Overview
Assets Under Management: $120 million
High-Net-Worth Clients: 22
Average Client Assets: $5 million
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Fee Structure
Primary Fee Schedule (INVESTORS MOSAIC BROCHURE)
Min | Max | Marginal Fee Rate |
---|---|---|
$0 | $1,000,000 | 0.75% |
$1,000,001 | $2,000,000 | 0.65% |
$2,000,001 | $3,000,000 | 0.55% |
$3,000,001 | $4,000,000 | 0.45% |
$4,000,001 | $5,000,000 | 0.35% |
$5,000,001 | and above | 0.25% |
Minimum Annual Fee: $5,000
Illustrative Fee Rates
Total Assets | Annual Fees | Average Fee Rate |
---|---|---|
$1 million | $7,500 | 0.75% |
$5 million | $27,500 | 0.55% |
$10 million | $40,000 | 0.40% |
$50 million | $140,000 | 0.28% |
$100 million | $265,000 | 0.26% |
Clients
Number of High-Net-Worth Clients: 22
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 93.50
Average High-Net-Worth Client Assets: $5 million
Total Client Accounts: 129
Discretionary Accounts: 122
Non-Discretionary Accounts: 7
Regulatory Filings
CRD Number: 168619
Last Filing Date: 2024-05-01 00:00:00
Website: HTTP://WWW.INVESTORSMOSAIC.COM
Form ADV Documents
Primary Brochure: INVESTORS MOSAIC BROCHURE (2025-03-31)
View Document Text
Item 1 Cover Page
Investors Mosaic
1302 Oakland Ave.
Durham, NC 27705
March 31, 2025
This brochure provides information about the qualifications and business practices of Investors
Mosaic. If you have any questions about the contents of this brochure, please contact us at 617-272-
0006. The information in this brochure has not been approved or verified by the United States
Securities and Exchange Commission or by any state securities authority. Registration as a registered
investment advisor does not imply a certain level of skill or training.
Additional information about Investors Mosaic also is available on the SEC’s website at
http://www.adviserinfo.sec.gov.
Item 2 Material Changes
Filing Annual Updating Amendment for December 31, 2024.
Item 4: Advisory Business
Update AUM as of December 31, 2024.
Item 5: Fees and Compensation
Updated fee structure for Active Equity Investment service offering. We reduced the fee structure of this
service to be more in-line with industry averages. The new fee structure is as follows:
Account Assets
First $1 million
Next $4 million
Thereafter (asset above $5.0M)
Annual Fee
0.7500%
0.6375%
0.5525%
Item 12: Brokerage Practices
We removed all language regarding Shareholders Service Group as we no longer utilize them as a
custodian.
Item 13: Review of Client Accounts
Added language that states Trinity Critelli also conducts Client Reviews in addition to Evan McCormick.
Brochure Supplement
Removed Walter McCormick from the Brochure Supplement as it has been determined that Walter does
not meet the threshold as a Supervised Person. Added additional language about Trinity Critelli and
Evan’s role as her Supervisor.
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Item 3 Table of Contents
Item 2 Material Changes ...................................................................................................................... ii
Item 3 Table of Contents ..................................................................................................................... iii
Item 4 Advisory Business .................................................................................................................... 4
Item 5 Fees and Compensation ............................................................................................................ 7
Item 6 Performance-Based Fees and Side-by-Side Management ........................................................ 9
Item 7 Types of Clients ........................................................................................................................ 9
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................................. 9
Item 9 Disciplinary Information ......................................................................................................... 10
Item 10 Other Financial Industry Activities and Affiliations ............................................................. 10
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........ 11
Item 12 Brokerage Practices .............................................................................................................. 11
Item 13 Review of Accounts .............................................................................................................. 14
Item 14 Client Referrals and Other Compensation ............................................................................ 15
Item 15 Custody ................................................................................................................................. 15
Item 16 Investment Discretion ........................................................................................................... 15
Item 17 Voting Client Securities ........................................................................................................ 15
Item 18 Financial Information ........................................................................................................... 16
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Item 4 Advisory Business
Investors Mosaic is a registered investment advisor firm registered with the Securities Exchange Commission.
The principal and sole owner of Investors Mosaic is Evan A. McCormick, President and CEO.
Advisory Services
Investors Mosaic’s (“Advisor”) principal service is providing fee-based wealth management, investment
management and financial planning advisory services for individuals and families.
Wealth Management:
The wealth management service offering is a holistic approach to managing one’s net worth through a coordinated
approach to financial planning and investment management. Also, we seek to serve as a “quarterback” between
your tax advisor and estate attorney to ensure that all important facets of protecting and growing your wealth are
considered. The goal of wealth management is multi-faceted: 1) Establish short, medium, and long-term personal
and financial goals and objectives; 2) Assess risk tolerance and capacity to achieve stated goals and objectives;
3) Develop and execute a comprehensive financial plan; 3) align financial resources with their personal values;
and 4) Optimize financial resources to maximize the probability of achieving stated goals.
The engagement starts with a discovery process that enables the Advisor to fully understand the client and their
goals, dreams, fears, and stresses in life, which will inform the decisions around financial planning and investment
management. The discovery process usually takes 1 – 3 meetings. We strive to make these discussions fun and
enlightening in order to engage the client and establish a sense of ownership of the plan.
