A. MB, Levis & Associates, LLC (hereafter, “MB, Levis,” “we,” or “us”) is a limited
liability company formed in 2012 in the Commonwealth of Pennsylvania. MB, Levis’s
principal owner is J. Bruce Levis, Jr.
B.
INVESTMENT MANAGEMENT SERVICES
You can determine to engage our firm to provide discretionary investment advisory
services on a fee only basis. Our annual investment advisory fee is based upon a
percentage (%) of the market value of the assets placed under our management, generally
between negotiable and 1.00%.
Our annual investment advisory fee shall include investment advisory services, and, to
the extent specifically requested by you, financial planning and consulting services. In the
event that you require extraordinary planning and/or consultation services (to be
determined in our sole discretion), we may determine to charge for such additional
services, the dollar amount of which shall be set forth in a separate written notice to you.
MISCELLANEOUS
Non-Investment Consulting/Implementation Services. Neither we, nor any of our
representatives serves as an attorney, accountant, or licensed insurance agent, and no
portion of our services should be construed otherwise. To the extent requested by you, we
may recommend the services of other professionals for certain non-investment
implementation purposes (i.e., attorneys, accountants, insurance agents, etc.). You are
under no obligation to engage the services of any such recommended professional. You
retain absolute discretion over all such implementation decisions and are free to accept or
reject any recommendation from us.
If you engage any such recommended professional, and a dispute arises thereafter relative
to such engagement, you agree to seek recourse exclusively from and against the engaged
professional. It remains your responsibility to promptly notify us if there is ever any
change in your financial situation or investment objectives for the purpose of
reviewing/evaluating/ revising our previous recommendations and/or services.
Retirement Rollovers-Potential for Conflict 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). If we recommend that a client roll over their
retirement plan assets into an account to be managed by us, such a recommendation
creates a conflict of interest if we will earn new (or increase its current) compensation as
a result of the rollover. If we provide a recommendation as to whether a client should
engage in a rollover or not, we would be acting as a fiduciary 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. No client is under any
obligation to roll over retirement plan assets to an account managed by us.
Cash Positions. We continue to treat cash as an asset class. As such, unless determined
to the contrary by the Firm, all cash positions (money markets, etc.) shall continue to be
included as part of assets under management for purposes of calculating our advisory
fee. At any specific point in time, depending upon perceived or anticipated market
conditions/events (there being no guarantee that such anticipated market
conditions/events will occur), we may maintain cash positions for defensive purposes. In
addition, while assets are maintained in cash, such amounts could miss market advances.
Depending upon current yields, at any point in time, our advisory fee could exceed the
interest paid by the
client’s money market fund.
Availability of Mutual Funds. While we may allocate investment assets to mutual funds
that are not available directly to the public, we may also allocate investment assets to
publicly available mutual funds that the client could purchase without engaging the Firm
as an investment adviser. However, if a client or prospective client determines to
purchase publicly available mutual funds without engaging us as an investment adviser,
the client or prospective client would not receive the benefit of our initial and ongoing
investment advisory services with respect to management of the asset.
Portfolio Activity. We have a fiduciary duty to provide services consistent with the
client’s best interest. We will review client portfolios on an ongoing basis to determine if
any changes are necessary based upon various factors, including, but not limited to,
investment performance, market conditions, fund manager tenure, style drift, account
additions or withdrawals, and/or a change in the client’s investment objective. Based
upon these factors, there may be extended periods of time when We determine that
changes to a client’s portfolio are neither necessary, nor prudent. Clients remain subject
to the fees described in Item 5 below during periods of account inactivity.
Asset Aggregation / Reporting Services. In conjunction with the services currently
provided by ByAllAccounts, Inc. or Akoya, we may provide access to reporting services
that can reflect all of the client’s investment assets, including those investment assets that
are not part of the assets managed by the Firm (the “Excluded Assets”). Our service
relative to the Excluded Assets is limited to reporting service access only, which does not
include investment implementation. Because we do not have trading authority for the
Excluded Assets, the client (and/or another investment professional), shall be exclusively
responsible for directly implementing any recommendations relative to the Excluded
Assets. Further, the client and/or their other advisors that maintain trading authority, shall
be exclusively responsible for the investment performance or related activity (such as
timing and trade errors) pertaining to the Excluded Assets. The third-party reporting
platform may also provide access to financial planning information and applications,
which should not be construed as services, advice, or recommendations provided by us.
Accordingly, we shall not be held responsible for any adverse results a client may
experience if the client engages in financial planning or other functions available on the
third-party reporting platform without our participation or oversight.
Client Obligations. In performing our services, we will not be required to verify any
information received from you or from your other professionals, and we are expressly
authorized to rely thereon. Moreover, you are advised that it remains your responsibility
to promptly notify us if there is ever any change in your financial situation or investment
objectives for the purpose of reviewing/evaluating/revising our previous
recommendations and/or services.
Disclosure Statement. A copy of our written Brochure and Client Relationship
Summary, as set forth on Part 2A of Form ADV and Form CRS, respectively, shall be
provided to you prior to, or along with, the execution of the Investment Advisory
Agreement.
C. We will provide investment advisory services specific to your needs. Prior to providing
investment advisory services, we will ascertain your investment objective(s). Thereafter,
we will allocate and/or recommend that you allocate investment assets consistent with
your designated investment objective(s). You may, at any time, impose reasonable
restrictions, in writing, on our services.
D. We do not participate in a wrap fee program.
E. As of December 31, 2023, we had $349,621,078 in discretionary assets under
management.