About MCF Advisors, LLC
MCF Advisors, LLC (the “Firm”, “we”, “us”, “our”, or “MCF”) is an investment adviser registered with the United States
Securities and Exchange Commission (“SEC”) and is a Limited Liability Company formed under the laws of Kentucky
in December 2003. MCF formally known as Mid Central Financial Advisors, Inc. has been registered as an investment
advisor since May 2000 with the State of Ohio and subsequently with the SEC since August 2003. MCF is 100%
privately owned by its employees, with David L. Harris, Jr. as the principal owner. MCF has three office locations in
the State of Kentucky. MCF also operates under the registered d/b/a MCF Institutional and d/b/a MCF.
Types of Advisory Activities
Wealth Management
MCF’s Wealth Management division serves individuals and small business clients by offering financial planning,
portfolio management for individuals and/or small businesses, selection of other advisors (including private fund
managers), bill-payment services, tax advisory and preparation, personal CFO, and business accounting, consulting
and advisory services. MCF generally offers its advisory services through a Comprehensive Wealth Management
client experience where financial planning and investment management services are delivered together. Clients may
elect to engage MCF for any of its advisory services exclusive of other services.
Financial planning services – MCF provides financial planning services to clients, which can be offered exclusive of
investment management. Clients are not required to implement any recommendations made as a result of our
financial planning and/or consulting services. The breadth of our services will vary depending on client circumstances.
Portfolio management for individuals and/or small businesses (“Investment Management”)– MCF provides
investment management services to individuals and/or small businesses. We employ a tactical asset allocation
approach to investing.
Selection of other advisors (including private fund managers) – On occasion, MCF may select Independent
Investment Managers (“Independent Managers”) to invest capital in accordance with a client’s investment objective.
MCF will assist the client with the implementation of the Independent Manager’s strategy. For clients who meet
certain asset threshold requirements, we offer access to a separately managed account program (“SMA Program”),
a fund strategist portfolios program (“FSP Program”), a unified managed account program (“UMA Program”), and
other investment vehicles, including private funds/investments, that have certain eligibility requirements. These
eligibility requirements may include minimum investment amounts and/or investor accreditation.
MCF has partnered with Tamarac, Inc. (“Tamarac”), a third-party service provider, to make available its managed
account platform (the “Envestnet Platform”) through its wholly owned affiliate and registered investment advisor
Envestnet Asset Management, Inc. (“Envestnet”). Through the Envestnet Platform, MCF can allocate a client’s assets
among its SMA Program, FSP Program, and UMA Program (collectively, the “Managed Account Programs”). Envestnet
facilitates certain operational functions for those clients utilizing a Managed Account Program(s) offered by
Envestnet, including but not limited to fee billing, portfolio reporting, account rebalancing, and trade execution, based
on instructions provided by MCF and/or the Independent Manager(s). When providing these services, Envestnet is
acting as an agent of MCF. Envestnet charges a tiered platform fee based on assets under management. As assets
on the Envestnet platform increase, the fee decreases. There is a minimum annual fee of $50 per account. The
Envestnet fees are separate from, and in addition to, MCF’s advisory fees, custodial fees and Independent Manager
fees. Additional services are available on the UMA platform for an additional fee at the client's request. Additional
services include but are not limited to tax overlay and impact overlay. We describe the fees charged for the Managed
Account Programs below under Item 5 - Fees and Compensation.
Tax return preparation and filing services – MCF provides tax return preparation services to clients for a separate
and additional fee. Services provided are the preparation and filing of individual income tax return (federal, state, and
local), trust tax returns, business tax returns, estate tax return, and gift tax returns. MCF also assists with the
preparation of estimated tax payment vouchers. Please Note: clients are not required to engage MCF for tax
services and may choose to work with any tax professional of their choosing.
Accounting and CFO services – These services are offered for a separate and additional fee. Accounting and CFO
services may include, but are not limited to bookkeeping, bank account reconciliations, income and expense
classification, bill-payment, preparation of adjusting journal entries, and financial statement preparation. The specific
scope of services to be provided and manner in which fees are charged by MCF is established in a client’s written
agreement with MCF.
As described above, we provide portfolio management services that are tailored to the specific needs of each client.
The client may, at any time, impose reasonable restrictions, in writing, on the securities in which they choose to
invest.
MCF Institutional
MCF Institutional provides portfolio management for businesses or institutional clients, portfolio management
for individuals and/or small businesses, pension consulting, and selection of other advisors (including private fund
managers) services.