Once the discovery process is complete, we begin the Financial Planning process. The financial plan is an iterative
process, and we focus on achieving the highest impact goals first, knowing that clients usually have an acute issue
they want addressed and their capacity to execute on the “To Do” list is limited. After the discovery meetings,
we develop a detailed report that entails a comprehensive analysis into a client’s current financial situation and
maps out a path towards achieving their defined goals. Elements of a typical financial plan are:
Investment Portfolio Review & Risk Tolerance Assessment
• Net Worth Analysis
•
• Cash Flow & Budgeting
• Retirement Planning
• Education Funding Planning
• Debt Analysis and Paydown Options
•
Insurance Needs and Coverage
• Risk Management
The financial planning process is collaborative as we focus on making sure the client “buys into” the plan – which
we believe will improve the chances that the client ultimately executes the plan. In our opinion, getting client
“buy-in” requires the client to be actively involved in the process, so there are multiple meetings and/or phone
calls before a plan is finalized. Once the financial plan is finalized, Investors Mosaic and the client begin
executing the plan. Investors Mosaic provides guidance and encouragement to the client through the entire
process, hoping to serve as a catalyst for action. We know that a comprehensive financial plan can be
overwhelming for a client, so we breakdown the “to-do list” into discrete and manageable tasks, and importantly,
only give the client one action item at a time. Once that action item is complete, we give them another action
item. While the client is executing their part of the financial plan, we simultaneously begin executing our to-do
list. Overall, we prioritize the action item list by importance and impact, striving to address any serious “gaps”
immediately.
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Once the financial plan is in place, we begin the investment management process. Our goal with investment
management is to optimize the client’s portfolio to maximize the probability of achieving their life goals, while
taking into consideration their personal situation, age, and risk tolerance and risk capacity. Importantly, our
investment management process seeks to coordinate and harmonize asset allocation across all investment
accounts, thereby maximizing the impact of the plan. A key tenant of our investment management philosophy
within the wealth management framework is a focus on passive investing, utilizing low-cost and broad-based
ETFs and mutual funds. Research has shown that proper asset allocation is more important than security selection,
so we have embraced a passive approach for wealth management clients.
However, when appropriate, we are also comfortable owning individual stocks for client portfolios. Utilizing our
research and knowledge from the active portfolio strategy, we have identified a list of best-of-breed companies
that we believe are long-term winners vs. the index and believe that it may be prudent for clients to have additional
exposure to these stocks. Owning individual stocks is also part of our tax-loss harvesting strategy and optimizing
a client’s international equity exposure.
Also, each client has a certain level of “path dependency” with their existing portfolio when they become clients,
so the process of migrating a portfolio to the optimal portfolio could take several quarters due to the need for
being “tax-aware” when rebalancing portfolios. Ultimately, the goal is to build a portfolio that is properly
diversified across asset classes and geographies and is long-term in nature to minimize trading costs and taxes.
We also provide guidance and encouragement to serve as a catalyst for our clients to make important changes to
their financial life. We recognize that clients are busy, and usually over-whelmed with life tasks, so we are
committed to helping them overcome the inertia that prevents many people from executing upon a well-developed
financial plan. Furthermore, we strive to be a source of level-headedness during market volatility as clients look
to us as a calm voice and steady hand during these worrisome times. In this situation, our goal is to keep clients
invested and focused on the long-term.
Even though we seek to serve as a quarterback for a client and their tax and estate attorney, and provide
suggestions on insurance need and coverage, Investors Mosaic and its representatives are not attorneys,
accountants, or insurance specialists, and do not offer accounting or tax advice, nor do we prepare legal
documents. Clients should discuss suggestions with an attorney, tax advisor or insurance specialist before
implementation.
Stand-Alone Investment Management:
The Advisor offers stand-alone investment management services for clients that are only looking for guidance
and support on establishing and maintaining a portfolio that adheres to proper asset allocation, asset location, and
risk management. The process and execution for stand-alone investment management is the same as described
in the wealth management section. Investment management works best when a client allows us to manage, or at
least analysis, their entire investment portfolio so we take into consideration the holistic view of a client’s unique
situation in order to construct and manage the optimal portfolio.
Active Equity Management:
For legacy clients, Investors Mosaic manages one model equity portfolio, labeled “Growth”, on a discretionary
basis, according to the client’s objectives and investment suitability. Investors Mosaic confirms that all clients
understand the risk and return potential of the model portfolio and client’s financial situation, investment
objectives, time horizon, and risk tolerance are suitable for the investment strategy.
The Growth model utilizes fundamental analysis to determine stocks to include in the investment portfolio and
adhere to a well-defined investment process. First, we seek to identify “mega trends” that will create a financial
tailwind for companies and its stock price. Mega trends are defined as themes that will create long-term revenue
and earnings growth potential for companies in the industry. Often, mega trends consist of new, disruptive
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technology in existing industries. Examples of current mega trends the firm is following are: big data, cloud
computing, cyber security, human disintermediation, and post-COVID-19 structural changes.
Once we have identified mega trends, we attempt to identify the Best-of-Breed companies in the related industry.
Best-of-Breed companies tend to exhibit sustainable competitive advantages based on superior product
innovation, management team, and capital allocation. Based on these innate characteristics, we believe the stocks
of Best-of-Breed companies can outperform the broad market, enabling investors to generate alpha.
