This Disclosure document is being offered to you by Frontier Asset Management, LLC (“Frontier ” 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.
Our Firm became an investment adviser registered with the Securities and Exchange Commission in August 2000 and
is privately owned by principal owner Gary Miller, CFA, other employees and employee family members.
We are committed to helping clients build, manage and preserve their wealth. Our Firm provides services that seek
to help clients to achieve their stated financial goals.
Investment and Wealth Management Services:
We provide fee-based investment advisory services to retail investors, high net worth individuals, trusts, charitable
organizations, endowments, retirement plans, and other individual and institutional investors. We are also retained
to manage investment models and client accounts, either as a sub-advisor, joint-advisor, or on a model provider basis,
by a variety of third parties who are unaffiliated with us. Our firm engages in no business activities other than fee-
based investment advisory, financial planning, and model provider services.
We manage advisory accounts on a discretionary and non-discretionary basis. For discretionary accounts, once the
appropriate strategy has been determined for the client, we will execute the day-to-day transactions without seeking
prior client consent but within the expected investment guidelines. We may accept accounts with certain restrictions,
if circumstances warrant. Our investment strategies primarily use mutual funds, exchange traded funds (“ETFs”) and
exchange traded notes (“ETNs"). We generally invest client’s cash balances in money market funds. In most cases,
at least a partial cash balance will be maintained in a money market account so that our firm may debit advisory fees
for our services. Mutual fund strategies may hold ETFs or ETNs but ETF Strategies will not hold mutual funds.
We do not customize or tailor portfolios to individual client needs. Client assets are positioned in one of our
investment strategies based on their financial objectives. Likewise, we are not able to accommodate clients to
impose restrictions on investing in certain securities or types of securities.
During personal discussions with clients, we or our joint advisor / sub-advisor partners determine the client’s
objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review a client’s prior
investment history, as well as family composition and background. We or our joint advisor partner select what we
feel is the appropriate investment strategy and Frontier manages the client’s investments based on those objectives.
We provide ongoing investment review and management services. It is the client’s obligation to notify us or their
joint advisor / sub-advisor immediately if circumstances have changed with respect to their goals.
In all cases, clients have a direct and beneficial interest in their securities, rather than an undivided interest in a pool
of securities. We do have limited authority to direct the Custodian to deduct our investment advisory fees from your
account(s), but only with the appropriate written authorization from clients.
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.
Frontier Asset Management | ADV Brochure 20240311.33333 Page 5 of 57
Use of Alternative Investments: Alternative Investments represent asset classes outside the realm of traditional
stocks, bonds, mutual funds, ETFS and cash equivalents and include, among other things, private equity,
venture capital, and funds of private funds. Frontier does not currently utilize alternative investments in our
strategies.
Tax Management Services:
Taxable accounts receive certain services based on the account size. In general we analyze the tax-
sensitivity of the funds we use. A taxable portfolio will look different than a non-taxable portfolio,
depending on the tax-sensitivity of the funds. We attempt to shift taxable accounts into asset classes
that may be more tax efficient. We seek to limit short-term gains. For accounts valued at over $250,000
we look for tax-loss harvesting opportunities throughout the year, and we monitor capital gains
distributions.
Tax management services are limited through model provider relationships where Frontier does not
have discretion over account management. Tax management is also not offered for ETF strategies.
Please note that the Tax Management Services described above are not intended to, and do not,
constitute tax advice. Frontier does not provide tax advice. Clients should consult their own tax adviser
to discuss their own particular circumstances, objectives and risk tolerance before investing in our Tax
Aware and Tax Management services.
Discretionary Accounts – Joint Advisory:
We enter into an investment advisory agreement with the client and the client’s financial advisor. Both Frontier
and the client’s financial advisor serve as fiduciaries to the client under this agreement, which means they are
required to put the client’s interests before their own.
Frontier’s primary responsibility is to manage the client’s assets on a discretionary basis. This means that
Frontier initiates transactions in the client’s account without prior approval. Frontier initiates these transactions
directly through the independent custodian that holds the client’s assets.
Every quarter we make performance reports available to help clients and their financial advisor assess
the value of our services and measure progress toward their goals. We make every effort to be
transparent with our clients and encourage them to compare the performance reports to the custodial
statement that they receive.
The performance of an investment strategy may be compared to that of a benchmark (e.g., a market
index that tracks how a particular segment of the market is performing, like the S&P 500). Frontier used
a blended benchmark that is comprised of a number of different indices. The performance of a
benchmark may not reflect the deduction of the fees that you pay, which would reduce your returns.
Frontier Asset Management | ADV Brochure 20240311.33333 Page 6 of 57
The choice of an appropriate benchmark is important in evaluating performance because it is important
to compare apples to apples. It is generally not possible to invest directly in an index.
