View Document Text
Brochure
Form ADV Part 2A
Item 1 - Cover Page
CRD# 108170
1100 Atlanta Financial Center
3353 Peachtree Road NE
Atlanta, Georgia 30326
(404) 504-8600
www.MarcoInv.com
March 20, 2025
This Brochure provides information about the qualifications and business practices of Marco
Investment Management, LLC. If you have any questions about the contents of this Brochure, please
contact us at (404) 504-8600 or MBurton@marcoinv.com. 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.
Marco Investment Management, LLC, is an investment advisory firm registered with the U.S.
Securities and Exchange Commission. Registration does not imply a certain level of skill or training.
Additional information about Marco Investment Management, LLC, is available on the SEC’s website
at www.AdviserInfo.sec.gov.
Item 2 - Material Changes
This Brochure is prepared in the revised format required beginning in 2011. Registered Investment
Advisers are required to use this format to inform clients of the nature of advisory services provided,
types of clients served, fees charged, potential conflicts of interest and other information. The
Brochure requirements include providing a Summary of Material Changes (the “Summary”)
reflecting any material changes to our policies, practices, or conflicts of interest made since our last
required “annual update” filing. In the event of any material changes, such Summary is provided to
all clients within 120 days of our fiscal year end. Our last annual update was filed on February 7,
2024. The complete Brochure is available to you at any time upon request.
Item 3 - Table of Contents
Page
Item 1 - Cover Page ............................................................................................................................................................ 1
Item 2 - Material Changes ............................................................................................................................................... 1
Item 3 - Table of Contents ............................................................................................................................................... 2
Item 4 - Advisory Business ............................................................................................................................................. 3
Item 5 - Fees and Compensation .................................................................................................................................. 5
Item 6 - Performance-Based Fees and Side-By-Side Management ................................................................ 5
Item 7 - Types of Clients .................................................................................................................................................. 5
Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss........................................................ 6
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.. 10
Item 12 - Brokerage Practices ...................................................................................................................................... 11
Item 13 - Review of Accounts ....................................................................................................................................... 14
Item 14 - Client Referrals and Other Compensation ........................................................................................... 14
Item 15 - Custody .............................................................................................................................................................. 15
Item 16 - Investment Discretion ................................................................................................................................. 15
Item 17 - Voting Client Securities ............................................................................................................................... 16
Item 18 - Financial Information................................................................................................................................... 16
Brochure Supplements…………………..………………………...…………….…………………………………… Exhibit A
Page 2
Item 4 - Advisory Business
General Information
Marco Investment Management, LLC (“MIM”), is a limited liability company organized in Georgia.
Marco Investment Management, an investment advisory firm registered with the United States
Securities and Exchange Commission, was formed in 1998 and provides portfolio management
services, including specialized services involving option strategies, to our clients. Please see Item 8
- Methods of Analysis, Investment Strategies and Risk of Loss for more detail regarding MIM’s
Investment Management Strategies. Registration with the SEC does not imply a certain level of skill
or training.
Steven S. Marco is the sole principal owner of MIM. Please see Brochure Supplements, Exhibit A, for
more information on Mr. Marco and others who formulate advice for clients.
As of December 31, 2024, MIM managed $1,561,855,720 on a discretionary basis and did not manage
any assets on a non-discretionary basis.
SERVICES PROVIDED
At the outset of each client relationship, we spend time with you, asking questions, discussing your
investment experience and financial circumstances, and reviewing options for you. Based on our
review, we generally develop:
•
•
a financial outline for you based on your financial circumstances and goals and your risk
tolerance level (the “Financial Profile” or “Profile”); and
your investment objectives and guidelines (the “Investment Plan” or “Plan”).
The Financial Profile is a reflection of your current financial picture and a look to your future goals.
The Investment Plan outlines the types of investments we will make on your behalf to meet those
goals. The Profile and the Plan are discussed regularly with you but are not necessarily written
documents.
Portfolio Management
As described above, at the beginning of a client relationship, we meet with you, gather information,
and perform research and analysis as necessary to develop your Investment Plan. We also discuss
the investment strategies that we use, to help ensure the management styles are commensurate with
your needs.
