A. Firm Information
Marino, Stram & Associates, LLC d/b/a MSA Financial (“MSA Financial” or the “Advisor”) is a registered
investment advisor with the U.S. Securities Exchange Commission (“SEC”). The Advisor is organized as a limited
liability company (“LLC”) under the laws of the Commonwealth of Massachusetts. In 1997 Richard E. Stram and
Paul M. Marino co-founded MSA Financial and chose to affiliate with Securities America, Inc., an independent
broker-dealer. MSA Financial became an LLC in Massachusetts on January 1, 2010 and in June 2011 MSA
Financial became a registered investment advisor with the SEC in order to achieve a greater degree of
independence and operational efficiency.
MSA Financial is owned and operated by Richard E. Stram (Financial Advisor, Managing Director and Chief
Compliance Officer), Paul M. Marino (Managing Director and Financial Advisor), Michael P. Cammarata
(Financial Advisor, Partner) and Ryan A. Zimmerman (Financial Advisor, Partner). This Disclosure Brochure
provides information regarding the qualifications, business practices, and the advisory services provided by MSA
Financial.
B. Advisory Services Offered
MSA Financial offers investment advisory services to individuals, high net worth individuals, trusts, estates,
business entities, and retirement plans (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. MSA Financial’s fiduciary commitment is further described in the Advisor’s Code of Ethics.
For more information regarding our Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest
in Client Transactions and Personal Trading.
Investment Management Services
MSA Financial provides customized investment advisory solutions for its Clients. This is achieved through
continuous personal Client contact and interaction while providing discretionary and non-discretionary investment
management and consulting services. The Advisor’s services are always provided based on the individual needs
of each Client. This means, for example, that the Client is given the ability to impose restrictions on their
account[s], including restricting specific investment selections and sectors. MSA Financial works with the Client
on a one-on-one basis through interviews and questionnaires to determine the investment objectives and
suitability information of the Client. MSA Financial will then implement a strategy, consisting of diversified mutual
funds, variable annuities certificates of deposit (“CDs”), United States government securities and/or exchange-
traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks and
bonds to meet the needs of its Clients. The Advisor may also retain certain legacy investments based on portfolio
fit and/or tax considerations.
MSA Financial’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. MSA Financial will construct, implement and monitor the portfolio to ensure it meets the goals,
objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to
place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to
acceptance by the Advisor.
MSA Financial evaluates and selects investments for inclusion in Client portfolios only after applying its internal
due diligence process. MSA Financial may recommend, on occasion, redistributing investment allocations to
diversify the portfolio. MSA Financial may recommend specific positions to increase sector or asset class
weightings. The Advisor may recommend employing cash positions as a possible hedge against market
movement. MSA Financial may recommend selling positions for reasons that include, but are not limited to,
harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities,
overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating
cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
Page 5
At no time will MSA Financial accept or maintain custody of a Client’s funds or securities, except for the limited
authority as outlined in item 15 – Custody. All Client assets will be managed within their designated account[s] at
the Custodian, pursuant to the terms of the advisory agreement. For additional information, please see Item 12 –
Brokerage Practices.
Retirement Accounts – When deemed to be in the Client’s best interest, the Advisor will provide investment
advice to a Client regarding a distribution from an ERISA sponsored plan or to roll over the assets to an
Individual Retirement Accounts (“IRAs”), or recommend a similar transaction including rollovers from one ERISA
sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g.
commission-based account to fee-based account). In such instances, the Advisor will serve as an investment
fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”) and/or
the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Such a
recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee
as a result of the transaction. No client is under any obligation to roll over a retirement account to an account
managed by the Advisor.
Non-Purpose Loans – When deemed to be in the Client’s best interest, the Advisor will introduce Clients to
Goldman Sachs Private Bank Select, a non-purpose loan program available through Goldman Sachs Bank USA
(“Lending Program”). In such instances, the Client’s assets in their account[s] at the Custodian will be utilized as
collateral for a non-purpose loan. The recommendation of a Lending Program presents a conflict of interest as
the Advisor will continue to receive investment advisory fees for managing the collateralized assets in the Client’s
account[s]. Clients are not obligated to engage the Advisor for the Lending Program. For additional information
related to the risks involved non-purpose loans, please see Item 8 – Methods of Analysis, Investment Strategies
and Risk of Loss.
