Trademark Financial Management, LLC (“Trademark”) has been operating as an investment
adviser since 2000. Trademark’s managing member, Mark Carlton is the principal owner and
has been active in the industry since 1986. Trademark offers personalized investment advisory
services to individuals, retirement and profit-sharing plans, trusts, estates, charitable
organizations, corporations, and on occasion to other investment advisers. Trademark is a
fiduciary and is required to act in a client’s best interest at all times.
Asset Management Programs
Trademark manages portfolios using a tactical asset allocation approach on a discretionary
basis, and, occasionally, on a non-discretionary basis. Portfolio management services are
provided on a continuous basis where the investment advice is tailored to meet the needs and
investment objectives of the client. The proportion of bond and stock funds in a portfolio, the
volatility of the portfolio, the decision whether to use sector funds, and the cash balance of the
portfolio is determined by the risk tolerance of the investor. Subject to any written guidelines,
which the client may provide, Trademark is granted full discretion and authority to manage the
account. Accordingly, Trademark is authorized to perform various functions, at the client's
expense, without further approval from the client. Such functions include the determination of
securities to be purchased/sold, as well as the amount of securities to be purchased/sold. Once
the portfolio is constructed, Trademark provides continuous supervision and re-optimization of
the portfolio as changes in market conditions and client circumstances may require. Where
Trademark enters into non-discretionary arrangements with clients, Trademark will obtain client
approval prior to the execution of a trade. It is the client's responsibility to notify Trademark of
any change in financial status or personal data as it occurs.
Advisory Consulting Services
Trademark offers consulting related services that may include, but are not limited to, portfolio
reviews, investment analysis, and/or asset allocation modeling. Such services are “one time
only” engagements and are not considered by Trademark to be “on-going.” Fees associated
with such services are based on Trademark's hourly rate of $175. Trademark may also perform
the contracted services for an agreed upon
fixed fee or retainer basis, which is based on an
estimate of the number of hours required to complete the contracted services. The final fee
shall be clearly set forth in the executed agreement for services signed by both Trademark and
the client. In limited circumstances, the cost/time could potentially exceed the initial estimate.
In such cases, Trademark will notify the client and may request that the client pay an additional
fee. All such fees are payable in arrears upon completion of services rendered. Under no
circumstances will Trademark require prepayment of a fee more than six months in advance and
in excess of $1,200.
Services for Other Investment Advisers
Trademark manages portfolios for other registered investment advisers pursuant to advisory
agreements. Terms of the services provided, the fees to be charged, and other penalties or
termination provisions are subject to negotiation between both advisers and will be outlined in
the final agreement. Occasionally, Trademark may provide portfolio consulting for other
investment advisers at a rate of $175 per hour.
Types of Investments
Trademark typically provides investment advice on mutual fund shares, insurance products
(including variable annuities and life insurance) and ETFs (exchange-traded funds). Trademark
may also provide investment advice on exchange listed securities, securities traded over-the-
5 of 22
counter, foreign issues, certificates of deposit, REITs (real estate investment trusts), oil and gas
interests, and any type of investment held in a client’s portfolio at the inception of the advisory
relationship. This may not be an all-inclusive list.
General Information
All Asset Management Services may be provided on a discretionary or nondiscretionary basis by
Trademark. Discretion means the trading activity within the Client’s account(s) may be entered
by Trademark without receiving prior authorization for each trade. This discretion is authorized
by the Client in writing (upon signing the specific Management Program Agreement) and may be
revoked at any time by submitting a written request to Trademark. In most cases, discretion will
be utilized. As of December 31, 2023, $250,208,252 of assets under management is managed on
a discretionary basis. The Client will receive confirmations and statements showing all trading
activity in the account(s).