Frontier also offers billing services for its discretionary accounts. Through this service, Frontier
automatically collects its fee and the advisor’s fee directly from the client’s account and distributes the
advisor’s portion to the RIA or B/D. Please see the Fees and Compensation and Custody sections for
additional information.
The client’s financial advisor serves as the client’s investment advisor and consultant. In that role, the advisor
provides services such as:
• helping the client identify long-term goals and investment objectives
• developing an investment strategy to achieve those goals and objectives
• determining the ongoing suitability of Frontier’s services for the client
• helping the client assess the performance of the client’s account
• interacting directly with Frontier on client’s behalf
The financial advisor may provide other services to the client as agreed between the advisor and the client.
Model Provider Investment Strategies:
Frontier provides model investment strategies to investment advisory firms, through a third-party portfolio
platform. We do not enter into direct relationships with, or serve as fiduciaries to, these clients. Instead, we
serve
as a strategist to the firms that offer our model investment strategies and are paid a fee by them. We
refer to these relationships as Platform relationships. Frontier also participates in model programs, sometimes
referred to as UMA programs, where we furnish investment advice and recommendations by delivering a
model securities portfolio to, as directed by, the model program manager.
As a strategist, Frontier provides ongoing monitoring and supervision of the strategies and periodically
recommends purchase and sale transactions with respect to the management of the model investment
strategies by adjusting positions on the online Platform portal / console. The firms that offer our models are
solely responsible for implementing all trading activity that Frontier recommends. The firms are obligated to
employ our recommendations. They are also responsible for providing all administrative and performance
reporting services to their clients. On occasion, these models can hold slightly different funds than Frontier’s
direct advisory accounts due to custodial relationship constraints with Fund Companies that are outside of our
control. Frontier has the ability to obtain waivers in some cases and makes every effort to obtain access to
restricted funds. Because of this fact the performance between our standard direct models and our platform
models can and will differ.
Consulting Services:
Frontier Asset Management | ADV Brochure 20240311.33333 Page 7 of 57
Frontier provides investment consulting services to financial advisors and institutional clients. Our consulting
services include guidance relating to a broad range of investment issues such as asset allocation, manager
selection, investment strategy design and construction, performance measurement and development of
investment policy statements.
Direct Advisory Accounts:
Frontier accepts advisory clients and manages accounts for those clients on a discretionary basis. These
relationships typically include individual investors that meet account minimum criteria, charitable organizations
that request Frontier’s services or existing Frontier clients whose financial advisor is no longer able or willing to
service the client’s account. Frontier also accepts advisory clients based on a promoter relationship at their
discretion. Frontier offers direct services through our Elevate Wealth Management, Frontier’s financial planning
division.
Sub-Advisor Services:
Frontier provides sub-advisor services to Investment Advisors. In these arrangements, Frontier oversees
investment strategies on a discretionary basis for clients of the Advisor. Both parties act as fiduciaries in the
relationship. Investment strategies are managed and monitored by Frontier on an ongoing basis. The Advisor is
responsible for the administrative paperwork, servicing the accounts and account maintenance. Frontier offers
the investment advisor access to our Tamarac Advisor Portal to enable performance reporting.
Retirement Plan 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(38) of the Employee Retirement Income Security
Act of 1974, as amended (“ERISA”).
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.
Disclosure Regarding Rollover Recommendations:
We are fiduciaries under the Investment Advisers Act of 1940 (the “Act”) 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
Frontier Asset Management | ADV Brochure 20240311.33333 Page 8 of 57
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.
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. Our Firm’s Chief Compliance Officer remains available to address any questions that a client
or prospective client has regarding the oversight.
Financial Planning Services:
Frontier offers certain financial planning services to potential and current direct clients. These services may
include portfolio evaluation, cash flow analysis, short- and long-term goal assessment, retirement income
planning and an overall review of the client’s financial situation.
Wrap Fee Program:
Our Firm does not sponsor a Wrap Fee Program.
Assets:
Frontier Asset Management offers asset-class allocation and investment management services directly to
investing clients as well as through other independent Registered Investment Advisers, Model Investment
Strategy Providers and Subadvisors and their respective clients. Collectively, Advisory clients of Frontier, clients
of Independent Registered Investment Advisors, clients of Model Investment Strategy Providers and clients of
Subadvisors are referred to as Client(s). As of December 31, 2022, Frontier oversaw total assets of
$5,945,548,711 for Clients. Discretionary Assets are those accounts where Frontier has direct authority over an
account and provides continuous and ongoing management of the account. Some Client accounts are
administered on a Non-Discretionary basis where Frontier provides ongoing management of the account but
Frontier Asset Management | ADV Brochure 20240311.33333 Page 9 of 57
does not have direct authority to affect the individual account. These relationships are managed under a Model
Provider Investment Strategy relationship.
Discretionary $1,270,323,583
Non-Discretionary $4,701,125,717
$5,971,449,300