A. Firm Information
Market Street Wealth Management, LLC (“MSWM” or the “Advisor”) is a registered investment advisor with the
U.S. Securities and Exchange Commission (“SEC”). MSWM is organized as a Limited Liability Company (“LLC”)
under the laws of the Commonwealth of Pennsylvania. MSWM was founded in September 2010 and is owned
and by Market Street Financial Group, LLC, which is owned by its founding members, Jeffrey Leppert, Mark
Meloro, and Kevin Holt. This Disclosure Brochure provides information regarding the qualifications, business
practices, and the advisory services provided by MSWM.
The Advisor serves as a fiduciary to Clients, as defined under 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. Our fiduciary commitment is further described in our 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.
B. Advisory Services Offered
MSWM offers investment advisory services primarily to individuals and high net worth individuals (each referred
to as a “Client”).
Investment Management Services
MSWM 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. MSWM works 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. MSWM will then
construct a portfolio, consisting of diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve
the Client’s investment goals. The Advisor may also utilize individual stocks, individual bonds and other types of
investments, as appropriate, to meet the needs of particular Clients.
MSWM’s investment strategy is primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held less than one year to meet the objectives of the Client or due to market
conditions. MSWM 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.
MSWM evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. MSWM may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. MSWM 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. MSWM 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 Client, generating cash to meet Client needs, or any
risk deemed unacceptable for the Client’s risk tolerance.
MSWM also provides discretionary investment management services through an automated, online investment
management program (the “Program”). The Program is made available through the Fidelity Automated
Managed Platform, a managed account platform made available to clients of Fidelity through its independently
operated affiliate, eMoney Advisor, LLC.
MSWM is the client’s investment advisor and primary point of contact with respect to the Program. We are solely
responsible for determining the appropriateness of the Program for the client, choosing a suitable investment
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strategy and investment model(s) for the client’s investment needs and goals, and providing ongoing review and
monitoring of the client’s asset allocation among the various investment models made available.
During enrollment in the Program, the client will provide information about a variety of factors and will be asked
a series of questions regarding the client’s financial situation, investment objectives, risk tolerance and planned
investment time horizon. MSWM will then recommend an appropriate investment model(s) and risk profile
based upon the client’s individual circumstances.
The investment model(s) to which Program assets are allocated are managed by Geode Capital Management,
LLC (“Geode”), an unaffiliated registered investment adviser. Geode is not responsible for gathering client
information and determining or assisting Clients in selecting the appropriate Model. Clients do not pay fees to
Geode in connection with the Program, but we charge clients a fee for our services as described below under
Item 5 Fees and Compensation. Program clients do not pay brokerage commissions or any other fees to Fidelity
or its affiliate, National Financial Services, LLC, in connection with the Program.
Use of Independent Managers
MSWM may recommend and refer Clients that all or a portion of their portfolio be implemented by utilizing one
or more unaffiliated money managers or investment advisors (herein “Independent Manager[s]”). Through these
arrangements, the Client will either enter into an advisory agreement with that Independent Manager to which
that Independent Manager will assist and advise the Client in establishing investment objectives and develop an
investment strategy to meet those objectives by identifying appropriate investments and monitoring such
investments, or in other situations MSWM will oversee the assets with the Independent Manager and maintain
involvement in the management of the Client’s assets. The terms and agreements with the Independent
Manager[s] will differ and are set forth in the agreement[s] with those manager[s]. The Independent Manager[s]
will have investment discretion over the Client’s account[s], but may allow the Client to impose reasonable
investment restrictions. The Advisor will assist and advise the Client in establishing investment objectives for
their account[s], the selection of the Independent Manager[s], and defining any restrictions on the account[s].
The Client, prior to entering into an agreement with unaffiliated money manager[s] or investment advisor[s], will
be provided with the advisor's Form ADV 2 (or a brochure that makes the appropriate disclosures).
Please Note. The investment management fee charged by the Independent Manager[s] is separate from, and in
addition to, MSWM’s investment advisory fee disclosed at Item 5 below. ANY QUESTIONS: MSMW’s Chief
Compliance Officer remains available to address any questions that a client or prospective client may have
regarding the allocation of account assets to an Independent Manager(s), including the specific additional fee to
be charged by such Independent Manager(s).
