our
firm to customize an investment portfolio for you in accordance with your risk tolerance and
investment objectives. Once we construct an investment portfolio for you, or select a model
portfolio, we will monitor your portfolio’s performance and re-balance your investments as
required by changes in market conditions and in your financial circumstances.
MPWS‘s portfolio management services may be offered through third-party investment advisers
on a sub-advised basis.
For its discretionary asset management services, MPWS receives a limited power of attorney to
effect securities transactions on behalf of its clients that include securities and strategies
described in Item 6 of this brochure, and to retain and allocate all or a portion of the account to
sub-advisers and third-party asset managers.
Clients have the right to provide the firm with any reasonable investment restrictions that should
be imposed on the management of their portfolio (must be in writing and sent to the firm), and
should promptly notify the firm in writing of any changes in such restrictions or in the client’s
personal financial circumstances, investment objectives, goals and tolerance for risk. MPWS will
remind clients of their obligation to inform the firm of any such changes or any restrictions that
should be imposed on the management of the client’s account. MPWS 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.
Fees and Compensation
Fee Schedule
The annual fee for portfolio management services will be charged as a percentage of assets
under management according to the following fee schedule.
Value of Household Assets Annual Client Fee Multi-Sleeve Strategies*
$0-$249,999 1.75% +0.25%
$250,000-$499,999 1.50% +0.25%
$500,000-$999,999 1.25% +0.25%
$1,000,000-$4,999,999 1.00% +0.25%
$5,000,000-$9,999,999 0.90% +0.25%
$10,000 and above 0.80% +0.25%
*Clients selecting a multi-sleeve strategy will be charged an additional 0.25% premium. Please
be advised there is a conflict of interest in that MPWS has an economic incentive to recommend
clients utilize a multi-sleeve strategy, because it provides an economic benefit to MPWS.
Portfolio management fees are negotiable depending on factors such as the amount of assets
under management, range of investments, and complexity of your financial circumstances,
among others. At our discretion, we may combine the account values of family members living
in the same household to determine the applicable advisory fee. For example, we may combine
account values for you and your minor children, joint accounts with your spouse, and other
types of related accounts.
Asset-based fees are always subject to the investment advisory agreement between the client
and MPWS. Such fees are payable quarterly in advance and will be calculated based upon the
market value on the last business day of the previous calendar quarter. The fees will be prorated
if the investment advisory relationship commences otherwise than at the beginning of a
calendar quarter. Capital additions and withdrawals from your account in any amount greater
than $20,000 will not be reconciled until the following quarterly billing period. MPWS may
modify the fee at any time upon 30 days’ written notice to the client. In the event the client has
an ERISA-governed plan, fee modifications must be approved in writing by the client.
These fees include charges for all transaction costs such as commissions on purchase and sales
of stocks, bonds, exchange-traded funds and options, and mutual fund transactions fees. Except
as otherwise provided below, client will incur no charges other than the adviser’s fee pursuant to
the above fee schedule in connection with the maintenance of and activity in client’s account.
The wrap fee does not include private alternative investment fees and expenses, annual account
fees or other administrative fees, such as wire fees, charged by manager or brokerage firm; fees
for securities transactions executed away from the custodian; certain odd-lot differentials,
transfer taxes, transaction fees mandated by the Securities Act of 1934, postage and handling
fees, and charges imposed by law with regard to transactions in the client’s account;
and advisory fees, expenses or sales charges (loads) of mutual funds (including money market
funds), closed-end investment companies or other managed investments, if any, held in client’s
account. The wrap fee also does not cover certain costs associated with securities transactions in
the over-the-counter market, such as fixed income securities where manager must approach a
dealer or market maker to purchase or sell a security. Such costs include the dealer’s mark-up,
mark-down or spread and odd-lot differentials or transfer taxes imposed by law.
B. Disclosure of Cost Difference if Services Purchased Separately
Depending on a number of factors, such as the number, size and nature of the securities
transactions in an advisory account, the overall fees and charges borne by the client over time
could be more or less than what these fees and charges would be if the same services were
provided on a separate basis. Bundled fees generally provide an economic incentive for the
advisory firm to select investments and strategies that minimize trading costs. Frequent trading
in an account where transaction fees are included as part of the overall advisory fee to the client
drive trading costs higher and reduce the overall fee revenue to the advisor. As a result, higher
trading costs in a bundled fee account have a negative impact on the advisory firm’s
profitability.
C. Additional Client Fees and Terms of Payment
Client Payment of Fees
MPWS generally requires fees to be prepaid on a quarterly basis. MPWS requires clients to
authorize the direct debit of fees from their accounts. Exceptions may be granted subject to the
firm’s consent for clients to be billed directly for our fees. For directly debited fees, the
custodian’s periodic statements will show each fee deduction from the account. Clients may
withdraw this authorization for direct billing of these fees at
any time by notifying us or their
custodian in writing.
MPWS will deduct advisory fees directly from the client’s account provided that (i) the client
provides written authorization to the qualified custodian, and (ii) the qualified custodian sends
the client a statement, at least quarterly, indicating all amounts disbursed from the account. The
client is responsible for verifying the accuracy of the fee calculation, as the client’s custodian will
not verify the calculation.