Once we have identified the Best-of-Breed company, we establish a rigid valuation framework that guides our
buy and sell decision-making process. Even though we are seeking to invest in the best companies in the world,
we’ll patiently wait for a stock to trade at a valuation we deem attractive. Conversely, we’ll sell positions when
we determine that the market is “pricing in” too much good news or business fundamentals deteriorate.
Specifically, we establish three price targets for all the stocks in the model portfolio: bull case, base case, and
bear case. These price targets are based upon our internally developed earnings expectations for the next 12
months. In general, we are buying a stock when it approaches the lower bound of our price targets and selling a
stock when it approaches the upper bound. Our rigid approach to valuation is aimed at removing emotion from
the decision-making process, which we believe helps us make better investment decisions.
We utilize several key information sources for our stock research, including The Wall Street Journal; SEC filings
such as 10-K’s, 10-Q’s, proxy statements, and S-1 filings; business magazines such as Forbes, Fortune, and
Business Week; and the Investor Relations materials from public companies. Furthermore, Investors Mosaic
utilizes less mainstream news sources such as Twitter, StockTwits, blogs, trade magazines, and lectures at Duke
University and the University of North Carolina at Chapel Hill to enhance our understanding of the world
economy, financial markets, and business and technology trends.
The Investors Mosaic “Growth” model maintains a relatively concentrated portfolio for our clients, typically 15
– 25 securities, that we have a high-degree of conviction in the long-term thesis. Additionally, our model portfolio
is constructed from a bottoms-up approach, meaning that our model portfolio will look very different than the
S&P 500. We are simply trying to find companies that we expect to grow earnings substantially over a multi-
year period, regardless of what industry it operates in. Investors Mosaic will use exchange-listed securities,
securities traded over-the counter, equity securities of foreign issuers, and options on securities to accomplish the
investment objectives.
Given the relatively concentrated nature of the portfolio, we maintain very strict risk management policies.
Specifically, no security can be more than 10% of the portfolio and no sector can be more than 35% of the
portfolio. We attempt to remain “fully invested” as we do not believe that any investor can accurately and
consistently time the stock market. We generally maintain a 2% - 10% cash position in the model portfolio
depending on the attractiveness of investment opportunities and market conditions, but our Investment Policy
allows the model portfolio to be as high as 20% cash if we deem the risk/return tradeoff to be extremely
unattractive.
Investors Mosaic will confirm the suitability of our investment strategy and model portfolio for new clients before
accepting funds. We determine suitability based on meetings and conversations with the client. If clients wish
to impose certain restrictions on investing in certain securities or types of securities, the Advisor will address
those restrictions with the client to have a clear understanding of the client’s requirements.
Investors Mosaic does not provide portfolio management services to wrap fee programs.
As of December 31, 2024, Investors Mosaic had 29 clients and $148.4M of client assets under management.
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Item 5 Fees and Compensation
We offer a complimentary 30-minute, no commitments, meeting with all prospective clients to help them
determine if Investors Mosaic is a good fit for their unique situation. During this meeting, we learn about the
client’s financial situation and discuss how we might be able to work together in a productive relationship.
Wealth Management Fee Structure:
The wealth management fee structure is tiered based upon assets under management as follows:
Account Assets
First $1 million
Next $1 million ($1M - $2M)
Next $1 million ($2M - $3M)
Next $1 million ($3M - $4M)
Next $1 million ($4M - $5M)
Thereafter (Greater than $5M)
Annual Fee
0.75%
0.65%
0.55%
0.45%
0.35%
0.25%
Pursuant to a wealth management advisory contract signed by each client, the client will pay Investors Mosaic a
management fee, payable quarterly in arrears, based on the average of the asset values of the account managed
by the Advisor at the end of each month in the quarter. New account fees will be prorated from the inception of
the account to the end of the first quarter. This fee may be negotiated at the sole discretion of the Advisor.
Stand-Alone Investment Management Fee Structure:
Pursuant to a stand-alone investment advisory contract signed by each client, the client will pay Investors Mosaic
a management fee, payable quarterly in arrears, based on the average of the asset values of the account managed
by the Advisor at the end of each month in the quarter. New account fees will be prorated from the inception of
the account to the end of the first quarter. The annualized fee to be charged is based on the level of assets in the
account as follows:
Annual Fee
Account Assets
First $1 million
Next $1 million ($1M - $2M)
Next $1 million ($2M - $3M)
Next $1 million ($3M - $4M)
Next $1 million ($4M - $5M)
Thereafter (Greater than $5M)
0.50%
0.45%
0.40%
0.35%
0.30%
0.25%
The management fee for stand-alone investment management offering is lower than the active equity
management fee since the Advisor utilizes a passive strategy for stand-alone investment management accounts.
This approach is less time-intensive than active stock selection, so the Advisor can pass those savings along to
the client. This fee may be negotiated at the sole discretion of the Advisor.
Active Equity Investment Management Fees:
Pursuant to an investment advisory contract signed by each client, the client will pay Investors Mosaic a
management fee, payable quarterly in arrears, based on the average of the asset values of the account managed
by the Advisor at the end of each month in the quarter. New account fees will be prorated from the inception of
the account to the end of the first quarter. The annualized fee to be charged is based on the level of assets in the
account as follows:
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Account Assets
First $1 million
Next $4 million
Thereafter (asset above $5.0M)
Annual Fee
0.7500%
0.6375%
0.5525%
The fee structure may be negotiated at the sole discretion of the Advisor.
