Mutual of Omaha Investor Services, Inc. (“MOIS”, “Mutual of Omaha Financial
Advisors”, “we”, or “us”), became a registered investment adviser (“RIA”) in 2002. MOIS
is wholly owned by Mutual of Omaha Holdings, Inc., a Nebraska corporation. Our
Investment Advisor Representatives (“Advisors”) may use the name Mutual of
Omaha Financial Advisors, a marketing name for MOIS.
INTRODUCTION
The investment advisory services of MOIS are provided to you through an
appropriately licensed and qualified individual who is an Advisor of MOIS (referred
to as your Advisor or Investment Advisor Representative throughout this brochure).
Your Advisor is limited to providing services and charging investment advisory fees
in accordance with the descriptions detailed in this brochure. However, your Advisor
may be allowed to set advisory fees within the ranges described in this brochure. As
a result, the rates actually charged by two different Advisors of MOIS may vary for
similar services. The exact services you receive and the fees you will be charged will
be specified in your advisory services agreement.
ADVISORY SERVICES AND SERVICES OVERVIEW
We offer advisory programs and services to help you in the pursuit of your financial
goals. These advisory programs include our Mutually Focused and Mutually
Managed Programs and Retirement Plan Services. The services provided under each
of these programs include:
Mutually Focused Program
• Financial Planning
• Ongoing Financial Planning Support Services
• Financial Plan Reviews
• Financial Consulting
Mutually Managed Program
• Third-Party Money Manager Relationships
• MOIS Managed Account Services
Retirement Plan Services
• Retirement Plan Consulting Services
• Retirement Plan Advisory Services
Description of Advisory Services
The following are descriptions of the primary advisory services of MOIS. Please
understand that a written agreement, which details the exact terms of the service,
must be signed by you and MOIS before we can provide you the services described
below.
MUTUALLY FOCUSED PROGRAM
Financial Planning
We offer a wide range of financial planning services depending on your needs and
requirements. Advisors develop plans for your specific circumstances, taking into
account your current financial situation, anticipated changes, and financial goals. The
plan may focus on specific goals or be more comprehensive. Generally, the more
detailed and complex the plan, the greater the cost is to you. We typically use
financial planning software to assist in the analysis.
The focus of a financial plan can vary. For example, you may choose a comprehensive
analysis which might include:
• accumulation planning
• college planning
• debt (e.g., home mortgage)
• estate analysis
• income and asset protection
• income replacement analysis
• portfolio analysis (e.g., asset allocation)
• qualified plan distributions
• retirement planning
• survivor needs analysis
Or, you may choose more limited financial planning services.
Business oriented financial planning generally focuses on managing risks and
providing employee benefits, which may involve payment for individual employee
financial planning services. It can include analyzing financial data and recommending
ways to pursue financial goals. Private businesses may require special planning
needs such as:
• transferring ownership when the owner dies, retires, or becomes disabled
• dealing with the loss in value to the business when a key employee dies
• providing certain employee benefits to retain key employees
• transition of a retirement plan to a new platform provider
Your Advisor may present you with specific recommendations based on the plan.
Specific recommendations may include an asset allocation or risk management
strategy. Under a new agreement subject to additional fees or commissions, we can
help you implement some or all of the recommendations, or you can choose to work
with one of our affiliates or any other financial institution that is qualified to make or
implement specific investment recommendations.
If you subsequently purchase an investment, insurance, or other financial product
through us or any of our affiliates, we, or our affiliates, may receive an additional fee
or commission. A portion of that fee or commission will be paid to your Advisor in
his or her capacity as an agent, registered representative or investment adviser
representative. If you choose to purchase products or services and implement the
financial plan through a non-affiliated advisor, agent, registered representative or a
financial institution, we, or our affiliates, will not receive additional compensation. If
you choose another financial institution, you should consult them about their fees
and charges.