Through detailed discussions with you, we provide the following services: 1) analyze existing assets;
2) analyze current asset allocation strategy; 3) make recommendations for changes in asset
allocation and specific investments; and 4) implement the recommendations. The Investment Plan
will be updated from time to time when requested by you or when determined to be necessary or
advisable by us based on updates to your financial or other circumstances.
To implement your Investment Plan, we will manage your investment portfolio on a discretionary
basis. As a discretionary investment adviser, we will have the authority to supervise, direct, and make
changes to your portfolio without prior consultation with you.
Notwithstanding the foregoing, you may impose certain written restrictions on us in the management
Page 3
of your investment portfolio, such as prohibiting the inclusion of certain types of investments in your
investment portfolio or prohibiting the sale of certain investments held in your account at the
commencement of the relationship. You should note, however, that restrictions imposed by you may
adversely affect the composition and performance of your investment portfolio. You should also note
that your investment portfolio is treated individually by giving consideration to each purchase or sale
for your account. For these and other reasons, such restrictions can cause the composition and
performance of your investment portfolio to differ from that of portfolios of similarly situated clients
with the same investment objectives, goals and/or risk tolerance.
Individual Retirement Advice
When we are making investment recommendations to you regarding your retirement plan account
or individual retirement account, we are acting as fiduciaries within the meaning of Title I of the
Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which
are laws governing retirement accounts. As a fiduciary, we have duties of care and of loyalty to you.
As a result, you have certain rights that cannot be waived or limited by contract. Nothing in our
agreement with you should be interpreted as a limitation of our obligations under federal and state
securities laws or as a waiver of any unwaivable rights you possess. The way we make money or are
otherwise compensated creates some conflicts with your financial interests, so we operate under a
special rule that requires us to act in your best interest and not put our interest ahead of yours.
Under this special rule's provisions, we must:
Meet a professional standard of care when making investment recommendations (give
prudent advice) to you;
Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
Avoid misleading statements about conflicts of interest, fees, and investments;
Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
Charge no more than what is reasonable for our services; and
Give you basic information about our conflicts of interest.
Financial Planning
From time to time we offer financial planning services to clients on a limited basis, usually in
conjunction with Portfolio Management services and not as a stand-alone service. Our financial
planning services normally address areas such as general cash flow planning, retirement planning,
estate planning and insurance analysis. The goal of this service is to assess your financial
circumstances in order to more effectively manage your investment portfolio.
Portfolio Manager in Wrap Programs
We serve as a portfolio manager for certain clients of unaffiliated investment advisors (each a
“Primary Advisor”) in connection with wrap fee programs. Clients of the Primary Advisors, after
consulting with the Primary Advisors, have selected us to manage a portion of their assets. The
Primary Advisors work with the client to develop, and keep current, investment guidelines and to
determine the amount to be allocated to their client’s account managed by us.
Investment management that we provide to wrap fee clients is substantially the same as that
provided to non-wrap fee clients. However, practical restraints on the management of wrap fee
accounts can exist. Most notably, the smaller asset value of certain wrap fee accounts can result in
slightly different returns due to investment limitations imposed by investment restrictions,
Page 4
administrative restrictions, and the wrap fees imposed by wrap fee sponsors.
Item 5 - Fees and Compensation
General Fee Information
Fees paid to us are exclusive of all custodial and transaction costs paid to your custodian, brokers,
or other third-party consultants. Please see Item 12 - Brokerage Practices for additional
information. Fees paid to us are also separate and distinct from the fees and expenses charged by
mutual funds, ETFs (exchange traded funds) or other investment pools to their shareholders
(generally including a management fee and fund expenses, as described in each fund’s prospectus or
offering materials). You should review all fees charged by funds, brokers, MIM and others to fully
understand the total amount of fees paid by you for investment and financial-related services.
Portfolio Management Fees
The annual fee schedule, based on a percentage of assets under management, is as follows:
First $2,000,000
Next $8,000,000
Remainder over $10,000,000
1.00%
0.75%
0.50%
The minimum portfolio value is generally set at $1,000,000. The minimum annual fee for any account
is $5,000. At our sole discretion, we make exceptions to the foregoing or negotiate special fee
arrangements where we deem it appropriate under the circumstances.