For wealth and investment, the qualified custodian will directly deduct asset management fees from the client
account on a quarterly basis. The client will give written authorization permitting the Advisor to be paid directly
from their account held by the custodian. The custodian will send a statement directly to the client at least
quarterly. For those accounts where direct fee deduction is not practicable, invoices will be sent to clients shortly
after the end of the quarter and the invoice is due by the end of the month it was delivered.
The annual fee is based on market value on the closing date of the quarter, as reported by the custodian
of each account. Portfolio value includes mutual funds, ETFs, individual securities, annuities, IRAs and
defined contribution plans. Portfolio value does not include checking and savings accounts, money
market accounts, CDs, savings bonds, insurance policies (except annuities), real estate rental properties,
primary residence, vacation homes or defined benefit plans.
Minimum Fee
The Advisor has a minimum annual fee of $5,000 for all new clients (both Wealth Management or Standalone
Investment Management). The minimum annual fee comes into effect if the AUM for a client is below the
required level to achieve such a fee based upon the fee structure of the given service offering. We will not take
on a client if the minimum fee exceeds 2.0% of their investable assets to avoid the excessive fee threshold, but
we also reserve the right to waive the minimum fee for specific clients. The minimum annual fee helps us manage
our capacity and business model in order to allow us to focus on providing our clients with a superior service &
experience. The minimum fee may be waived or lowered by the sole discretion of the firm.
For the Advisor's services described above, the Client may terminate these services within five business days of
the effective date of an Agreement signed with the Advisor without any payment of the Advisor's fee.
Client is responsible for all custodial and securities execution fees charged by the custodian and executing broker-
dealer. The Advisors fee is separate and distinct from the custodian and execution fees.
Neither Investors Mosaic nor its supervised persons accept compensation for the sale of securities or other
investment products, including asset-based sales charges or service fees from the sale of mutual funds.
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Item 6 Performance-Based Fees and Side-by-Side Management
Investors Mosaic does not charge performance-based fees.
Item 7 Types of Clients
The Advisor offers its services to individuals and families, which are typically in the mass affluent to high-net-
worth spectrum.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
For Wealth Management and Investment Management, Investors Mosaic focuses on asset allocation, asset
location and risk management. We believe that when managing a client’s investment account on a holistic basis,
it’s more important – and generates better returns – to coordinate and harmonize the investment strategy across
all accounts, using low-cost ETFs and mutual funds, Individual Bonds, CDs, Money Market Funds, and
Treasuries to establish the ideal asset allocation. When we talk about asset allocation, we mean a focus on the
optimal mix of stocks and bonds, sub-divided into categories such as U.S. stocks, International stocks, Large Cap
stocks, Government bonds, Corporate bonds, long-term and short-term bonds. Each asset class has different risk
and return characteristics, which when combined properly, can create an optimal portfolio for a given level of
risk. We are also dedicated to low-turnover, tax-efficient, and long-term investing.
Our preferred ETF provider is Vanguard, with Schwab as our primary secondary choice given their intense focus
on low-cost and well-constructed ETFs and funds that closely track the underlying benchmark or asset class.
When Vanguard or Schwab does not offer the superior solution, we have identified several other ETFs and mutual
funds from T. Rowe Price, Fidelity, iShares, and other well-regarded institutions to provide the required
benchmark or asset class exposure.
We monitor client portfolios on a regular basis. On an annual basis, and more frequently if warranted, we re-
balance client accounts to maintain the desired asset allocation and risk/return profile of their portfolio. Also,
when appropriate, we conduct tax-loss harvesting in taxable accounts to minimize the impact of capital gains
taxes.
For Active Equity Management, the Advisor utilizes fundamental analysis techniques in formulating investment
advice, constructing portfolios, managing assets for clients.
Fundamental analysis of businesses involves analyzing its financial statements and health, its management and
competitive advantages, and its competitors and markets. Fundamental analysis is performed on historical and
present data but with the goal of making financial forecasts. There are several possible objectives: to conduct a
company stock valuation and predict its probable price evolution; to make a projection on its business
performance; to evaluate its management team and business, and to estimate its operational and credit risk.
The investment strategies the Advisor will implement may include long-term purchases of securities held at least
for one-year, short-term purchases for securities sold within a year, trading of securities sold within 30 days, and
option writing, including covered options.
Clients need to be aware that investing in securities involves risk of loss that clients need to be prepared to bear.
The method of analysis and the investment strategy followed by the Advisor is utilized across all the Advisors
clients, as applicable. However, the client should be aware that with any trading that occurs in the client account,
the client will incur transaction and administrative costs.
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Investing includes the risk that the value of an investment can be negatively affected by factors specifically related
to the investment (e.g., capability of management, competition, new inventions by other companies, lawsuits
against the company, labor issues, patent expiration, etc.), or to factors related to investing and the markets in
general (e.g., the economy, wars, civil unrest or terrorism around the world, concern about oil prices or
unemployment, etc.). Clients need to be aware that investing in securities involves risk of loss of some or all of
their investment that clients need to be prepared to bear.