Generally, preparing and delivering a financial plan is a one-time service and does
not involve an ongoing relationship between you and your Advisor. We will typically
complete your plan within six months after you sign the advisory services
agreement. After we deliver your financial plan, your financial planning advisory
relationship with us and your Advisor ends. We will not automatically monitor or
update the plan. If you use our services after you receive your plan for plan updates
or additional investment assistance, these services will involve a separate written
agreement between you and us. At no time will your Advisor require payment of
more than $1,200 in fees more than six months in advance of services rendered.
Ongoing Financial Planning Support
MOIS offers ongoing financial planning support for a monthly or quarterly fee.
Ongoing financial planning support generally involves multiple meetings (in-person
or via phone) with your Advisor relating to your specific financial situation. Your
Advisor will initially gather information relating to your financial needs, goals, and
anticipated changes. During ongoing meetings, your Advisor will continue to discuss
your financial situation and provide ongoing financial advice. Ongoing financial
planning support also involves the generation of a financial plan, which establishes
the foundation for the ongoing support. You may be provided with online access to
financial planning software to utilize various electronic tools and provide input
regarding your financial situation. In addition, ongoing financial planning support
may offer access to a data aggregation system to assist with effective monitoring of
your financial accounts. You will receive ongoing communication from MOIS or your
Advisor such as newsletters, teleconferences, quarterly updates, and other
communications relating to financial topics.
Ongoing financial planning support fees generally range from $25 to $300 per month
or $75 to $900 per quarter for services provided to individuals. For ongoing
financial planning support services provided to businesses, the fees generally range
from $25 to $2,000 per month or $75 to $6,000 per quarter. The cost of the services
will vary based on services available to you and the complexity of your financial
situation. Ongoing financial planning fees are charged in arrears on a monthly or
quarterly basis as specified in your financial planning agreement.
Ongoing financial planning support services will continue until terminated by either
party. MOIS may terminate your ongoing financial planning arrangement at any time
based on the Firm’s oversight of the planning support provided by your Advisor. No
fees will be charged after the termination of the ongoing financial plan.
Financial Plan Reviews
By its nature, the analysis conducted in conjunction with a financial plan is specific to
a particular point in time. We recommend that you review your financial situation
regularly, in particular when financial or life conditions change. We will not
automatically monitor or update your financial plan. At your request, your Advisor
may review changes in your financial situation that have occurred to determine if
there have been changes to your financial goals. After we provide recommendations
in connection with your financial plan review, your financial planning relationship
with MOIS and your Advisor ends. Your Advisor will typically complete the review
within six months after you sign the advisory services agreement.
Financial Consulting
We also offer financial consultations in order to discuss financial planning topics. In
the event that you do not need a comprehensive written financial plan, MOIS offers
one-time financial consultations, which may cover mutually agreed upon topics
related to investments or financial planning. We also offer “as-needed” financial
consultations, which relate to particular investment or financial planning topics.
Financial consultation services may consist of a review of new or existing issues that
may have an impact on your financial situation, which may include:
• income or asset protection
• cash flow and budgeting
• retirement, investment, social security, education, or business planning
After we deliver the financial consultation recommendations, your financial
consulting advisory relationship with MOIS and your Advisor ends. We will not
automatically monitor or update your situation. Your Advisor will typically complete
the consultation within six months after you sign the investment services agreement.
MUTUALLY MANAGED PROGRAM
Third-Party Money Manager Relationships
MOIS offers advisory services through co-advisory and promoter arrangements with
unaffiliated third-party money managers offering asset management and other
investment advisory services. The third-party managers are responsible for the
continuous and regular supervisory or management services for client accounts and
making trades in client accounts when necessary. As a result of the co-advisory and
promoter arrangements, we are paid a portion of the fee charged and collected by
the third-party money managers. Each arrangement is performed pursuant to a
written agreement and each co-advisory or promoter arrangement is in compliance
with SEC Regulations and applicable state securities rules and regulations.
Under this program, your Advisor will assist you with identifying your risk tolerance
and investment objectives. Your Advisor recommends third-party money managers
in relation to your stated investment objectives and risk tolerance, and you may
select a recommended third-party money manager or model portfolio based upon
your needs. You must enter into agreements with MOIS and the third-party money
manager for asset management services under this program. MOIS may assign or re-
assign, at its discretion, an Advisor of record to your account to provide services on
behalf of MOIS.
