of the Plan; act with the care, skill, prudence, and diligence that a prudent man
would use in the same situation; diversify Plan investments to reduce the risks of large losses unless it is
clearly prudent not to do so; and act according to the terms of the Plan documents, to the extent the
documents are consistent with ERISA.
Use of Alternative Investments
To investors for whom an alternative investment is suitable, we will recommend investment in one or
more alternative investment vehicles including, but not limited to, hedge funds, private equity funds, and
private debt/credit investments. A recommendation to invest in such an alternative investment vehicle is
done so on a non-discretionary basis. This means that even if we recommend an alternative investment,
you are not required to make such investment and any investment will only be made upon your execution
of subscription or other documents (“Offering Documents”) admitting you as an investor.
To invest in an alternative investment vehicle, you will be required to meet strict suitability criteria with
regards to your net worth, liquid net worth, income and other applicable requirements. You will receive
disclosure documents for each fund in which you are interested in investing. It is important that you read
2024-03-27 Form ADV Part 2A Page 6 of 23
the disclosure documents and ask us if you have any questions prior to investing. See Items 5, 7 and 8 for
additional information regarding our recommendation of alternative investments.
Use of Independent Managers
At times, MKD will select or recommend that you select certain Independent Managers to actively
manage a portion of your assets. This generally includes recommending equity or fixed income managers
but may include Independent Managers in other strategies
. The specific terms and conditions under which
you engage an Independent Manager are either in a separate written agreement with the designated
Independent Manager or alternatively are in a sub-advisory agreement between MKD and the
Independent Manager as permitted by your Advisory Agreement with MKD. In addition to our Disclosure
Brochure, you will receive the Independent Manager’s written disclosure documents either from us or
from the Independent Manager directly.
MKD evaluates a variety of information about Independent Managers, which may include the
Independent Managers’ public disclosure documents and materials supplied by the Independent Managers
themselves. To the extent possible, we seek to assess the Independent Managers’ investment strategies,
past performance and risk results in relation to its clients’ individual portfolio allocations and risk
exposure. We also take into consideration each Independent Manager’s management style, returns,
reputation, financial strength, reporting, pricing and research capabilities, among other factors.
On an ongoing basis, MKD monitors the performance of client accounts being managed by Independent
Managers. We seek to ensure the Independent Managers’ strategies and target allocations remain aligned
with client investment objectives and overall best interests.
IRA Rollover Recommendations
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.
We benefit financially from the rollover of your assets from a retirement account that we do not manage
on your behalf to an account that we manage or provide investment advice, because the assets increase
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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.
Additional resources about IRA Rollovers are available to investors through the website of the Financial
Industry Regulatory Authority (“FINRA”) at
www.finra.org.
Assets Under Management
We manage client assets on both a discretionary and non-discretionary basis, and as of December 31,
2023, we had $347,943,505 in client assets managed on a discretionary basis and $11,818,890 in client
assets managed on a non-discretionary basis.