Description of Firm
The Connemara Group is a registered investment adviser primarily based in Gaithersburg, Maryland.
We are organized as a limited liability company ("LLC") under the laws of the State of Maryland. We
have been providing investment advisory services since 2015. We are owned by Thomas Conway and
David Quinn.
The following paragraphs describe our services and fees. Refer to the description of each investment
advisory service listed below for information on how we tailor our advisory services to your individual
needs. As used in this brochure, the words "we," "our," and "us" refer to The Connemara Group and
the words "you," "your," and "client" refer to you as either a client or prospective client of our firm.
The Connemara Group has developed a proprietary program of service that all fall under the umbrella
of MATRIX360©. These various offerings have been described below.
MATRIX360© Investment Advisory Services
We offer discretionary portfolio management via our MATRIX360© investment advisory services. Our
investment advice is tailored to meet our clients' needs and investment objectives. These services are
offered as a wrap fee program. We are a portfolio manager to and sponsor of a wrap fee program,
which is a type of investment program that provides clients with access to several money managers or
mutual fund asset allocation models for a single fee that includes administrative fees, management
fees, and commissions. As part of the wrap fee program, you will pay our firm a single fee, which
includes our money management fees, certain transaction costs, and custodial and administrative
costs. We receive a portion of the wrap fee for our services. The overall cost you will incur if you
participate in our wrap fee program may be higher or lower than you might incur by separately
purchasing the types of securities available in the program.
Transactions for your account must be executed by either Charles Schwab & Co. Inc
or Fidelity Financial Services, both are securities broker-dealers and members of the Financial Industry
Regulatory Authority and the Securities Investor Protection Corporation. To compare the cost of the
wrap fee program with non-wrap fee portfolio management services, you should consider the
frequency of trading activity associated with our investment strategies and the brokerage commissions
charged by or other broker-dealers, and the advisory fees charged by investment advisers. For more
information concerning the Wrap Fee Program, see Appendix 1 to this Brochure.
MATRIX360© investment advisory services have been developed by the Connemara Group to
complement and supplement (but never to replace) professional practice standards established by the
CFP Board regarding aspects of the financial planning process relating to investment analysis,
implementation, and monitoring.
MATRIX360© investment advisory services are provided to clients seeking ongoing professional
assistance with personal financial planning services and investment advisory services following
completion of an initial comprehensive MATRIX360© financial planning services analysis.
If you participate in our discretionary MATRIX360© investment advisory services, we require you to
grant our firm discretionary authority to manage your account. Discretionary authorization will allow us
to determine the specific securities, and the amount of securities, to be purchased or sold for your
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account without your approval prior to each transaction. Discretionary authority is typically granted by
the investment advisory agreement you sign with our firm and the appropriate trading authorization
forms.
You may limit our discretionary authority (for example, limiting the types of securities that can be
purchased or sold for your account) by providing our firm with your restrictions and guidelines in
writing.
MATRIX360© Financial Planning Services
We offer MATRIX360© financial planning services which typically involve providing a variety of
advisory services to clients regarding the management of their financial resources based upon an
analysis of their individual needs. These services can range from broad-based financial planning to
consultative or single subject planning. If you retain our firm for MATRIX360© financial planning
services, we will meet with you to gather information about your financial circumstances and
objectives. Once we specify those long-term objectives (both financial and non-financial), we will
develop shorter-term, targeted objectives. Once we review and analyze the information you provide to
our firm and the data derived from our financial planning software, we will deliver a written plan to you,
designed to help you achieve your stated financial goals and objectives.
Financial plans are based on your financial situation at the time we present the plan to you, and on the
financial information you provide to us. You must promptly notify our firm if your financial situation,
goals, objectives, or needs change.
You are under no obligation to act on our financial planning recommendations. Should you choose to
act on any of our recommendations, you are not obligated to implement the financial plan through any
of our other investment advisory services. Moreover, you may act on our recommendations by placing
securities transactions with any brokerage firm.