Financial Planning Services
MSWM will typically provide a variety of financial planning services to Clients, pursuant to a written financial
planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their
goals, objectives and financial situation. 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. MSWM 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.
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MSWM also offers a financial planning and consulting service specifically designed to address the unique
needs of younger investors. In addition to the preparation of a financial plan, this service also includes regular
meetings with the client to track the client’s progress towards their financial goals and to update and revise
financial goals, objectives, and action steps on a regular basis. This service can also include access to data
aggregation tools to allow the client to view all of their assets in one setting, a client website that will also track
budgeting, a client vault to store documents, overall asset allocation recommendations for any client assets,
student loan and debt advice, and insurance and benefits advice.
Financial planning and consulting recommendations may pose a potential conflict between the interests of the
Advisor and the interests of the Client. For example, a recommendation to engage the Advisor for investment
management services or to increase the level of investment assets with the Advisor would pose a conflict, as it
would increase the 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.
Retirement Plan Advisory Services
MSWM, in conjunction with Plan Confidence Corporation, an unaffiliated registered investment adviser, can
provide investment advice on a co-advisory basis with respect to client assets held in a retirement plan qualified
under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). Such advice includes
periodic allocation and investment recommendations delivered electronically. Neither MSWM nor Plan
Confidence Corporation provides ongoing management of the individual plan participant’s account. Under this
program, MSWM will review each plan participant’s financial situation, risk tolerance, and investment objectives,
and recommend an appropriate allocation model. Plan Confidence will offer specific allocation recommendations
based on the model selected and the available investments within the plan. Plan participants are solely
responsible for placing any and all transactions.
A complete description of Plan Confidence Corporation’s services is described in their Form ADV Part 2A
Disclosure Brochure. MSWM acts as a co-adviser with Plan Confidence Corporation and provides advice to
clients, assists clients in determining the suitability of the Plan Confidence™ services for their accounts, and
assists clients in establishing and maintaining Plan Confidence™ services accounts.
Miscellaneous Disclosures
Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the
extent requested by the client, MSWM will generally provide financial planning and related consulting services
regarding non-investment related matters, such as tax and estate planning, insurance, etc. MSWM will
generally provide such consulting services inclusive of its advisory fee set forth at Item 5 below (exceptions may
occur based upon assets under management, special projects, etc. for which MSWM may charge a separate
fee, or require a stand-alone financial planning engagement for a separate fee). Please Note: MSWM does not
serve as an attorney or accountant, or insurance agency. Accordingly, MSWM does not prepare estate planning
or any type of legal documents or tax returns, nor does it sell insurance products. To the extent requested by a
client, MSWM will recommend the services of other professionals for certain non-investment implementation
purpose (i.e. attorneys, accountants, insurance, etc.), including: (1) representatives of MSWM in their separate
individual capacities as representatives of USA Financial Securities ("USA Financial”), an SEC registered and
FINRA member broker-dealer; (2) representatives of MSWM in their separate individual capacities as licensed
insurance agents, including as agents of the MSWM’s affiliated licensed insurance agencies, Market Street
Insurance Services, LLC and Market Street Financial Group, LLC; and (3) MSWM’s affiliated tax preparation
firm, Market Street Tax Services, LLC. The commission compensation earned by our insurance affiliate and its
agents is separate from, and in addition to, MSWM’s investment advisory fee. The client is under no obligation
to engage the services of any such recommended professional or entity. The client retains absolute discretion
over all such implementation decisions and is free to accept or reject any recommendation from MSWM and/or
its representatives. Please Note: If the client engages any professional or entity, recommended or otherwise,
and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from
the engaged professional or entity. At all times, the engaged licensed professional(s) and entity(ies), and not
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MSWM, shall be responsible for the quality and competency of the services provided. Please Also Note-
Conflicts of Interest: The recommendation by a MSWM representative that a client purchase a securities or
insurance commission product from a MSWM representative or Insurance, or engage Tax for tax preparation
services, presents a conflict of interest, as the compensation to be received by a representative or affiliated
entity from such sale/service may provide an incentive to recommend such investment or insurance product,
and/or tax preparation services. No client is under any obligation to purchase any securities, insurance, or tax
preparation products or services from a MSWM representative or affiliated entity. Clients are reminded that they
may purchase such products and/or services that may be recommended by MSWM through other, non-affiliated
registered representatives, insurance agents, and tax preparers. ANY QUESTIONS: MSWM’s Chief
Compliance Officer, Kevin Holt, remains available to address any questions that a client or prospective client
may have regarding the above conflicts of interest.