Your Advisor is available to answer questions that you may have regarding your
account and act as the communication conduit between you and the third-party
money manager. The third-party money manager may use discretionary authority to
determine the securities to be purchased and sold for your account. Your Advisor
and MOIS do not have discretionary authority with respect to your account managed
by the third-party money manager. MOIS enters into only a select number of
relationships with third-party investment adviser firms that have agreed to pay us a
portion of the overall fee charged to our clients. Therefore, MOIS has a conflict of
interest in that it will only recommend third-party investment advisers that are
available on the firm’s platform. This is a conflict of interest because we do not
recommend portfolios, model providers, strategies, or products that are not
approved or available through MOIS.
There may be other third-party managed programs not recommended by our firm
that are suitable for you and that may be less costly than arrangements
recommended by our firm. No guarantees can be made that your financial goals or
objectives will be achieved by a third-party investment adviser recommended by our
firm. Further, no guarantees of performance can ever be offered by our firm.
We will not enter into an investment advisory relationship with you if your stated
investment objectives are incompatible with our investment philosophy or strategies
or if you seek to impose unduly restrictive investment guidelines. Following are
descriptions of the types of third-party money manager programs offered by MOIS.
Mutual Fund and Exchange Traded Fund Asset Allocation Programs
We offer mutual fund and exchange traded fund (“ETF”) asset allocation
programs through these third-party money manager relationships. Typically,
assets are allocated among institutional, no-load, and load-waived mutual
funds or ETFs in an account established for you. After your investment goals
are identified, the unaffiliated RIA recommends a particular asset allocation of
mutual funds or ETFs and manages the portfolio on a discretionary basis.
We offer access to asset allocation programs offered by:
• AssetMark, Inc. (“AssetMark”)
• Brinker Capital, Inc. (“Brinker”)
• Hanlon Investment Management, Inc. (“Hanlon”)
• Morningstar Investment Services, Inc. (“Morningstar”)
When our Advisor presents you with an asset allocation program offered by
one of the third-party managers, you will receive a copy of that manager’s
Form ADV Part 2A, detailing its investment programs. We recommend that
you review this information carefully before you invest in any of the programs.
Separately Managed Accounts
In separately managed accounts (“SMAs”), you have access to actively managed
investment portfolios managed by independent investment management firms.
The unaffiliated third-party manager either screens and selects independent
investment management firms with varying styles and recommends a
particular manager(s) based on your needs and goals, or manages the
investments through its own investment management team. SMAs are
designed to provide you with the ability to design an investment portfolio to
your specific financial needs. An SMA is a portfolio of individually owned
securities that can be tailored to fit your investing preferences. The selected
money managers execute transactions on a discretionary basis in securities
consistent with your strategy. This means the investment manager determines
the investments and makes trades without first notifying you. The third party
money manager will monitor the performance of the investment managers and
provide you with varying services that may include, but not be limited to:
administrative services, trading, quarterly reporting, ongoing manager due
diligence, and investment strategy recommendations.
SMAs offer varying asset allocation and risk management approaches designed
to meet your needs. SMAs are offered through:
• AssetMark
• Brinker
• Hanlon
• Morningstar
When you are presented with an SMA option, you will receive a copy of the
unaffiliated money manager’s Form ADV Part 2A, detailing its investment
programs. We recommend that you review this information before you invest
in any program.
Unified Managed Accounts
Unified managed accounts ("UMAs") provide access to multiple investment
strategies through multiple money managers in a single account. An
unaffiliated third-party manager selects a sub-manager or overlay manager,
who is responsible for managing the asset allocation of the account on a
discretionary basis and coordinating the trading across investments.
Investments will be made by using securities recommendations of
independent
investment management firms with knowledge in specific asset
classes, consistent with your strategy.
UMAs offer varying asset allocation and risk management approaches designed
to meet your needs. UMAs are offered through:
• AssetMark
• Brinker
When you are presented with a UMA option, you will receive a copy of the
unaffiliated RIA's Form ADV Part 2A, detailing its investment programs. We
recommend that you review this information before you invest in any
program.