Services Included with MATRIX360©
As part of the MATRIX360© investment advisory and financial planning services, we also offer the
below services for those that require additional advice based on their specific facts and circumstances.
These additional services include:
•MATRIX360
© Retirement Distribution and Estate Planning Services
•Clients approaching the end of the wealth accumulation mode and either nearing or in
the wealth distribution mode may have very different risk tolerances, risk preferences,
and risk
capacities. Dollar-cost averaging into portfolios during the wealth accumulation
mode may have different consequences than dollar-cost averaging out of portfolios
during the wealth distribution mode. In retirement distribution planning, many factors
take on increasing importance, including household immediate liquidity and spending
needs, portfolio sustainability, tax management, portfolio optimization, asset allocation,
asset location, volatility, duration risk, inflation, healthcare costs, longevity, lifetime as
well as post-mortem intra-family giving and charitable giving, and estate planning.
•MATRIX360
© Federal Retirement Planning Services
•As with most post-retirement decisions involving employer qualified retirement plans,
careful consideration must be given, and numerous factors must be weighted in deciding
whether to roll over federal Thrift Savings Plan accounts to Individual Retirement
Arrangements ("IRAs"). Our MATRIX360© federal retirement planning services
incorporate the use of careful questioning and fiduciary software applications to help
assess whether full or partial rollovers might be warranted as specific points in time
during the retirement phase.
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•MATRIX360
© Professional and Executive Retirement Planning Services
•This service advises clients on whether or not to roll over all or part of employer qualified
retirement plans (401(k)s, etc.) and how to manage and structure various other benefits
(deferred compensation arrangements, restricted stock and/or restricted stock units
(RSUs), nonqualified stock options (NSOs), incentive stock options (ISOs), performance
share awards (PSAs), employee stock purchase plans (ESPPs), Employee Stock
Ownership Plans (ESOPs), Net Unrealized Appreciation (NUA) rules, etc.).
•MATRIX360
© Association and Not-for-Profit Executive Retirement Planning Services
•This service advises clients whether or not to roll over all or part of defined contribution
employer qualified retirement plans (403(b)s, etc.) and how to manage and structure
various other benefits in conjunction with private sector defined benefit pension plans.
•MATRIX360
© Charitable and Philanthropic Services
•Whether or not to use Qualified Charitable Distributions (QCDs) from IRAs post age 70
½ to manage tax exposure while accomplishing charitable goals, whether or not to use
DAFs on a standalone basis or in conjunction with private foundations, and whether or
not to use trusts to achieve all or a portion of a clients lifetime or post-mortem charitable
and philanthropic goals and objectives are considered and discussed with clients as part
of the firm's MATRIX360© financial planning services and MATRIX360© investment
advisory services offerings.
Types of Investments
We offer advice on equity securities, corporate debt securities (other than commercial paper), United
States government securities, mutual funds, money market funds, and ETFs.
Additionally, we may advise you on various types of investments based on your stated goals and
objectives. We may also provide advice on any type of investment held in your portfolio at the inception
of our advisory relationship.
Since our investment strategies and advice are based on each client's specific financial situation, the
investment advice we provide to you may be different or conflicting with the advice we give to other
clients regarding the same security or investment.
In general, we manage wrap fee accounts on a discretionary basis. Wrap fee accounts are typically
more appropriate for active accounts and are managed accordingly. If you participate in a wrap fee
program, we will provide you with a separate Wrap Fee Program Brochure explaining the program and
costs associated with the program. You should also review this Part 2A thoroughly to evaluate any
differences between the services we offer as wrap versus non-wrap.
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's
Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the
following acknowledgment to you. 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);
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•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.
We benefit financially from the rollover of your assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our assets under management
and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in
your best interest.
Assets Under Management
As of our last annual updating amendment dated, January 31, 2023, the Connemara Group had
$236,219,331 million in regulatory assets under management. All of these assets are managed on a
discretionary basis.