A. Firm Information
Miracle Mile Advisors, LLC (“Miracle Mile Advisors” or the “Advisor”) is a registered investment advisor
with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited
Liability Company (LLC) under the laws of the State of California. Miracle Mile Advisors was founded
in May 2007 and is a wholly owned subsidiary of Miracle Mile Advisor Holdings LLC (“Miracle Mile
Advisor Holdings”). Miracle Mile Advisor Holdings, through various intermediate subsidiaries is owned
by Angels Management LLC and Corsair VI Capital Partners AIV L.P. Angels Management LLC is
primarily owned by Karp Family Holdings Corporation and Duncan E. Rolph. Karp Family Holdings
Corporation is wholly owned by the Karp Family Trust U/A 6/27/2006. Corsair VI Capital Partners AIV L.P
is primarily owned by Corsair VI Capital Partners Investors, LLC.
This Disclosure Brochure provides information regarding the qualifications, business practices, and the
advisory services provided by Miracle Mile Advisors. For additional information please contact Marla
Wooton (Chief Compliance Officer) at (310) 246-1243.
B. Advisory Services Offered
Miracle Mile Advisors offers investment advisory services, which includes investment management,
financial planning and retirement plan advisory services, to individuals, high net worth individuals,
trusts, estates, businesses, charitable organizations, insurance companies, third party broker-dealers
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. Miracle Mile Advisors’ fiduciary commitment is further
described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please
see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.
Wealth Management Services
Miracle Mile Advisors typically provides clients with comprehensive wealth management services
which generally includes financial planning and/or consulting services in conjunction with ongoing
investment management of Client Portfolios. Miracle Mile Advisors works closely with each Client to
identify their investment goals and objectives as well as risk tolerance and financial situation in order
to create a portfolio strategy.
Financial Planning and Consulting Services – Miracle Mile Advisors will typically provide a variety of
financial planning and consulting services to Clients as part of its wealth management services.
Miracle Mile Advisors may also offer financial planning and consulting services on a standalone basis
pursuant to a separate written financial planning and 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 involve preparing a formal financial plan or rendering a specific 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
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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.
Miracle Mile Advisors may also refer Clients to an accountant, attorney or other specialists, as
appropriate for their unique situation. For certain financial planning engagements, the Advisor will
provide a written summary of the 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 (6) 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.
Portfolio Management Services – Miracle Mile Advisors will typically provide portfolio management
services to Clients as part of its wealth management services. Miracle Mile Advisors may also offer
portfolio management services on a standalone basis pursuant to a separate written agreement.
Whether through wealth management or portfolio management services, Miracle Mile Advisors will
then construct an investment portfolio, consisting of low-cost, diversified mutual funds and/or
exchange-traded funds (“ETFs”), individual stocks and bonds to achieve the Client’s investment goals.
On a case-by-case basis, the Advisor may recommend the use of options, independent third-party
money managers (See Use of Independent Managers below) as well as the use of illiquid investments
such as private investment funds, hedge funds, and structured notes to meet the needs of its Clients.
The Advisor may retain certain types of investments based on a Client’s legacy investments based on
portfolio fit and/or tax considerations.
Miracle Mile Advisors’ investment strategies are 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. Miracle Mile Advisors 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.
Miracle Mile Advisors evaluates and selects investments for inclusion in Client
portfolios only after
applying its internal due diligence process. Miracle Mile Advisors may recommend, on occasion,
redistributing investment allocations to diversify the portfolio. Miracle Mile Advisors 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. Miracle Mile Advisors 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.
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At no time will Miracle Mile Advisors 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 the
designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see
Item 12 – Brokerage Practices.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA
retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the
meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal
Revenue Code (“IRC”), as applicable, which are laws governing 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 retirement account or to roll over the assets to an IRA, 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). 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.
Use of Independent Managers – When it’s deemed to be in the Client’s best interest, Miracle Mile
Advisors will recommend that Clients utilize one or more unaffiliated investment managers or
investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s
investment portfolio, based on the Client’s needs and objectives. In such instances, the Client may be
required to authorize and enter into an investment management agreement with the Independent
Manager[s] that defines the terms in which the Independent Manager[s] will provide its services. The
Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager
to ensure the strategy remains aligned with Clients’ investment objectives and overall best interests.
The Advisor will also assist the Client in the development of the initial policy recommendations and
managing the ongoing Client relationship. The Client, prior to entering into an agreement with an
Independent Manager, will be provided with the Independent Manager’s Form ADV Part 2A -
Disclosure Brochure (or a brochure that makes the appropriate disclosures).
Retirement Plan Advisory Services
Miracle Mile Advisors provides retirement plan advisory services on behalf of the retirement plans
(each a “Plan”) and the company (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 and its Plan
Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services
available include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Investment Oversight (ERISA 3(21))
• Investment Management (ERISA 3(38))
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• Provider Search
• ERISA 404(c) Assistance
• Benchmarking Services
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These services are provided by Miracle Mile Advisors 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 Miracle Mile Advisors’
fiduciary status, the specific services to be rendered and all direct and indirect compensation the
Advisor reasonably expects under the engagement.
Financial Institution Consulting Services
Miracle Mile Advisors provides investment consulting services to certain broker/dealers’ customers
(“Brokerage Customers”) who provide written consent requesting to receive the firm’s consulting
services. Brokerage Customers have entered into a written advisory agreement with Miracle Mile
Advisors.
C. Client Account Management
Prior to engaging Miracle Mile Advisors to provide investment advisory services, each Client is required
to enter into one or more agreements with the Advisor that define the terms, conditions, authority and
responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – Miracle Mile Advisors, in connection with the Client, will
develop a strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Miracle Mile Advisors will develop a strategic asset allocation that is targeted
to meet the investment objectives, time horizon, financial situation and tolerance for risk for
each Client.
• Portfolio Construction – Miracle Mile Advisors will develop a portfolio for the Client that is
intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Miracle Mile Advisors will provide investment
management and ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Miracle Mile Advisors sponsors a legacy wrap fee program but does not place any new Client assets
into the program. Depending on the level of trading required for the Client’s account[s] in a particular
year, the Client may pay more or less in total fees than if the Client paid its own transaction fees.
Please see Appendix 1 – Wrap Fee Program Brochure for additional information
E. Assets Under Management
As of December 31, 2023, Miracle Mile Advisors manages $4,895,699,621 in Client assets, all of which
are managed on a discretionary basis. Clients may request more current information at any time by
contacting the Advisor.