Risks of fundamental analysis may include risks that market actions, natural disasters, government actions, world
political events or other events not directly related to the price or valuation of a specific company’s fundamental
analysis can adversely impact the stock price of a company causing a portfolio containing that security to lose
value. Risks may also include that the historical data and projections on which the fundamental analysis is
performed may not continue to be relevant to the operations of a company going forward, or that management
changes or the business direction of management of the company may not permit the company to continue to
produce metrics that are consistent with the prior company data utilized in the fundamental analysis, which may
negatively affect the Advisor’s estimate of the valuation of the company.
Clients are advised that many unexpected broad environmental factors can negatively impact the value of portfolio
securities causing the loss of some or all of the investment, including changes in interest rates, political events,
natural disasters, and acts of war or terrorism. Further, factors relevant to specific securities may have negative
affects on their value, such as competition or government regulation. Also, the factors for which the company
was selected for inclusion in a client portfolio may change, for example, due to changes in management, new
product introductions, or lawsuits.
Item 9 Disciplinary Information
Neither Investors Mosaic nor its management persons have had any legal or disciplinary events, currently or in
the past.
Item 10 Other Financial Industry Activities and Affiliations
Neither Investors Mosaic nor any of its management persons are registered, or have an application pending to
register, as a broker-dealer or a registered representative of a broker-dealer.
Neither Investors Mosaic nor any of its management persons are registered or have an application pending to
register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an
associated person of the foregoing entities.
Investors Mosaic does not currently have any relationships or arrangements that are material to its advisory
business or clients with either a broker-dealer, municipal securities dealer, or government securities dealer or
broker, investment company or other pooled investment vehicle (including a mutual fund, closed-end investment
company, unit investment trust, private investment company or “hedge fund” and offshore fund), other investment
advisor or financial planner, futures commission merchant, commodity pool operator, or commodity trading
advisor, banking or thrift institution, accountant or accounting firm, lawyer or law firm, insurance company or
agency, pension consultant, real estate broker or dealer or sponsor of syndicator of limited partnerships.
Investors Mosaic does not recommend or select other investment advisers for clients.
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Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Investors Mosaic is registered as a state registered investment advisor registered with the North Carolina securities
regulators and has adopted as an industry best practice a Code of Ethics that sets forth the basic policies of ethical
conduct for all managers, officers, and employees of the adviser. In addition, the Code of Ethics governs personal
trading by each employee of Investors Mosaic deemed to be an Access Person and is intended to ensure that
securities transactions effected by Access Persons of Investors Mosaic are conducted in a manner that avoids any
conflict of interest between such persons and clients of the adviser or its affiliates. Investors Mosaic collects and
maintains records of securities holdings and securities transactions effected by Access Persons. These records
are reviewed to identify and resolve conflicts of interest. Investors Mosaic will provide a copy of the Code of
Ethics to any client or prospective client upon request.
Investors Mosaic and/or its investment advisory representatives may from time to time purchase or sell products
that they may recommend to clients. Investors Mosaic and/or its investment advisory representatives have a
fiduciary duty to put the interests of their clients ahead of their own. Specifically, Evan McCormick, CEO, invests
personally in the same model portfolio used in the Investors Mosaic active equity strategy. This is due to the fact
that the strategy is based upon Mr. McCormick’s personal investment philosophy, and properly aligns his
incentives with his clients. In order to make sure that Mr. McCormick maintains his fiduciary duty to clients and
puts their interest ahead of his own, all trades – buy and sell orders – will be executed for the client portfolios
before Mr. McCormick trades for his personal account.
Investors Mosaic requires that its investment advisory representatives follow its basic policies and ethical
standards as set forth in its Code of Ethics.
Item 12 Brokerage Practices
The Custodians and Brokers We Use
Investors Mosaic does not maintain custody of your assets that we manage or on which we advise, although we
may be deemed to have custody of your assets if you give us authority to withdraw assets from your account (see
Item 15—Custody, below). Your assets must be maintained in an account at a “qualified custodian,” generally a
broker-dealer or bank. We request that our clients use either Charles Schwab & Co., Inc. (“Schwab”) or Fidelity
Investments (“Fidelity”) as custodian. We collectively refer to Schwab and Fidelity as “Custodians”. Both are
registered broker-dealers, members SIPC, as the qualified custodian.
We are independently owned and operated and are not affiliated with Fidelity or Schwab. The Custodians will
hold your assets in a brokerage account and buy and sell securities when we instruct them to. While we request
that you use Schwab as custodian/broker, you will decide whether to follow or suggestion or choose another
custodian for your assets. If you choose another custodian, you will need to grant Investors Mosaic LPOA on
those accounts so we can execute trades on your behalf. Also, you will need to designate Investors Mosaic as an
Interested Party so we can view account balances as well as receive quarterly statements.
You will open your account with Schwab or Fidelity by entering into an account agreement directly with them.
We do not open the account for you, although we may assist you in doing so.
All new client accounts will be opened on the Fidelity or Schwab platform.
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How We Select Brokers and Custodians
We seek to recommend a custodian/broker that will hold your assets and execute transactions on terms that are,
overall, most advantageous when compared with other available providers and their services. We consider a wide
range of factors, including:
• Combination of transaction execution services and asset custody services (generally without a separate
fee for custody)
• Capability to execute, clear, and settle trades (buy and sell securities for your account)
• Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill
payment, etc.)
• Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds, etc.)
• Availability of investment research and tools that assist us in making investment decisions
• Quality of services
• Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.)
and willingness to negotiate the prices
• Reputation, financial strength, security and stability
• Prior service to us and our clients
• Availability of other products and services that benefit us, as discussed below (see “Products and services
available to us from Schwab”)
The client will provide authority to Investors Mosaic to direct all transactions through that broker-dealer in
the investment advisory agreement.