MOIS Managed Account Services
Under this program sponsored by MOIS, you will engage MOIS to provide Managed
Account Services to a specific account or group of accounts mutually designed by you
and MOIS (“Account”). MOIS may assign or re-assign, at its discretion, an Advisor of
record to assist in providing Managed Account Services on behalf of MOIS.
The Account will consist of a separate account(s) through MOIS as the introducing
broker-dealer and held by a qualified custodian under your name. The qualified
custodian will maintain physical custody of all funds and securities of the Account.
You will retain all rights of ownership for the Account, including but not limited to
the right to withdraw securities or cash, exercise or delegate proxy voting, and
receive transaction confirmations. At least quarterly, you will receive an account
statement from the qualified custodian of the Account detailing transactions in the
Account.
MOIS has entered into an agreement with a third-party platform provider, Envestnet
Asset Management, Inc. (“Envestnet” or “Platform Manager”), which is an SEC
registered investment adviser and provides investment advisory, administrative and
technology services.
Your Advisor will assist you in completing a questionnaire to gather personal
financial information from you. Based on your Advisor’s review of the information
you provide, your Advisor will provide investment recommendations to you.
Your Advisor is generally only able to recommend portfolios, model providers,
strategies, and products which have been approved by MOIS. This is a conflict of
interest because we do not recommend portfolios, model providers, strategies, or
products that are not approved or available through MOIS.
MOIS may hire/fire at its discretion the Platform Manager and other service
provider(s) for services related to the Managed Account Services provided to the
Account. Such services provided by Platform Manager and service provider(s) may
include, but are not necessarily limited to:
• access to service provider’s technology platform and/or assistance with data
reconciliation, performance and/or position reporting
• database maintenance
• due diligence of the Model Providers
• fee calculation and billing
• marketing and presentation materials
• order entry
• quarterly performance evaluations
• website administration
Due to these arrangements, such service provider(s) will have access to the Account
and/or your information.
MOIS Managed Account Services are described below.
Fund Strategist Portfolios
Fund Strategist Portfolio (“FSP”) Accounts will be invested in (i) mutual funds
and/or exchange-traded funds (“ETFs”) managed by the Platform Manager
using one or more investment models available under the Program that were
created by one or more independent investment advisers (the “Model
Providers”) (the “Investment Models Program Assets”); or (ii) PMC Select
Portfolios, (“PMC Select Portfolios”), a series of portfolios comprised
predominately of Platform Manager’s proprietary sub-advised mutual funds or
ETFs (“PMC Funds”). Pershing, LLC (“Pershing”) is the qualified custodian for
FSP accounts.
The Platform Manager for these services will conduct due diligence of any
recommended Model Provider and monitor the performance of the Model
Provider’s models and/or trade signals relative to appropriate peers and/or
benchmarks. Multiple Model Provider selections are available. You may
contact your Advisor or MOIS for details regarding the available Model
Provider selections. The Model Provider is responsible for the continuous and
regular supervisory or management services for client accounts and making
trades in client accounts when necessary.
The Platform Manager will implement the selected Model Provider’s model for
the Account by acquiring the fund shares or investments that are represented
in the selected model portfolios of the Model Provider. You will grant the
Platform Manager with the discretionary authority to make all decisions to
buy, sell or hold securities, cash or other investments for such portion of the
Account, without first consulting with you. You will also grant the Platform
Manager with the power and authority to carry out these decisions by giving
instructions, on behalf of you, to brokers and dealers and the qualified
custodian of the Account.
MOIS Advisor as Portfolio Manager Services
MOIS Advisor as Portfolio Manager (“APM”) Accounts are managed by an MOIS
Advisor based on the financial information and investment objectives you
provide. Your Advisor will recommend an investment model based on your
risk profile. Your APM Account may be invested in mutual funds, exchange-
traded funds (“ETFs”), equities, fixed income securities or variable annuity
sub-accounts.