Portfolio management fees are generally payable quarterly, in arrears. If investment management
begins after the start of a quarter, fees will be prorated accordingly. With your authorization and
unless other arrangements are made, fees are normally debited directly from your account(s).
For accounts with a margin balance, you are assessed the management fee based on the gross value
of the assets in your account. In other words, your account value on which the fee is calculated is not
reduced by the margin balance.
Either you or MIM may terminate your Investment Management Agreement at any time, subject to
any written notice requirements in the agreement. In the event of termination, any paid but unearned
fees will be promptly refunded to you based on the number of days that your account was managed,
and any fees due to us from you will be invoiced or deducted from your account prior to termination.
Item 6 - Performance-Based Fees and Side-By-Side Management
We do not have any performance-based fee arrangements. “Side-by-Side Management” refers to a
situation in which a firm manages accounts that are billed based on a percentage of assets under
management and at the same time manages other accounts for which fees are assessed on a
performance fee basis. Because we have no performance-based fee accounts, we have no side-by-
side management.
Item 7 - Types of Clients
We serve individuals, high-net-worth individuals, pension and profit-sharing plans, corporations,
trusts, estates, charitable organizations, and government entities. With some exceptions, the
minimum portfolio value eligible for conventional investment advisory services is $1,000,000, and
Page 5
the annual minimum fee charged is $5,000. Under certain circumstances and in our sole discretion,
we may negotiate such minimums.
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
In accordance with the Investment Plan, we will primarily invest your account in common stocks,
with some use of corporate, agency and municipal bonds, as well as options. To a very limited extent,
we will use ETFs and even less often will invest in mutual funds. Investing in securities involves risk
of loss, which you should be prepared to bear.
In selecting individual stocks for an account, we generally apply traditional fundamental analysis
including, without limitation, the following factors:
o Financial strength ratios;
o Price-to-earnings ratios;
o Dividend yields; and
o Growth rate-to-price earnings ratios
From time to time, we also incorporate other methods of analysis, such as technical analysis, which
involves studying past price patterns and trends in the financial markets to predict the direction of
both the overall market and specific stocks.
Changes to the buy list are initiated by members of the Investment Strategy Committee and must be
approved by the Committee. Generally, equities are chosen on the basis of their expected returns in
the future combined with sound fundamentals and reasonable valuation metrics.
At times, we use fixed-income investments as a strategic investment to fulfill liquidity or income needs
in a portfolio or to add a component of capital preservation. We will generally evaluate and select
individual bonds or bond funds based on a number of factors including, without limitation, rating,
yield and duration.
Mutual funds and ETFs are generally evaluated and selected based on a variety of factors including,
without limitation, past performance, fee structure, portfolio manager, fund sponsor, overall ratings
for safety and returns, and other factors.
Investment Strategies
Our strategic approach is to invest your portfolio in accordance with the Plan that has been developed
specifically for you. Our approach can include one or more of the following strategies, as appropriate
for you:
Our Core Equity Process is centered on buying high-quality companies with strong fundamentals
that will thrive in a strong economic environment but are well capitalized to endure a decline in
economic activity. We target companies that are market leaders in their respective sectors, with
particular emphasis on earnings quality and growth. We also target what we believe to be emerging
leaders in the mid-cap category. As a top-down manager, we are not sector neutral but will generally
not exceed two times the S&P 500 sector weight. When appropriate, we are willing to employ
derivative strategies to delay a tax event or trigger a limit order with call options after reviewing
these strategies in detail with you to be sure they are suitable.
Page 6
Our Core Value Equity Process uses the same top-down sector analysis as above plus a screen for
specific quantitative criteria, placing particular emphasis on absolute and relative valuation levels
and a price-to-earnings ratio that is less than the expected long-term estimate for earnings growth.
Our objective is to find companies trading at low price-to-earnings multiples with improving
fundamental characteristics, with a preference for dividend yields above that of the broad market.