Your Brokerage & Custody Costs
For our clients’ accounts that Custodian maintains, they do not charge you separately for custody services but are
compensated by charging you commissions or other fees on trades that it executes for your account(s). Custodians
are also compensated by earning interest on the uninvested cash in your account via Cash Sweep Accounts. These
are all standard methods for Custodians to be compensated for the value services they provide.
Products and Services Available to us From Fidelity & Schwab
Fidelity’s Wealthscape and Schwab’s Schwab Advisor Services™ are businesses serving independent investment
advisory firms like us. They provide us and our clients with access to their institutional brokerage services
(trading, custody, reporting, and related services), some of which are not typically available to Fidelity or Schwab
retail customers. These custodians also make available various support services. Some of those services help us
manage or administer our clients’ accounts, while others help us manage and grow our business. Custodian
support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge
to us. Following is a more detailed description of Fidelity and Schwab’s support services:
Services that benefit you. Both custodians offer institutional brokerage services include access to a broad range
of investment products, execution of securities transactions, and custody of client assets. The investment products
available through Fidelity and Schwab include some to which we might not otherwise have access or that would
require a significantly higher minimum initial investment by our clients. The services described in this paragraph
generally benefit you and your account.
Services that may not directly benefit you. Fidelity and Schwab also make available to us other products and
services that benefit us but may not directly benefit you or your account. These products and services assist us in
managing and administering our clients’ accounts. They include investment research, both Fidelity’s, Schwab’s,
and that of third parties. We may use this research to service all or a substantial number of our clients’ accounts.
In addition to investment research, both Fidelity and Schwab also makes available software and other technology
that:
• Provide access to client account data (such as duplicate trade confirmations and account statements)
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• Facilitate trade execution and allocate aggregated trade orders for multiple client accounts
• Provide pricing and other market data
• Facilitate payment of our fees from our clients’ accounts
• Assist with back-office functions, recordkeeping, and client reporting
Services that generally benefit only us. Fidelity and Schwab also offer other services intended to help us manage
and further develop our business enterprise. These services include:
• Educational conferences and events
• Consulting on technology, compliance, legal, and business needs
• Publications and conferences on practice management and business succession
• Access to employee benefits providers, human capital consultants, and insurance providers
• Marketing consulting and support
Our custodians may provide some of these services themselves. In other cases, it will arrange for third-party
vendors to provide the services to us. Fidelity or Schwab may also discount or waive its fees for some of these
services or pay all or a part of a third party’s fees. Both custodians may also provide us with other benefits, such
as occasional business entertainment of our personnel.
Investors Mosaic take advantage of most of the services that Fidelity and Schwab have to offer.
Our Interest in Fidelity’s Services
The availability of these services from Fidelity benefits us because we do not have to produce or purchase them.
We don’t have to pay for Fidelity’s services (unless our AUM falls below $25M at the custodian). This creates
an incentive to recommend that you maintain your account with Fidelity, based on our interest in receiving
Fidelity’s services that benefit our business rather than based on your interest in receiving the best value in custody
services and the most favorable execution of your transactions. This is a potential conflict of interest. We believe,
however, that our selection of Fidelity as custodian and broker is in the best interests of our clients. Our selection
is primarily supported by the scope, quality, and price of Fidelity’s services (see “How we select brokers/
custodians”) and not Fidelity’s services that benefit only us.
Our Interest in Schwab’s Services
The availability of these services from Schwab benefits us because we do not have to produce or purchase them.
We don’t have to pay for Schwab’s services. [These services are not contingent upon us committing any specific
amount of business to Schwab in trading commissions or assets in custody.] This creates an incentive to
recommend that you maintain your account with Schwab, based on our interest in receiving Schwab’s services
that benefit our business rather than based on your interest in receiving the best value in custody services and the
most favorable execution of your transactions. This is a potential conflict of interest. We believe, however, that
our selection of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily
supported by the scope, quality, and price of Schwab’s services (see “How we select brokers/ custodians”) and
not Schwab’s services that benefit only us.
Investors Mosaic does not receive research or other products or services other than execution from a broker-dealer
or third party as a result of client securities transactions.
Investors Mosaic does not receive client referrals from any broker-dealer or third party as a result of the firm
selecting or recommending that broker-dealer to clients.
As an investment advisory firm, Investors Mosaic has a fiduciary duty to seek best execution for client
transactions. While best execution is difficult to define and challenging to measure, there is some consensus that
it does not solely mean the achievement of the best price on a given transaction. Rather, it appears to be a
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collective consideration of factors concerning the trade in question. Such factors include the security being traded,
the price of the trade, the speed of the execution, apparent conditions in the market, and the specific needs of the
client. Investors Mosaic’s primary objectives when placing orders for the purchase and sale of securities for client
accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of order,
3) difficulty of execution, 4) confidentiality and 5) liquidity. Investors Mosaic may not necessarily pay the lowest
commission or commission equivalent as specific transactions may involve specialized services on the part of the
broker.
Investors Mosaic may combine orders into block trades when more than one account is participating in the trade.