Portfolio management for individuals and/or small businesses – We offer risk-based managed asset allocation
models to retirement plan participants. Through a separate and additional advisory agreement, plan participants may
engage MCF to provide discretionary investment management services to their retirement accounts.
Portfolio management for businesses (other than small businesses) or institutional clients (other than
registered investment companies and other pooled investment vehicles) – We provide discretionary money
management services to pension plans, endowments, corporations, privately-held businesses, non-profit
organizations, and insurance companies.
Pension consulting services – As an ERISA 3(21) or 3(38) investment fiduciary, we work with Plan Sponsors and
organizations to design and implement an efficient retirement plan, while providing clarity to Plan Sponsors and
organizations on their fiduciary responsibilities, as well as working to increase plan participation, provide participant
education, assess participant retirement readiness, and/or investment performance. Our services generally include
the development of an Investment Policy Statement (“IPS”), as well as ongoing monitoring and reporting.
We also offer pension consulting services on a limited consulting basis. Under this engagement scenario, the scope
of the engagement and our services will be defined under a written agreement. Services offered under this type of
engagement may include benchmarking fees and services of incumbent plan service providers, including
recordkeepers, third-party administrators, custodians, and investment advisers, best practice review of committee
governance documents, and/or review of existing investment alternatives.
Selection of other advisors (including private fund managers) – We may assist Plan Sponsors and organizations in
the selection of money managers to invest capital in accordance with their plan IPS. Additionally, we supervise,
monitor, and evaluate the selected money managers’ investment performance, risk exposure, asset class purity, peer
group rankings, and benchmark deviation.
As described above, we provide portfolio management services that are tailored to the specific needs of each client.
The client may, at any time, impose reasonable restrictions, in writing, on the securities in which they choose to
invest.
MCF does not sponsor or act as a portfolio manager for a wrap fee program.
Assets Under Management
As of 12/31/2023, MCF managed the following assets:
Type Amount ($)
Discretionary Asset Basis $ 1,988,537,412
Non-Discretionary Asset Basis $ 896,588,391
Total $ 2,885,125,803
Miscellaneous Additions
Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent
specifically requested by a client to do so, MCF shall generally provide financial planning and related consulting
services regarding non-investment related matters, such as estate planning, insurance, etc. MCF does not serve
as an attorney or insurance agency, and no portion of our services should be construed as same. Accordingly,
MCF does not prepare estate planning documents. To the extent requested by a client, we may recommend the
services of other professionals and/or service providers for certain non-investment implementation purpose (i.e.
attorneys, accountants, etc.) including MCF’s representatives in their separate individual capacities as licensed
insurance agents. The client is under no obligation to engage the services of any such recommended professional.
The client retains absolute discretion over all such implementation decisions and is free to accept or reject any
recommendation from MCF and/or its representatives. Please Note: If the client engages any recommended
unaffiliated professional and/or service providers, and a dispute arises thereafter relative to such engagement, the
client agrees to seek recourse exclusively from and against the engaged professional and/or service providers.
Please Also Note-Conflict of Interest: The recommendation by MCF that a client purchase an insurance
commission product from an MCF representative in his/her individual capacity as an insurance agent, presents a
conflict of interest, as the receipt of commissions provides an incentive to recommend insurance products based
on commissions to be received, rather than on a particular client’s need. No client is under any obligation to
purchase any insurance commission products from MCF’s representatives. Clients are reminded that they are free
to purchase insurance products recommended by MCF through other, non-affiliated insurance agents. MCF’s
Chief Compliance Officer, Timothy Gavin, remains available to address any questions that a client or prospective
client may have regarding the above conflict of interest.
Unaffiliated Private Investment Funds. MCF also provides investment advice regarding unaffiliated private
investment funds. MCF, on a non-discretionary basis, at times, recommends that certain qualified clients consider
an investment in unaffiliated private investment funds. MCF’s role relative to the private investment funds shall be
limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become
a private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under
management” for purposes of MCF calculating its investment advisory fee. MCF’s clients are under absolutely no
obligation to consider or make an investment in a private investment fund(s).
Please Note-Private Investment Funds: Private investment funds generally involve various risk factors, including,
but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete
discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review
and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily
liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement,
pursuant to which the client shall establish that he/she is qualified for investment in the fund and acknowledges
and accepts the various risk factors that are associated with such an investment.
