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)

MinMaxMarginal 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 AssetsAnnual FeesAverage 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. ii Investors Mosaic Page 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 iii Investors Mosaic Page 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. 4 Investors Mosaic Page 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 5 Investors Mosaic Page 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. 6 Investors Mosaic Page 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: 7 Investors Mosaic Page 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. 8 Investors Mosaic Page 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. 9 Investors Mosaic Page 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. 10 Investors Mosaic Page 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. 11 Investors Mosaic Page 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) 12 Investors Mosaic Page • 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 13 Investors Mosaic Page 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. 14 Investors Mosaic Page 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 15 Investors Mosaic Page 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. 16 Investors Mosaic Page 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. 17 Investors Mosaic Page 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. 18 Investors Mosaic Page 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. 19 Investors Mosaic Page