This blocking technique is utilized to achieve a trade execution price that is equitable across similarly managed
accounts. Block trading is performed when it is consistent with the duty to seek best execution and is consistent
with the terms of Investors Mosaic’s investment advisory agreements. Allocations of block orders are performed
in a timely and efficient manner. All managed accounts participating in a block execution receive the same
execution price (average share price) for the securities purchased or sold in a trading day. Any portion of an order
that remains unfilled at the end of a given day will be rewritten on the following day as a new order with a new
daily average price to be determined at the time of the trade. Due to the low liquidity of certain securities, broker
availability may be limited. Orders that have not been executed by the end of the trading day will be canceled.
If an order is filled in its entirety, securities purchased in the aggregated transaction will be allocated among the
accounts participating in the trade in accordance with the allocation statement. If an order is partially filled, the
securities will be allocated pro rata based on the allocation statement. Investors Mosaic may allocate trades in a
different manner than indicated on the allocation statement (non-pro rata) only if all managed accounts receive
fair and equitable treatment.
Item 13 Review of Accounts
At the onset of every client relationship, the Advisor will review factors such as the client’s risk tolerance, income
needs, retirement requirements and other investment objectives, time horizon, and overall financial situation to
ensure that the Advisor becomes familiar with each client’s unique circumstances and needs. All accounts are
reviewed at least quarterly. The frequency of client outreach is as follows:
Wealth Management & Financial Planning: We meet with / call clients at least annually to review their financial
plan and investment portfolio. If desired, or life circumstances dictate, we will meet with / call clients on a more
frequent basis. Clients also receive an investment portfolio report quarterly, provided by either the custodian or
Investors Mosaic.
Stand-Alone Investment Management: We meet with / call clients at least annually to review their investment
performance and portfolio, risk tolerance, and investment policy statement. If desired, or life circumstances
dictate, we will meet with / call clients on a more frequent basis. Clients also receive an investment portfolio
report quarterly, provided by either the custodian or Investors Mosaic.
Active Investment Management: At the beginning of a relationship, we confirm that the selected strategy is
suitable to the client’s needs. Afterward, the firm reviews client accounts on an annual basis, or when conditions
would warrant a review based on market conditions or changes in client circumstances. Clients also receive an
Investor Letter and investment portfolio report quarterly, provided by either the custodian or Investors Mosaic.
For all clients and service offerings, triggering factors for more frequent meetings may include Investors Mosaic
becoming aware of a change in client’s investment objective, a change in market conditions, change of
employment, or a change in risk tolerance, among other factors.
All reviews are performed by Evan McCormick, President and CEO, or Trinity Critelli, Client Service and
Financial Planning Associate.
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The client is encouraged to notify the Advisor and Investment Advisor Representative if changes occur in his/her
personal financial situation that might materially affect his/her investment plan.
The client will receive written statements no less than quarterly from the custodian. In addition, the client will
receive other supporting reports from mutual funds, asset managers, or other custodians who are involved with
client accounts. Investors Mosaic provides clients with a quarterly performance report comparing the performance
of their account to the S&P 500, and other benchmarks if warranted.
Item 14 Client Referrals and Other Compensation
We receive an economic benefit from Schwab and Fidelity in the form of the support products and services they
make available to us and other independent investment advisors whose clients maintain their accounts at these
custodians. These products and services, how they benefit us, and the related conflicts of interest are described
above (see Item 12—Brokerage Practices).
Investors Mosaic is not compensated by anyone for providing investment advice or other advisory services except
as previously disclosed in this Brochure.
Investors Mosaic does not directly or indirectly compensate any person who is not a supervised person for client
referrals.
Item 15 Custody
Under government regulations, we are deemed to have custody of your assets if, for example, you authorize us to
instruct Fidelity or Schwab to deduct our advisory fees directly from your account or if you grant us authority to
move your money to a 3rd Party account. (A 3rd party account is one in which the legal ownership is modified or
changes from the 1st Party account registration.)
However, Fidelity and Schwab maintain actual custody of your assets. You will receive account statements
directly from the Custodian at least quarterly. Statements will be sent to the email or postal mailing address you
provided to the Custodian. You should carefully review those statements promptly when you receive them. We
also urge you to compare your account statements with the periodic account statements & portfolio reports you
receive from us. Any discrepancies should be immediately brought to the firm’s attention. The Custodians
provide access the client account on-line 24/7/365. Clients will receive a report from Investors Mosaic quarterly.
Item 16 Investment Discretion
Investors Mosaic generally has discretion over the selection and amount of securities to be bought or sold in client
accounts without obtaining prior consent or approval from the client for each transaction. However, these
purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set
forth by the client and agreed to by Investors Mosaic.
Discretionary authority will only be provided upon full disclosure to the client. The granting of such authority
will be evidenced by the client’s execution of a Wealth Management or Investment Advisory Agreement
containing all applicable limitations to such authority. All discretionary trades made by Investors Mosaic will be
in accordance with each client’s investment objectives and goals through the Investment Policy Statement.
Item 17 Voting Client Securities
Investors Mosaic will not vote, nor advise clients how to vote, proxies for securities held in client accounts.
However, in rare circumstances where the Client must forfeit proxy voting authority for job-related compliance
reasons, Investors Mosaic reserves the right to enter into an agreement with Client to vote proxies. If Investors
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Mosaic accepts, and the Client authorizes us to vote proxies on their behalf, such an agreement will be outlined
within the Investment Advisor Agreement. In the absence of such an agreement, the client clearly keeps the
authority and responsibility for the voting of these proxies. Clients will receive proxy solicitations from their
custodian and/or transfer agent. However, you can reach out to Investors Mosaic if you have questions about
proxy voting.