Please Note-Valuation. In the event that MCF references private investment funds owned by the client on any
supplemental account reports prepared by MCF, the value(s) for all private investment funds owned by the client
shall reflect the most recent valuation provided by the fund sponsor. If no subsequent valuation post-purchase is
provided by the Fund Sponsor, then the valuation shall reflect the initial purchase price (and/or a value as of a
previous date), or the current value(s) (either the initial purchase price and/or the most recent valuation provided
by the fund sponsor). If the valuation reflects initial purchase price (and/or
a value as of a previous date), the
current value(s) (to the extent ascertainable) could be significantly more or less than the original purchase price.
The client’s advisory fee shall be based upon reflected fund value(s).
Please Note-Use of Mutual Funds: Most mutual funds are available directly to the public. Thus, a prospective client
can obtain many of the mutual funds that might be recommended and/or utilized by MCF independent of engaging
MCF as an investment advisor. However, if a prospective client determines to do so, he/she will not receive MCF’s
initial and ongoing investment advisory services.
Please Note-Retirement Rollovers-Conflict of Interest: 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);
• 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.
A client or prospective client 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) roll over 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). In the event MCF recommends that a client roll over their retirement
plan assets into an account to be managed by MCF, such a recommendation creates a conflict of interest if MCF
will earn an advisory fee on the rolled over assets. When acting in such capacity, MCF serves as a fiduciary under
the Employee Retirement Income Security Act (ERISA).
There is a conflict of interest when an MCF representative makes a recommendation that a participant roll over
assets from a retirement account into a new or existing account or investment (e.g. rollover IRA) managed by
MCF. The conflict of interest exists because MCF will receive compensation (e.g., management fees) if the money
is rolled over, but it will not if the recommendation is not accepted.
No client is under any obligation to rollover retirement plan assets to an account managed by MCF. MCF’s Chief
Compliance Officer, Timothy Gavin remains available to address any questions that a client or prospective client
may have regarding the potential for conflict of interest presented by such rollover recommendation.
ERISA PLAN ENGAGEMENTS: The Firm may be engaged to provide discretionary investment advisory services to
ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with the investment objective
designated by the Plan sponsor. In such engagements, the Firm will serve as an investment fiduciary as that term
is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”) and referenced in the rollover
section above. The Firm will generally provide services on an “assets under management” fee basis per the terms
and conditions of an Investment Advisory Agreement between the Plan and the Firm.
Participant Directed Retirement Plans. MCF provides investment advisory and consulting services to participant
directed retirement plans per the terms and conditions of a Fiduciary Consulting Agreement between MCF and
the plan. For such engagements, MCF shall assist the Plan Sponsor with the selection of an investment platform
from which Plan participants shall make their respective investment choices, and, to the extent engaged to do so,
also provide corresponding education to assist the participants with their decision-making process. Such
engagements present a conflict of interest if a plan participant chooses an investment option (asset allocation
models) devised and managed by MCF, as more specifically disclosed in the Plan and participant enrollment
documents and investment platform/service provider web site. MCF generally earns an additional fee for its asset
allocation models. As a result, MCF has an economic incentive to recommend that plan participants utilize MCF
models rather than other available non-MCF model plan investment options, thereby presenting a conflict of
interest.
Please Note-Liquidity Constraints. MCF may utilize mutual funds and/or exchange traded funds that provide for
limited liquidity, generally on a quarterly basis. Thus, if we determined that the fund was no longer performing or
if you ever determined to transfer your account, the Fund could not be sold or transferred immediately. Rather,
sale or transfer would need to await the quarterly permitted sale date. Moreover, the eventual net asset value for
the Fund could be substantially different (positive or negative) than the Fund value on the date that the sale was
requested. There can be no assurance that any such strategy will prove profitable or successful. In light of these
enhanced risks/rewards, a client may direct MCF, in writing, not to employ any or all such strategies for the client’s
account.
Client Obligations. In performing our services, MCF shall not be required to verify any information received from
the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client
is advised that it remains his/her/its responsibility to promptly notify us if there is ever any change in his/her/its
financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous
recommendations and/or services.
Please Note-Investment Risk. Different types of investments involve varying degrees of risk, and it should not be
assumed that future performance of any specific investment or investment strategy (including the investments
and/or investment strategies recommended or undertaken by MCF) will be profitable or equal any specific
performance level(s).