Please Note: MSWM, in its sole discretion, and based upon various factors, may make Market Street Tax
Services, LLC professional services available to certain clients for a reduced fee, or no additional fee. The
determination by MSWM to offer this discounted service through its affiliate may be based on such factors as
the size and nature of the client relationship, or the length of time that the client worked with MSWM. MSWM is
under no obligation to reduce or eliminate the affiliate tax service fee and this fee is separate from the client’s
advisory fee.
Please Note: Retirement Rollovers – No Obligation / 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 MSWM recommends that a client roll over their retirement plan assets
into an account to be managed by MSWM, such a recommendation creates a conflict of interest if MSWM will
earn a new (or increase its current) compensation as a result of the rollover. If MSWM provides a
recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan
or an existing IRA), MSWM is 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
MSWM, whether it is from an employer’s plan or an existing IRA. MSWM’s Chief Compliance Officer, Kevin
Holt, remains available to address any questions that a client or prospective client may have regarding the
potential for conflict of interest presented by such rollover recommendation.
Custodian Charges-Additional Fees. As discussed below at Item 12 below, when requested to recommend a
broker-dealer/custodian for client accounts, MSWM generally recommends that
Fidelity serve as the broker-
dealer/custodian for client investment management assets. Broker-dealers such as
Fidelity
charge brokerage
commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e.,
including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income
transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as
well as the amount of those fees) shall differ depending upon the broker-dealer/custodian (while certain
custodians, including
Fidelity, do not currently charge fees on individual equity transactions, others do).
Please Note: there can be no assurance that
Fidelity will not change its transaction fee pricing in the future.
Please Also Note:
Fidelity may also assess fees to clients who elect to receive trade confirmations and
account statements by regular mail rather than electronically. When beneficial to the client, individual fixed‐
income and/or equity transactions may be effected through broker‐dealers with whom MSWM and/or the client
have entered into arrangements for prime brokerage clearing services, including effecting certain client
transactions through other SEC registered and FINRA member broker‐dealers (in which event, the client
generally will incur both the transaction fee charged by the executing broker‐dealer and a “trade-away” fee
charged by
Fidelity). These fees/charges are in addition to MSWM’s investment advisory fee at Item 5 below.
MSWM does not receive any portion of these fees/charges.
Unaffiliated Private Investment Funds. MSWM also provides investment advice regarding private investment
funds. MSWM, on a non-discretionary basis, may recommend that certain qualified clients consider an
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investment in private investment funds, the description of which (the terms, conditions, risks, conflicts and fees,
including incentive compensation) is set forth in the fund’s offering documents. MSWM’s role relative to
unaffiliated private investment funds shall be limited to its initial and ongoing due diligence and investment
monitoring services. If a client determines to become an unaffiliated private fund investor, the amount of assets
invested in the fund(s) shall be included as part of “assets under management” for purposes of MSWM
calculating its investment advisory fee. MSWM’s fee shall be in addition to the fund’s fees. MSWM’s clients are
under absolutely no obligation to consider or make an investment in any private investment fund(s).
Please Note: Private investment funds generally involve various risk factors, including, but not limited to,
potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of
which is set forth in each fund’s offering documents, which will be provided to each client for review and
consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily
liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement,
pursuant to which the client shall establish that he/she is qualified for investment in the fund, and acknowledges
and accepts the various risk factors that are associated with such an investment.
Please Also Note: Valuation. In the event that MSWM references private investment funds owned by the client
on any supplemental account reports prepared by MSWM, the value(s) for all private investment funds owned
by the client shall reflect the most recent valuation provided by the fund sponsor. However, if subsequent to
purchase, the fund has not provided an updated valuation, the valuation shall reflect the initial purchase price. If
subsequent to purchase, the fund provides an updated valuation, then the statement will reflect that updated
value. The updated value will continue to be reflected on the report until the fund provides a further updated
value. Please Also Note: As result of the valuation process, if the valuation reflects initial purchase price or an
updated value subsequent to purchase price, the current value(s) of an investor’s fund holding(s) could be
significantly more or less than the value reflected on the report. Unless otherwise indicated, MSWM shall
calculate its fee based upon the latest value provided by the fund sponsor.