Companies in the mid-cap category are prevalent in Core Value Equity portfolios. When appropriate,
we are willing to employ derivative strategies to delay a tax event or trigger a limit order with call
options after reviewing these strategies in detail with you to be sure they are suitable.
Our Option Overwrite Strategy provides a less aggressive alternative to a traditional equity
portfolio. The portfolio consists of a diversified selection of equity securities combined with call
options written on those same securities. This combination of long stock with short call options
provides a degree of principal protection as the call premium helps to insulate the portfolio. The
process is not dependent on rising equity markets for a positive return and is not subject to the
interest rate risk typically associated with a fixed income portfolio.
Our Active Intermediate Fixed Income Strategy focuses on securities primarily in the two- to ten-
year maturity range. We favor sectors offering excess yield to comparable Treasury securities. In
determining a portfolio’s optimum average maturity point, we analyze five primary economic
variables: monetary policy, inflation, real rate of return, economic activity level, and shape of the yield
curve. We overweight sectors we believe offer the best risk/reward ratio. Within favored sectors, we
focus on investment-grade issues.
We create portfolios of individual stocks and bonds to achieve your objective. Stocks are selected by
our Investment Strategy Committee, which reviews our Buy List on a regular basis. The following
specific strategies are available in varying combinations over time for your portfolio, depending upon
your individual circumstances.
Long-Term Purchases – securities purchased with the expectation that the value of those
securities will grow over a relatively long period of time, generally greater than one year.
Short-Term Purchases – securities purchased with the expectation that they will be sold
within a relatively short period of time, generally less than one year, to take advantage of the
securities’ short-term price fluctuations.
Margin Transactions – securities transactions in which an investor borrows money to
purchase a security and the security serves as collateral on the loan.
Options Trading/Writing - securities transactions that involve buying or selling (writing) an
option. If you write an option and the buyer exercises the option, you are obligated to
purchase or deliver a specified number of shares at a specified price at the exercise of the
option regardless of the market value of the security at the exercise or the expiration of the
option. Buying an option gives you the right to purchase or sell a specified number of shares
at a specified price at any time up to the date of expiration of the option, regardless of the
market value of the security at the exercise or the expiration of the option.
Page 7
Risk of Loss
While we seek to diversify your investment portfolio across various asset classes consistent with your
Investment Plan in an effort to reduce the risk of loss, all investment portfolios are subject to risks.
Accordingly, there can be no assurance that your investment portfolio will be able to fully meet your
investment objectives and goals or that investments will not lose money.
Below is a description of several of the principal risks that your investment portfolio faces.
Management Risks. While we manage your investment portfolio based on our experience, research
and proprietary methods, the value of your investment portfolio will change daily based on the
performance of the underlying securities in which it is invested. Accordingly, your investment
portfolio is subject to the risk that we allocate your assets to individual securities and/or asset classes
that are adversely affected by unanticipated market movements and the risk that our specific
investment choices could underperform their relevant indexes.
Risks of Investments in Mutual Funds, ETFs and Other Investment Pools. As described above, we invest
some portfolios in mutual funds, ETFs and other investment pools (“pooled investment funds”).
Investments in pooled investment funds are generally less risky than investing in individual
securities because of their diversified portfolios; however, these investments are still subject to risks
associated with the markets in which they invest. In addition, pooled investment funds’ success will
be related to the skills of their particular managers and their performance in managing their funds.
Pooled investment funds are also subject to risks due to regulatory restrictions applicable to
registered investment companies under the Investment Company Act of 1940.
Equity Market Risks. We will invest portions of your assets directly into equity investments, primarily
stocks, or into pooled investment funds that invest in the stock market. As noted above, while pooled
investments have diversified portfolios that may make them less risky than investments in individual
securities, funds that invest in stocks and other equity securities are nevertheless subject to the risks
of the stock market. These risks include, without limitation, the risks that stock values will decline
due to daily fluctuations in the markets and that stock values will decline over longer periods (e.g.,
bear markets) due to external factors that cause general market declines in the stock prices for all
companies, regardless of any individual security’s prospects.