Managed Account Programs – When deemed to be in the Client’s best interest, MSA Financial will recommend to
Clients that all or a portion of their portfolio be implemented by utilizing one or more unaffiliated money managers
participating in a managed accounts program at the Client's Custodian (the “Program Sponsor”). The Client will
then enter into a program and investment advisory agreement with the Program Sponsor and the participating
money manager[s]. The Advisor will assist and advise the Client in establishing investment objectives for the
account, the selection of the money manager[s], and defining any restrictions on the account. MSA Financial will
continue to provide oversight of the Client’s account[s] and ongoing monitoring of the activities of the unaffiliated
money managers.
These
money managers will develop an investment strategy to meet those objectives by identifying appropriate
investments and monitoring such investments. In consideration for such services, the Program Sponsor will
charge a program fee that includes the investment advisory fee of the money managers, the administration of the
program and trading, clearance and settlement costs. The Program Sponsor will add MSA Financial‘s investment
advisory fee (described below in Item 5) and will deduct the overall fee from the Client’s account[s], generally at
the start of each calendar quarter. The asset-based program fee is tiered and varies depending on the size of the
account, the asset class of the underlying securities and the sub-advisor selected. The overall fee (including the
Advisor's investment advisory fee) will not exceed 3% annually.
MSA Financial may receive monetary compensation from these unaffiliated money managers or the Program
Sponsor, other than MSA Financial’s investment advisory fee, as described in Item 5 below. The additional
compensation comes in the form of flights or hotels for meetings.
The Client, prior to entering into an agreement with a Program Sponsor, will be provided with the Program
Sponsor's Form ADV Part 2A (or a brochure that makes the appropriate disclosures). In addition, MSA Financial
and its Client will agree in writing that that selected Program Sponsor will manage the Client's account[s] on a
discretionary basis.
Retirement Plan Advisory Services
Page 6
MSA provides advisory services to retirement plans (each a “Plan”) and the company sponsor (the “Plan
Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its
fiduciary obligations to the Plan. Each engagement is customized to the needs of the Plan and Plan Sponsor.
Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Investment Oversight Services (ERISA 3(21))
• Investment Management Services (ERISA 3(38))
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
• Benchmarking Services
Certain of these services are provided by MSA serving in the capacity as a fiduciary under the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2),
the Plan Sponsor is provided with a written description of MSA’s fiduciary status, the specific services to be
rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement.
Financial Planning and Consulting Services
MSA Financial will typically provide a variety of financial planning or consulting services to Clients, either as a
component of investment management or pursuant to a written Financial Planning or Consulting Agreement.
Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives.
Generally, such financial planning services will involve preparing a financial plan or rendering a financial
consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass
one or more areas of need, including, but not limited to investment planning, retirement planning, personal
savings, education savings, insurance needs, and other areas of a Client’s financial situation.
A financial plan developed for or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs. MSA Financial may also refer
Clients to an accountant, attorney or another specialist, as appropriate for their unique situation. For certain
financial planning engagements, the Advisor will provide a written summary of Client’s financial situation,
observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a
written summary. Plans or consultations are typically completed within six months of contract date, assuming all
information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor
for investment management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects
to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
C. Client Account Management
Prior to engaging MSA Financial to provide investment advisory services, each Client is required to enter into
one or more agreements with the Advisor and that define the terms, conditions, authority and responsibilities of
the parties. These services may include:
• Establishing an Investment Strategy – MSA Financial, in connection with the Client, will develop a
strategy that seeks to achieve the Client’s investment goals and objectives.
Page 7
• Asset Allocation – MSA Financial will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and tolerance for risk of each Client.
• Portfolio Construction – MSA Financial will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
• Investment Management and Supervision – MSA Financial will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
MSA Financial does not sponsor a wrap fee program in connection with their investment management services.
However, the Managed Opportunities Program offered by Securities America and certain Managed Account
programs are wrap fee programs. A wrap fee program is defined as any advisory program under which a
specified fee or fees not based directly upon transactions in a Client’s account is charged for investment advisory
services (which may include portfolio management or advice concerning the selection of other investment
advisers) and the execution of Client transactions. Whenever a fee is charged to a Client for services described
in this brochure (whether wrap fee or non-wrap fee), the Advisor will receive all or a portion of the fee charged.
A complete description of these programs and related fees, charges, when due and termination procedures are
described in the respective managers disclosure brochures, which you receive at or prior to the time a third-party
managed account is established.
E. Assets Under Management
As of December 31, 2022, MSA Financial manages $870,408,679 in Client assets, $869,974,861 of which is
managed on a discretionary basis and $433,817 on a non-discretionary basis. Clients may request more current
information at any time by contacting the Advisor.