Cash Sweep Accounts. Cash Sweep Accounts. Account custodians generally require that cash proceeds
from account transactions or cash deposits be swept into and/or initially maintained in the custodian’s sweep
account. The yield on the sweep account is generally lower than those available in money market accounts. To
help mitigate this issue, Registrant shall generally purchase a higher yielding money market fund available on
the custodian’s platform with cash proceeds or deposits, unless Registrant reasonably anticipates that it will
utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the
client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash
balances for various reasons, including, but not limited to, the amount of dispersion between the sweep account
and a money market fund, the size of the cash balance, an indication from the client of an imminent need for
such cash, or the client has a demonstrated history of writing checks from the account.
Please Note: The above does not apply to the cash component maintained within the Registrant’s actively
managed investment strategy (the cash balances for which shall generally remain in the custodian designated
cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an
unaffiliated investment manager, and cash balances maintained for fee billing purposes. Please Also Note: The
client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding
transactions for cash balances maintained in any of the Registrant’s unmanaged accounts.
Cybersecurity Risk. The information technology systems and networks that MSWM and its third-party service
providers use to provide services to MSWM’s clients employ various controls, which are designed to prevent
cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions
in MSWM’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public
personal information. Clients and MSWM are nonetheless subject to the risk of cybersecurity incidents that could
ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to
respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or
interruption to systems. Although MSWM has established its processes to reduce the risk of cybersecurity
incidents, there is no guarantee that these efforts will always be successful, especially considering that MSWM
does not directly control the cybersecurity measures and policies employed by third-party service providers.
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Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect
issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other
regulatory authorities, exchange and other financial market operators, or other financial institutions.
Cryptocurrency: MSWM typically does not recommend investments in cryptocurrency. For clients who want
exposure to cryptocurrencies, including Bitcoin, MSWM will advise the client to consider a potential investment
in corresponding exchange traded securities, or an allocation to separate account managers and/or private
funds that provide cryptocurrency exposure. Crypto is a digital currency that can be used to buy goods and
services, but uses an online ledger with strong cryptography (i.e., a method of protecting information and
communications through the use of codes) to secure online transactions. Unlike conventional currencies issued
by a monetary authority, cryptocurrencies are generally not controlled or regulated and their price is determined
by the supply and demand of their market. Because cryptocurrency is currently considered to be a speculative
investment, MSWM will not exercise discretionary authority to purchase a cryptocurrency investment for client
accounts. Rather, a client must expressly authorize the purchase of the cryptocurrency investment. Please
Note: MSWM does not recommend or advocate the purchase of, or investment in, cryptocurrencies. MSWM
considers such an investment to be speculative. Please Also Note: Clients who authorize the purchase of a
cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility
and complete loss of principal.
Please Note-Use of Mutual and Exchange Traded Funds: Most mutual funds and exchange traded funds are
available directly to the public. Thus, a prospective client can obtain many of the funds that may be utilized by
MSWM independent of engaging MSWM as an investment advisor. However, if a prospective client determines
to do so, he/she will not receive MSWM’s initial and ongoing investment advisory services. Please Note: In
addition to MSWM’s investment advisory fee described below, and transaction and/or custodial fees discussed
below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed
at the fund level (e.g. management fees and other fund expenses). ANY QUESTIONS: MSWM’s Chief
Compliance Officer, Kevin Holt, remains available to address any questions that a client or prospective client
may have regarding the above.
Cash Positions. MSWM continues to treat cash as an asset class. As such, unless determined to the contrary
by MSWM, all cash positions (money markets, etc.) shall continue to be included as part of assets under
management for purposes of calculating MSWM’s 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), MSWM 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, MSWM’s advisory fee could exceed the interest paid by the client’s money market fund.
ANY QUESTIONS: MSWM’s Chief Compliance Officer, Kevin Holt, remains available to address any questions
that a client or prospective may have regarding the above fee billing practice.