Fixed Income Risks. We invest some portfolios directly into fixed income instruments, such as bonds
and notes, or into pooled investment funds that invest in bonds and notes. While investing in fixed
income instruments, either directly or through pooled investment funds, is generally less volatile
than investing in stock (equity) markets, fixed income investments nevertheless are subject to risks.
These risks include, without limitation, interest rate risks (risks that changes in interest rates will
devalue the investments), credit risks (risks of default by borrowers), or maturity risk (risks that
bonds or notes will change value from the time of issuance to maturity).
Foreign Securities Risks. We invest some portfolios into pooled investment funds that invest
internationally. While foreign investments are important to the diversification of your investment
portfolio, they carry risks that may be different from U.S. investments. For example, some foreign
investments are not subject to uniform audit, financial reporting or disclosure standards, practices
or requirements comparable to those found in the U.S. Some foreign investments are also subject to
foreign withholding taxes and the risk of adverse changes in investment or exchange control
regulations. Finally, foreign investments can involve currency risk, which is the risk that the value of
Page 8
the foreign security will decrease due to changes in the relative value of the U.S. dollar and the
security’s underlying foreign currency.
Short-Term Trading Risks. While we generally purchase securities with the intent to hold them for
more than a year, on occasion we may determine to buy or sell securities and hold them for less than
a year. Some of the risks associated with short-term trading that could affect investment
performance are increased commissions and transaction costs to your account and increased tax
obligations on the gains in a security’s value.
Options Risk. A small investment in options could have a potentially large impact on an investor’s
performance. The use of options involves risks different from, or possibly greater than, the risks
associated with investing directly in the underlying assets. Derivatives can be highly volatile, illiquid
and difficult to value, and there is the risk that a hedging technique will fail if changes in the value of
a derivative held by an investor do not correlate with the securities being hedged.
Margin Risk. We use margin as an investment strategy in limited situations as appropriate in light of
your circumstances. In addition, you can elect to borrow funds against your investment portfolio for
uses other than investing inside your managed account. When securities are purchased, they may be
paid for in full or you may borrow part of the purchase price from the account custodian. If you
borrow part of the purchase price, you are engaging in margin transactions, and there is risk involved
with investing on margin. The securities held in a margin account are collateral for the custodian that
loaned you money. If those securities decline in value, then the value of the collateral supporting your
loan also declines. As a result, the brokerage firm is required to take action in order to maintain the
necessary level of equity in your account. The brokerage firm may issue a margin call and/or sell
other assets in your account to accomplish this. It is important that you fully understand the risks
involved in trading securities on margin, including but not limited to:
•
•
•
•
•
•
It is possible to lose more funds than are deposited into a margin account;
The account custodian can force the sale of assets in your account;
The account custodian can sell assets in your account without contacting you first;
The account holder is not entitled to choose which assets in a margin account may be
sold to meet a margin call;
The account custodian can increase its “house” maintenance margin requirements at
any time without advance written notice; and
The account holder is not entitled to an extension of time on a margin call.
Cybersecurity Risk. The computer systems, networks, devices, and service providers we use to carry
out routine business operations employ a variety of protections designed to prevent damage or
interruption from computer viruses, network failures, computer and telecommunication failures,
infiltration by unauthorized persons, and security breaches. Despite the various protections utilized,
these systems, networks, devices, and providers potentially can be breached. A client could be
negatively impacted as a result of a cybersecurity breach.
Cybersecurity breaches can include unauthorized access to systems, networks, or devices; infection
from computer viruses or other malicious software code; and attacks that shut down, disable, slow,
or otherwise disrupt operations, business processes, or website access or functionality.
Cybersecurity breaches can cause disruptions and affect business operations, potentially resulting in
Page 9
financial losses to a client; impediments to trading; the inability by us and other service providers to
transact business; violations of applicable privacy and other laws; regulatory fines, penalties,
reputational damage, reimbursement or other compensation costs, or additional compliance costs;
as well as the inadvertent release of confidential information.