APM Accounts are managed by an MOIS Advisor on a discretionary basis. You
will be required to sign a written discretionary trading authorization providing
an MOIS Advisor with the authority to make decisions to buy, sell or hold
securities, cash or other investments in your account. In no event will an MOIS
Advisor or MOIS be obligated to affect any transaction for you that they believe
would be in violation of state or federal law, rule or regulation or any
regulatory or self-regulating body rule or regulation. Discretionary trading
authority will remain in effect until your account is closed.
APM mutual fund, equity, exchange-traded fund and fixed income securities
transactions are processed by MOIS, who is also a FINRA-registered broker-
dealer. Pershing, LLC (“Pershing”) is the qualified custodian for these APM
accounts.
We have also entered into agreements with insurance companies that allow for
the management and valuation of variable annuity accounts within the APM
program. The insurance companies’ custodians maintain custody of variable
annuity accounts. APM variable annuity transactions may be processed by the
insurance company’s custodian or through the Platform Manager’s electronic
transaction processing system.
Separately Managed Accounts
SMAs offer access to actively managed investment portfolios managed by
various Model Providers within the Envestnet platform. The Platform
Manager screens and selects SMA Model Providers with varying styles. SMAs
are designed to provide you with the ability to design an investment portfolio
to your specific financial needs. An SMA is a portfolio of individually owned
securities that can be tailored to fit your investing preferences. The selected
Model Providers execute discretionary transactions (i.e., the Model Provider
determines the investments and makes trades without first notifying you) in
individual securities consistent with your strategy. The Platform Manager will
monitor the investment managers' performance and may provide you with
varying services that may include, but not be limited to: administrative
services, trading, quarterly reporting, ongoing manager due diligence, and
investment strategy recommendations. The Model Provider is responsible for
the continuous and regular supervisory or management services for client
accounts.
When you are presented with an SMA option, you will receive copies of the
Model Provider’s Form ADV Part 2A, detailing their investment programs. We
recommend that you review this information before you invest in any SMA.
You may contact your Advisor or MOIS for details regarding the available
SMAs.
Unified Managed Accounts
UMAs provide access to multiple investment strategies through multiple Model
Providers in a single Account. Various asset classes may be represented in a
single UMA Account, which facilitates diversification based on the Client’s
investment profile. The UMA program utilizes the Program Manager as an
overlay portfolio manager, whose role includes managing the asset allocation
of the account on a discretionary basis and coordinating trading across
investments. Your Advisor will structure the account based on your stated
goals and objectives. The Model Provider is responsible for the continuous and
regular supervisory or management services for client accounts.
When you are presented with a UMA option, you will receive copies of the
Model Providers’ Forms ADV Part 2A, detailing their investment programs. We
recommend that you review this information before you invest in any UMA
program. You may contact your Advisor or MOIS for details regarding the
available UMAs.
RETIREMENT PLAN SERVICES
MOIS offers consulting and advisory services to Qualified Retirement Plans
(“Retirement Plans”). Retirement plan services offered by MOIS may include one or
more of the following services:
• benchmarking
• default investment alternative advice
• individualized participant advice
• investment due diligence review
• investment monitoring
• investment selection services
• non-discretionary investment advice
• participant education
• participant enrollment
• qualified retirement plan development
• retirement plan review
As an investment adviser, MOIS is considered to be a fiduciary under the Investment
Advisers Act of 1940. In addition, certain services provided to Retirement Plans are
considered to be fiduciary as defined under Section 3(21)(A)(ii) of the Employee
Retirement Income Security Act of 1974 (“ERISA”). MOIS will act in a manner
consistent with the requirements of a fiduciary under ERISA for all services for which
MOIS is considered a fiduciary under ERISA. In providing retirement plan services
for Retirement Plans, MOIS (a) has no responsibility and will not (i) exercise any
discretionary authority or discretionary control respecting management of a
Retirement Plan, (ii) exercise any authority or control respecting management or
disposition of assets of a Retirement Plan, or (iii) have any discretionary authority or
discretionary responsibility in the administration of a Retirement Plan or the
interpretation of retirement plan documents, (b) is not an “investment manager” as
defined in Section 3(38) of ERISA and does not have the power to manage, acquire or
dispose of any plan assets, and (c) is not the “Administrator” of a Retirement Plan as
defined in ERISA.