In the rare circumstance were Investors Mosaic votes proxies for a client, Investors Mosaic has adopted and
implemented written Proxy Voting Policies and Procedures (“Proxy Voting Procedures”) which are designed to
reasonably ensure that Investors Mosaic votes proxies in the best interest of its clients where the Advisor has
voting authority. The Proxy Voting Procedures describes how Investors Mosaic addresses voting authority,
material conflicts of interest, voting decisions, notification to the client, and books and records requirements, and
ensures that proxies are voting in the best interest of its clients.
Investors Mosaic acknowledges and agrees that it has a fiduciary obligation to its clients to ensure that any proxies
for which it has voting authority are voted solely in the best interests and for the exclusive benefit of its clients.
The Proxy Voting Procedures are intended to guide Investors Mosaic and its personnel in ensuring that proxies
are voted in such manner without limiting Investors Mosaic or its personnel in specific situations to vote in a
predetermined manner. These policies are designed to assist Investors Mosaic in identifying and resolving any
conflicts of interest it may have in voting client proxies. The Proxy Voting Procedures will be made available
upon request.
Item 18 Financial Information
Investors Mosaic does not require or solicit prepayment of more than $1,200 in fees per client, six months or more
in advance, and is not required to file a balance sheet.
Investors Mosaic has discretionary authority over client accounts and is not aware of any financial condition that
will likely impair its ability to meet contractual commitments to clients. If Investors Mosaic does become aware
of any such financial condition, this brochure will be updated, and clients will be notified.
Investors Mosaic has never been subject to a bankruptcy petition.
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Item 1 Cover Page for Brochure Supplement
Evan A. McCormick, President and CEO
Investors Mosaic
1302 Oakland Ave.
Durham, NC 27705
617-272-0006
December 31, 2024
This brochure supplement provides information about Evan A. McCormick that supplements the Investors
Mosaic brochure. You should have received a copy of that brochure. Please contact Evan A. McCormick
if you did not receive Investors Mosaic’s brochure or if you have any questions about the contents of this
supplement.
information about Evan A. McCormick
is available on the SEC’s website at
Additional
www.adviserinfo.sec.gov.
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Item 2 Educational Background and Business Experience
Evan A. McCormick, born in 1979, received a Bachelor of Arts degree in Economics from Davison College in
2002, and a Master of Business Administration, Dean’s List, from The Fuqua School of Business at Duke
University in 2011. Prior to forming and becoming President and CEO of Investors Mosaic, LLC in August 2013,
Mr. McCormick was Co-founder and CEO of Investors Mosaic, Inc. (June 2011 – July 2013), an LBO Research
Associate at Fidelity Equity Partners (September 2006 – May 2009), and an Equity Research Associate at Fidelity
Investments (June 2003 – September 2006).
Item 3 Disciplinary Information
There are no legal or disciplinary events or proceedings to report concerning Mr. Evan A. McCormick.
Item 4 Other Business Activities
Mr. Evan A. McCormick has no other business activities.
Item 5 Additional Compensation
Mr. Evan A. McCormick does not receive compensation or other economic benefit from anyone who is not a
client for providing advisory services.
Item 6 Supervision
Evan A. McCormick is the President, CEO, and Chief Compliance Officer of Investors Mosaic and can be reached
at 617-272-0006 and is authorized to provide investment advice to clients.
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Item 2 Educational Background and Business Experience
Trinity Critelli, born in 2001, graduated Summa Cum Laude with a B.S. in Finance and a minor in Accounting
from SUNY Polytechnic Institute in 2023 and is currently pursuing her MBA at SUNY Polytechnic Institute
concentrating in Accounting and Finance. Trinity attended Mohawk Valley Community College from 2019 –
2021 and earned a Business Associate’s Degree and Finance Certificate, and transferred to SUNY Polytechnic
Institute in 2021. Trinity has been working in the financial services industry since 2019. She holds FINRA Series
7 and 63, and 65 licenses, and she has plans to obtain her CFP® designation following her MBA graduation.
Item 3 Disciplinary Information
There are no legal or disciplinary events or proceedings to report concerning Ms. Trinity Critelli.
Item 4 Other Business Activities
Ms. Trinity Critelli offers pitching lessons for youth softball players during the summer for up to 3 hours a week.
Item 5 Additional Compensation
Ms. Trinity Critelli does not receive compensation or other economic benefit from anyone who is not a client for
providing advisory services.
Item 6 Supervision
Ms. Trinity Critelli is supervised by Evan A. McCormick, the President, CEO, and Chief Compliance Officer of
Investors Mosaic. Trinity and Evan work closely on a daily basis, and Evan McCormick ensure that Trinity is
abiding by company policies and procedures, and reviews and approves, in advance, all client investment and
financial planning advice that Trinity provides. You can reach Evan McCormick at 617-272-0006 if you have
any questions or concerns about Trinity Critelli. Trinity Critelli is authorized to provide investment advice to
clients.
Item 7 Requirements for State-Registered Advisers
Ms. Trinity Critelli has not been involved in an award or found liable in an arbitration claim, civil, or self-
regulatory organization event or administrative proceeding, or been the subject of a bankruptcy petition.
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