A client investment advisory agreement may be canceled at any time by the client, or by MPWS
with 30 days’ prior written notice to the client. Upon termination, any unearned, prepaid fees will
be promptly refunded.
Additional Fees
All fees paid for investment advisory services are separate and distinct from the fees and
expenses charged by exchange-traded funds, mutual funds, separate account managers, private
placement, pooled investment vehicles, and trade-away fees imposed by broker-dealers and
custodians, if any. Such fees and expenses are described in each exchange-traded fund and
mutual fund’s prospectus, each separate account manager’s Form ADV and Brochure and
Brochure Supplement or similar disclosure statement, each private placement or pooled
investment vehicle’s confidential offering memoranda, and by any broker-dealer or custodian
retained by the client. Clients are advised to read these materials carefully before investing. If a
mutual fund also imposes sales charges, a client may pay an initial or deferred sales charge as
further described in the mutual fund’s prospectus. A client using MPWS may be precluded from
using certain mutual funds or separate account managers because they may not be offered by
the client's custodian.
Please refer to the Brokerage Practices section (Items 9.B.2 and 9.B.3) for additional information
regarding the firm’s brokerage practices.
D. Compensation for Recommending the MPWS Wrap Fee Program
The MPWS Wrap Fee Program is a proprietary product offered exclusively through MPWS. As
such, there is a conflict of interest in that we are economically disincentivized to trade your
portfolio. The less we trade the more money we make, as our wrap fee includes trading costs.
E. External Compensation for the Sale of Securities to Clients
MPWS advisory professionals are compensated primarily through a salary and bonus structure/
through a percentage of advisory fees charged to clients. MPWS is not paid any sales, service or
administrative fees for the sale of mutual funds or any other investment products with respect to
managed advisory assets.
F. Important Disclosure – Custodian Investment Programs
Please be advised that the firm utilizes certain custodians/broker-dealers. Under these
arrangements we can access certain investment programs offered through such custodian(s)
that offer certain compensation and fee structures that create conflicts of interest of which
clients need to be aware. Please note the following:
Limitation on Mutual Fund Universe for Custodian Investment Programs: There are certain
programs in which we participate where a client’s investment options may be limited in certain
of these programs to those mutual funds and/or mutual fund share classes that pay 12b-1 fees
and other revenue sharing fee payments, and the client should be aware that the firm is not
selecting from among all mutual funds available in the marketplace when recommending
mutual funds to the client.
Conflict Between Revenue Share Class (12b-1) and Non-Revenue Share Class Mutual Funds:
Revenue share class/12b-1 fees are deducted from the net asset value of the mutual fund and
generally, all things being equal, cause the fund to earn lower rates of return than those mutual
funds that do not pay revenue sharing fees. The client is under no obligation to utilize such
programs or mutual funds. Although many factors will influence the type of fund to be used, the
client should discuss with their investment adviser representative whether a share class from a
comparable mutual fund with a more favorable return to investors is available that does not
include the payment of any 12b-1 or revenue sharing fees given the client’s individual needs
and priorities and anticipated transaction costs. In addition, the receipt of such fees can create
conflicts of interest in instances where the custodian receives the entirety of the 12b-1 and/or
revenue sharing fees and takes the receipt of such fees into consideration in terms of benefits it
may elect to provide to the firm, even though such benefits may or may not benefit some or all
of the firm’s clients.
Additional Disclosure Concerning Wrap Programs: To the extent that we either sponsor or
recommend wrap fee programs, please be advised that certain wrap fee programs may (i) allow
our investment adviser representatives to select mutual fund classes that either have no
transaction fee costs associated with them but include embedded 12b-1 fees that lower the
investor’s return (“sometimes referred to as “A-Shares,” depending on the mutual fund issuer),
or (ii) allow the use of mutual fund classes that have transaction fees associated with them but
do not carry embedded 12b-1 fees (sometimes referred to as “I-Shares,” depending on the
mutual fund sponsor). Wrap fee programs offer investment services and related transaction
services for one all-inclusive fee (except as may be described in the applicable wrap fee program
brochure). The trading costs are typically absorbed by the firm and/or the investment
representative. If a client’s account holds A-Shares within a wrap fee program, the firm and/or its
investment adviser representative avoids paying the transaction fees charged by other mutual
fund classes, which in effect decreases the firm’s costs and increases its revenues from the
account. Effectively, the cost is transferred to the client from the firm in the form of a lower rate
of return on the specific mutual fund. This creates an incentive for the firm or investment adviser
representative to utilize such funds as opposed to those funds that may be equally appropriate
for a client but do not carry the additional cost of 12b-1 fees. As a policy matter, the firm does
not allow funds that impose 12b-1 or revenue sharing fees on the client’s investment within its
wrap fee programs. Clients should understand and discuss with their investment adviser
representative the types of mutual fund share classes available in the wrap fee program and the
basis for using one share class over another in accordance with their individual circumstances
and priorities.
G. Client Assets Under Management
As of December 31, 2023, MPWS manages $128,583,840 of discretionary assets. MPWS also
advises and provides advice on assets of $3,395,953 from third-party managers where the firm
has no discretion to hire or fire such third-party managers.
Item 5: Account Requirements and Types of Clients