MOIS Retirement Plan Services are described below.
Retirement Plan Consulting Services
MOIS offers consulting services to Retirement Plans for a monthly or quarterly fee.
Retirement Plan Consulting Services generally involve multiple meetings between
the Advisor and fiduciary for the Retirement Plan or their appointed representative
(“Authorized Individual”) to gather documents and information, discuss the
Retirement Plan’s needs, and provide ongoing services to the Retirement Plan.
Retirement Plan Consulting Services generally involve ongoing meetings or
discussions between the Advisor and the Authorized Individual regarding the
Retirement Plan’s specific situation.
Fees for Retirement Plan Consulting Services generally range from $25 to $2,000 per
month or $75 to $6,000 per quarter. The cost of the services will vary based on
services available to you and the complexity of your financial situation. Fees are
charged in arrears on a monthly or quarterly basis as specified in your Retirement
Plan Consulting agreement. MOIS will not assess a separate fee for services provided
to individual plan participants.
The Advisor may present specific recommendations to the Retirement Plan. Under a
new agreement subject to additional fees or commissions, the Advisor and MOIS may
help to implement some or all of the recommendations, which may involve the
purchase of an investment, insurance, or other financial product.
If the recommendation(s) results in the purchase of an investment, insurance, or
other financial product through us or any of our affiliates, we, or our affiliates, may
receive an additional fee or commission. A portion of that fee or commission will be
paid to the Advisor for the Retirement Plan in his or her capacity as an agent,
registered representative or investment adviser representative. If the Advisor’s
recommendation(s) results in the purchase products or services through a non-
affiliated advisor, agent, registered representative or a financial institution, we, or
our affiliates, will not receive additional compensation. If products or services are
provided to the Retirement Plan by financial institution, the Authorized Individual
should consult them about their fees and charges.
Retirement Plan Consulting Services will continue until terminated by either party.
MOIS may terminate these services at any time based on the Firm’s oversight of the
support provided by the Advisor. No fees will be charged after the termination of
the Retirement Plan Consulting Services agreement.
Retirement Plan Advisory Services
MOIS offers Retirement Plan Advisory Services to Retirement Plans through
arrangements with unaffiliated RIAs, through group variable annuities, or through
other retirement plan providers. Retirement plan services are provided by affiliated
and unaffiliated companies. Services provided by your advisor include, but may not
be limited to, guidance regarding the selection of a service provider for the platform
of investment options offered to participants under the plan. Upon request, your
Advisor may also provide services and information to help plan sponsors educate
plan participants on investment options and monitor the performance of investment
options.
Following are descriptions of Retirement Plan Advisory Services offered through
third-party money managers, group variable annuities, and other retirement plan
platforms.
Third-Party Money Managers
Unaffiliated RIAs receive compensation for services provided under the
program as a percentage of assets invested in their programs. These RIAs
typically pay a portion of the advisory services fees to us for services we
provide. You will also pay a separate fee to the administrator for its
recordkeeping and administrative services.
Group Variable Annuities
MOIS offers advisory services through group variable annuities underwritten
by affiliated or unaffiliated insurance companies. The insurance companies
typically pay a portion of advisory services fees to us for services we provide.
You will also pay a separate fee to the administrator for its recordkeeping and
administrative services.
Other Retirement Plan Providers
MOIS offers access to other retirement plans through affiliated or unaffiliated
companies. Retirement plan providers offer a variety of services, including but
not limited to technology and support services, retirement plan
administration, brokerage, advisory, custody services, and access to a variety
of investment options. These providers pay a portion of fees to us for services
provided. In addition, you will pay a separate fee to the administrators for
various services, which may include, but may not be limited to, trust custody
fees, investment fiduciary services, and administrative fees.
ASSETS UNDER MANAGEMENT
As of December 31, 2023, $15,498,267.16 assets are managed by the firm.