Independent Managers. MSWM may allocate a portion of a client’s investment assets among unaffiliated
independent investment managers in accordance with the client’s designated investment objective(s). In such
situations, the Independent Manager[s] shall have day-to- day responsibility for the active discretionary
management of the allocated assets. MSWM shall continue to render investment supervisory services to the
client relative to the ongoing monitoring and review of account performance, asset allocation and client
investment objectives. Factors that MSWM shall consider in recommending Independent Manager[s] include
the client’s designated investment objective(s), management style, performance, reputation, financial strength,
reporting, pricing, and research. Please Note: Additional Fee. The investment management fee charged by the
Independent Manager is separate from, and in addition to, MSWM’s investment advisory fee as set forth in the
fee schedule at Item 5 below. Please Also Note: MSWM may also recommend that the engage an Independent
Manager on a referral fee compensation basis. By so doing, the client shall separately engage the Independent
Manager, and the Independent Manager shall compensate MSWM with a portion of the advisory fee paid by the
client to the Independent Manager. ANY QUESTIONS: MSWM’s Chief Compliance Officer, Kevin Holt, remains
available to address any questions that a client or prospective client may have regarding Independent
Managers.
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Portfolio Activity. MSWM has a fiduciary duty to provide services consistent with the client’s best interest. As
part of its investment advisory services, MSWM 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,
fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment
objective. Based upon these factors, there may be extended periods of time when MSWM determines that
changes to a client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees
described in Item 5 below during periods of account inactivity. Of course, as indicated below, there can be no
assurance that investment decisions made by MSWM will be profitable or equal any specific performance
level(s).
Account Aggregation Platforms. MSWM may provide certain clients with access to account aggregation
platforms which can incorporate all of the client’s investment assets into one setting, including those investment
assets that are not part of the assets managed by MSWM (the “Unmanaged Assets”). MSWM may provide
asset allocation recommendations concerning the Unmanaged Assets but does not maintain any trading
authority over such assets. Rather, the client and/or the client’s designated other investment professional(s)
maintain and trading authority for the Unmanaged Assets and are exclusively responsible for implementing any
recommendations concerning the Unmanaged Assets. The client is under absolutely no obligation to accept
any such recommendation, and MSWM shall not be responsible for any implementation error (timing, trading,
etc.) relative to the Unmanaged Assets. In the event the client desires that MSWM provide investment
management services for the Unmanaged Assets, the client may engage MSWM to do so pursuant to the terms
and conditions of the Investment Advisory Agreement between MSWM and the client.
Client Obligations. In performing our services, MSWM shall not be required to verify any information received
from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, it
remains each client’s responsibility to promptly notify MSWM if there is ever any change in his/her/its financial
situation or investment objectives for the purpose of reviewing/evaluating/revising our previous
recommendations and/or services.
Non-Discretionary Services Limitations. Clients that determine to engage MSWM on a non-discretionary
investment advisory basis must be willing to accept that MSWM cannot effect any account transactions without
obtaining prior consent to any such transaction(s) from the client. Thus, in the event that MSWM would like to
make a transaction for a client’s account, and client is unavailable, MSWM will be unable to affect the account
transaction (as it would for its discretionary clients) without first obtaining the client’s consent.
Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and it should not
be assumed that future performance of any specific investment or investment strategy (including the
investments and/or investment strategies recommended or undertaken by MSWM) will be profitable or equal
any specific performance level(s).
Disclosure Brochure
A copy of MSWM’s written Brochure as set forth on Part 2A of Form ADV and Form CRS (Client Relationship
Summary) shall be provided to each client prior to, or contemporaneously with, the execution of an agreement
between the client and MSWM.
C. Client Account Management
Prior to engaging MSWM 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 – MSWM, in connection with the Client, may develop a
statement that summarizes the Client’s investment goals and objectives along with the broad
strategy[ies] to be employed to meet the objectives.
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• Asset Allocation – MSWM will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and tolerance of risk for each Client.
• Portfolio Construction – MSWM will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
• Investment Management and Supervision – MSWM will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
MSWM does not participate in a wrap fee program
E. Assets Under Management
As of December 31, 2023, MSWM manages the following assets:
Discretionary Assets $589,151,971
Non-Discretionary Assets $0
Total Assets Under Management $589,181,971
Clients may request more current information at any time by contacting the Advisor.