MWM is a SEC-registered investment adviser with its principal place of business located in Durango,
Colorado. MWM began conducting business as a registered investment adviser in 2008.
Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25%
or more of this company):
• David S. McAlvany, General Partner
• David S. McAlvany Irrevocable Trust, Limited Partner
MWM offers Individual Portfolio Management, Money Manager Search and Monitoring services to its
advisory clients. MWM also sponsors educational seminars that are open to clients and the public. Please
see the disclosure below in this Item for additional information regarding these services.
As of December 31, 2023, MWM was managing $88,866,698 of client assets on a discretionary basis and
$3,065,503 of client assets on a non-discretionary basis.
MWM also offers a Short Selling Strategy and a Tactical Negatively Correlated Strategy to clients when
appropriate to the client’s individual situation and tolerance for risk. Information about those strategies is
available in a separate Form ADV Part 2A brochure for each, which is available upon request.
INDIVIDUAL PORTFOLIO MANAGEMENT
MWM offers portfolio management services to its advisory clients on a separately managed account basis.
We will provide continuous advice to a client regarding the investment of client funds based on the client’s
individual needs. Through personal discussions with our clients, we develop a client's personal investment
policy. We then create and manage a portfolio based on that policy. During this data-gathering process,
we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. We may
also review and discuss a client’s prior investment history, as well as family composition and background.
We currently offer our portfolio management services on a discretionary basis only. Account supervision
is guided by the client's stated objectives (e.g., growth, income or a balance between growth and income),
as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities,
types of securities, or industry sectors.
Our investment recommendations are not limited to any specific product or service offered by a broker
dealer or insurance company. Our client portfolios will consist primarily of the following: stocks, options,
bonds and other fixed income securities, exchange-traded funds (“ETFs”), and no-load mutual funds.
Client portfolios may also include limited partnerships, private placement partnerships, and precious
metals. Because some types of investments involve certain additional degrees of risk, they will only be
implemented/recommended when consistent with the client's stated investment objectives, tolerance for
risk, liquidity and suitability.
MONEY MANAGER SEARCH AND MONITORING
We may also perform management searches of various independent registered investment advisers, on
behalf of a client. Based on a client's individual circumstances and needs, we will determine which
independent adviser's portfolio management is appropriate
for that client. Factors considered in making
this determination include account size, risk tolerance, the opinion of each client and the investment
philosophy of the independent adviser.
Clients should refer to the independent adviser's Firm Brochure (Form ADV Part 2) for a full description
of the services offered.
We will meet with the client at least annually to review the account. If we believe that an independent
adviser is performing inadequately, or if we believe that a different manager is more suitable for a client's
particular needs, then we will suggest that the client contract with a different adviser. Under this scenario,
we will assist the client in selecting a new adviser, and then monitor that adviser's performance. However,
any move to a new manager is solely at the discretion of the client.
SEMINARS
MWM sponsors educational seminars on various investment topics including technical portfolio analysis.
The investment information provided under this service does not purport to meet the objectives or needs
of each individual client. The seminars will provide participants with discussions on asset allocation
strategies, estate and retirement planning, and general educational topics. Our seminars are open to the
public.
ERISA FIDUCIARY
Retirement Rollovers: The Department of Labor’s Prohibited Transaction Rule 3.0 establishes that
advice to rollover or transfer an account is fiduciary advice even though the prospect is not a client.
ERISA fiduciaries are subject to the prohibited transaction rules, primarily 2020-02 which prohibits self-
dealing. The Prohibited Transaction Rule 3.0 requires four elements of disclosure:
1. Affirmation of ERISA fiduciary duty
2. Description of services to be provided
3. Disclosure of material conflicts of interest
4. Explanation of the reasons for the recommendation and how it is in the Retirement Investor's
best interest
Before making a recommendation to execute a rollover, MWM will consider the following factors when
evaluating whether a rollover is in the best interest of our client: the alternatives to a rollover including
leaving the money in the plan or account type, comparative fees or expenses, whether an employer or
other party pays for some or all administrative expenses. Depending on the circumstances, MWM may
identify other factors relevant to this analysis as well. McAlvany Wealth Management, LLC has and always
will act as a fiduciary for clients and prospective clients when reviewing a retirement rollover or transfer
of account.
Information related to tax and legal consequences that is provided as part of the financial plan is
for informative purposes only and should not be considered tax or legal advice. Clients should
contact their tax and/or legal advisor for personalized advice.
Wrap Fee Programs. MWM does not participate in any wrap fee programs.
Important Note: It is the Client’s responsibility to ensure that MWM is promptly notified if there are ever
any significant changes to their financial situation, goals, objectives or needs so we can review our previous
recommendations and make any necessary adjustments.