Description of Advisory Firm
BMB Advisers, LLC (“BMB,” “we,” “our,” or “us”) is a privately owned limited liability company
headquartered in Los Angeles, California. BMB is registered as an investment adviser with the U.S.
Securities and Exchange Commission.
BMB was formed in 1999 as the investment advisory affiliate of Freedman, Broder & Company, Certified
Public Accountants (“FB&C”), an accountancy firm established in 1963. FB&C specializes in providing a
complete range of planning and business management services catering specifically to the needs of
clients in the entertainment industry. Currently, the majority of BMB’s clients are clients of FB&C.
William Broder, Stephen Michalski, and Debra Bonseigneur are the principals and Members of BMB
Advisers, LLC. William Broder, Managing Member, is the majority owner of the firm.
Advisory Services Offered
BMB provides advice to our investment advisory clients through: (1) a direct portfolio management
program (the “Portfolio Management Program”); and (2) a program with independent third-party
investment advisers (the “Independent Advisor Program”).
Portfolio Management Program
Under the Portfolio Management Program, BMB offers direct investment management services to
clients. BMB will primarily invest client portfolios in mutual funds (no-load or low-load funds), exchange
traded funds (“ETFs”), and long term or short-term debt instruments, based on each client’s risk
tolerance.
BMB may occasionally offer advice regarding additional types of investments if they are appropriate to
address the individual needs, goals, and objectives of the client or in response to client inquiry. BMB
may also offer investment advice on any investment held by the client at the start of the advisory
relationship. We describe the material investment risks for many of the securities that we recommend
under the heading Specific Security Risks in Item 8 below.
After an initial interview and data gathering questionnaire is completed for the client, BMB creates an
investment plan, which is reviewed with the client prior to implementing the initial recommendations.
Thereafter, BMB will manage the client’s account on a discretionary or non-discretionary basis,
depending upon the terms agreed to with each client in the investment advisory agreement.
We discuss our discretionary authority below under Item 16 - Investment Discretion. For information
about the restrictions clients can put on their accounts, see Tailored Services and Client Imposed
Restrictions in this Item, below.
We describe the fees charged for the Portfolio Management Program below under Item 5 - Fees and
Compensation.
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Independent Advisor Program
Under the Independent Advisor Program, BMB does not actively manage client investment accounts or
recommend particular securities or other investments to clients. Third-party investment advisers
perform these activities; however, there may be limitations on services provided by third-party advisers.
Additional information concerning the programs offered by the independent third-party advisers and
any limitations on their services is contained in the disclosure brochure and information provided to the
client concerning each third-party adviser. All third-party investment advisers we recommended are
independent of BMB and FB&C.
BMB maintains a list of third-party investment advisers offering a variety of investment programs and
strategies. All third-party investment advisers to which BMB introduces clients will be registered as
investment advisers with the Securities and Exchange Commission or their appropriate state securities
regulator. We determine which programs and strategies are most appropriate for BMB’s clients based
on each client’s individual circumstances, needs, and investment objectives. Upon referral to a third-
party adviser, the client enters into an advisory agreement directly with the adviser.
Generally, clients will pay investment advisory fees to both BMB and the third-party adviser; these fees
are separate and distinct. Some of the investment programs offered by third-party investment advisers
may be “wrap fee programs,” which are programs under which a client is
charged a single bundled fee,
not based directly upon transactions in a client’s account, for both investment advisory services and
execution of client transactions.
Clients who are introduced to third-party investment advisers will receive full disclosure, including
services offered and fees charged by the third-party adviser, at the time of referral. BMB will deliver a
copy of the third-party adviser’s Form ADV Part 2 disclosure brochure as well as BMB’s brochure. If the
investment program recommended to a client is a wrap fee program, the client will receive the wrap
program brochure provided by the sponsor of the program. BMB will provide to each client all
appropriate disclosure statements, including, if applicable, disclosure of solicitation fees paid to BMB
and our Advisory Representatives as required by Securities Exchange Commission Rule 206(4)-3 and the
special disclosure required for affiliates of California certified public accountants under California
Business & Professions Section 5061 and California Board of Accountancy Rule 56.
For information about the restrictions clients can put on their accounts, see Tailored Services and Client
Imposed Restrictions in this Item, below.
Limitations on Investments
Under the Portfolio Management Program, the mutual fund portfolios BMB constructs are generally
comprised of funds offered by Dimensional Fund Advisors (“DFA”). DFA offers professionally managed
mutual funds at relatively low expense ratios. DFA funds are not available directly to individual
investors, but are limited to a select group of independent financial advisors approved by DFA. BMB is
not affiliated with DFA.
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In some circumstances, BMB’s advice may be limited to certain types of securities. For example, when
BMB is managing assets within a retirement plan such as 401(k), 403(b), ORP or other employer plan,
BMB is limited to those investment providers and investment options chosen by the plan administrator.
Similarly, when we provide services to participants in an employer-sponsored plan, the participant may
be limited to investing in securities included in the plan’s investment options. Therefore, BMB can only
make recommendations to the client from among the available options, and will not recommend or
invest the client’s account in other securities, even if there may be better options elsewhere.
See each third-party adviser’s disclosure brochure for information regarding any limitations on the
independent adviser’s services.
Tailored Services and Client Imposed Restrictions
Clients may impose reasonable restrictions on the management of their investment accounts. Clients
may instruct BMB or the third-party adviser regarding particular securities or types of securities that
should not be purchased for the account, or that should not be sold if held in the account. (Clients’
ability to place restrictions on third-party advisers may be limited by the third-party adviser – this would
be disclosed in the third-party adviser’s brochure.) BMB reserves the right to not accept and/or
terminate management of a client’s account if we feel that the client-imposed restrictions would limit or
prevent us from meeting or maintaining the client’s investment strategy.
BMB makes investment recommendations for clients based on information the client supplies about
your financial situation, goals, and risk tolerance. Our advice may be limited if the client does not
provide us with accurate and complete information. It is the client’s responsibility to keep BMB
informed of any changes to your investment objectives or restrictions.
Wrap Fee Programs
While BMB does not manage accounts as part of a wrap or bundled fee program, some of the third-
party advisers BMB recommends may offer wrap fee programs as described above. Clients will receive
the wrap program brochure of any wrap fee program that we recommend to the client.
Assets Under Management
BMB supervises client assets on a continuous and regular basis. As of 12/31/2022, the total amount of
assets under our management was:
Discretionary Assets $ 402,790,600
Non-Discretionary Assets $ 0
Total Assets $ 402,790,600
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