Schwab Institutional Intelligent PortfoliosTM Platform. Within our Wealth Management services described above,
we offer, but do not require clients as a condition to hire us, an automated investment program (the “Program”)
through which clients are invested in a range of investment strategies we have constructed and manage, each
consisting of a portfolio of exchange-traded funds (“Funds”) and a cash allocation. The client may instruct us to
exclude up to three Funds from their portfolio. The client’s portfolio is held in a brokerage account opened by the
client at Charles Schwab & Co., Inc. (“CS&Co”). We use the Institutional Intelligent Portfolios® platform (“Platform”),
offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors
and an affiliate of CS&Co., to operate the Program. We are independent of and not owned by, affiliated with, or
sponsored or supervised by SPT, CS&Co., or their affiliates (together, “Schwab”). MCF, and not Schwab, is the
client’s investment advisor and primary point of contact with respect to the Program. We are solely responsible,
and Schwab is not responsible, for determining the appropriateness of the Program for the client, choosing a
suitable investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio
on an ongoing basis. We have contracted with SPT to provide us with the Platform, which consists of technology
and related trading and account management services for the Program. The Platform enables us to make the
Program available to clients online and includes a system that automates certain key parts of our investment
process (the “System”). Based on information the client provides to us, we will recommend a portfolio via the
System. The client may then indicate an interest in a portfolio that is one level less or more conservative or
aggressive than the recommended portfolio, but we then make the final decision and select a portfolio based on
all the information we have about the client. The System also includes an automated investment engine through
which we manage the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting
(if the client is eligible and elects).
We charge clients a fee for our services as described below under Item 5 Fees and Compensation, Fee Schedule.
Our fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to
CS&Co. as part of the Program. Schwab does receive other revenues, including (i) the profit earned by Charles
Schwab Bank, a Schwab affiliate, on the allocation to the Schwab Intelligent Portfolios Sweep Program described
in the Schwab Intelligent Portfolios Sweep Program Disclosure Statement; (ii) investment advisory and/or
administrative service fees (or unitary fees) received by Charles Schwab Investment Management, Inc., a Schwab
affiliate, from Schwab ETFs™ Schwab Funds® and Laudus Funds® that we select to buy and hold in the client’s
brokerage account; and (iii) remuneration Schwab receives from the market centers where it routes ETF trade
orders for execution.
We do not pay SPT fees for the Platform so long as we maintain $100 million in client assets in accounts at CS&Co.
that are not enrolled in the Program. If we do not meet this condition, then we pay SPT an annual licensing fee of
0.10% (10 basis points) on the value of our clients’ assets in the Program. This fee arrangement gives us an
incentive to recommend or require that our clients with accounts not enrolled in the Program be maintained with
CS&Co. As of the date of this brochure, MCF maintains more than $100 million in client assets at CS&Co. Please
Note: Effective January 1, 2022 in an effort to provide a higher level of client service, MCF is no longer recommending
the Schwab Institutional Intelligent PortfoliosTM Platform for client accounts and is in process of phasing out the use
of this platform for client accounts.
Management of Held Away Assets. MCF has contracted with Pontera to facilitate account aggregation and
investment management services for accounts held away from our primary custodial affiliations. The Pontera
platform allows us to avoid being considered to have custody of client funds since we do not have direct access to
client login credentials to affect trades. A link will be provided to the client allowing them to connect an account(s)
to the platform.
MCF has also contracted with Morningstar® ByAllAccounts® (“BAA”) to facilitate account aggregation and
investment management services for held away assets that may not otherwise be supported by the Pontera
platform. When we utilize the BAA software to aggregate client account data, we will be deemed to have custody
of your assets, in the event we maintain access to your client login credentials, to affect trades in your held away
account.
The client’s individual investment strategy for held away assets is tailored to their specific needs and may include
some or all of the securities made available through the held away account’s custodian. Client portfolios will be
designed to meet a particular investment goal, determined to be suitable to the client’s circumstances, often in
coordination with all the client’s assets under management at MCF. Once the appropriate portfolio has been
determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced. We are not affiliated
with Pontera or BAA in any way and receive no compensation from them for using their platforms.
MCF shall not be responsible for, and it shall remain the client’s exclusive obligation to maintain updated login
credentials and to notify us of any changes that would impact our ability to discharge our duties. We charge clients
a fee for our services as described below within Item 5 Fees and Compensation, Fee Schedule. Clients do not pay
any other fees to Pontera or BAA.