Similar adverse consequences can result from cybersecurity breaches affecting issuers of securities
in which a client invests; governmental and other regulatory authorities; exchange and other
financial market operators, banks, brokers, dealers, and other financial institutions; and other
parties. In addition, these entities can incur substantial costs to prevent or mitigate the risk of
cybersecurity breaches in the future.
Item 9 - Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of MIM or the integrity of our
management.
In March 2016, Marco Investment Management (“MIM”) and Steven Marco entered into a settlement
with the U.S. Securities and Exchange Commission (the "SEC") to resolve certain aspects of our
operations that the SEC alleged violated the Investment Advisers Act of 1940 and two related rules
with respect to recordkeeping, calculation of assets under management, and the adequacy of
compliance policies and procedures. Primarily, the settlement concerned the manner in which we
calculated management fees for certain clients. We contacted each affected client and refunded any
fees the SEC alleged to be excessive, without regard to any underbillings to the same client. In
addition, for a period of three years, Mr. Marco was not permitted to serve as Chief Compliance Officer
or compliance officer for any broker, dealer, investment adviser, municipal securities dealer,
municipal advisor, transfer agent, or nationally recognized statistical rating organization. The Order
Instituting Proceedings, which sets forth the SEC's allegations as well as the administrative and
monetary sanctions imposed, can be found at https://www.sec.gov/litigation/admin/2016/ia-
4348.pdf. MIM and Mr. Marco neither admitted nor denied its allegations.
Item 10 - Other Financial Industry Activities and Affiliations
Neither MIM nor our Management Persons have any other financial industry activities or affiliations
to report.
Item 11 - Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading
Code of Ethics and Personal Trading
We have adopted a Code of Ethics (“the Code”), the full text of which is available to you upon request.
Our Code has several goals. First, the Code is designed to assist us in complying with applicable laws
and regulations governing our investment advisory business. Under the Investment Advisers Act of
1940, we owe fiduciary duties to our clients. Pursuant to these fiduciary duties, the Code requires
persons associated with us (managers, officers and employees) to act with honesty, good faith and
fair dealing in working with clients. In addition, the Code prohibits such associated persons from
trading or otherwise acting on insider information.
Next, the Code sets forth guidelines for professional standards for our associated persons. Under the
Code’s Professional Standards, we expect our associated persons to put the interests of our clients
Page 10
first, ahead of personal interests. In this regard, our associated persons are not to take inappropriate
advantage of their positions in relation to our clients.
Third, the Code sets forth policies and procedures to monitor and review the personal trading
activities of associated persons. From time to time, our associated persons may invest in the same
securities recommended to clients. Under our Code, we have adopted procedures designed to reduce
or eliminate conflicts of interest that this could potentially cause. The Code’s personal trading
policies include procedures for limitations on personal securities transactions of associated persons,
reporting and review of such trading, and pre-clearance of certain types of personal trading activities.
These policies are designed to discourage and prohibit personal trading that would disadvantage
clients. The Code also provides for disciplinary action as appropriate for violations.
Participation or Interest in Client Transactions
Because associated persons may invest in the same securities as those held in client accounts, we
have established a policy requiring our associated persons to pre-clear transactions in some types of
securities with our Chief Compliance Officer. The goal of this policy is to avoid any conflicts of interest
that arise in these situations. Some types of securities, such as CDs, treasury obligations and open-
end mutual funds are exempt from this pre-clearance requirement. However, in the event of other
identified potential trading conflicts of interest, our goal is to place client interests first.
Consistent with the foregoing, we maintain policies regarding participation in initial public offerings
(“IPOs”) and private placements in order to comply with applicable laws and avoid conflicts with
client transactions. If our associated person wishes to participate in an IPO or invest in a private
placement, he or she must submit a pre-clearance request and obtain the approval of our Chief
Compliance Officer. If associated persons trade with client accounts (e.g., in a bundled or aggregated
trade) and a trade is not filled in its entirety, the associated person’s share quantity will be removed
from the block and the balance of shares will be allocated among client accounts in accordance with
our written policy.
Item 12 - Brokerage Practices
Best Execution and Benefits of Brokerage Selection
When given discretion to select the brokerage firm that will execute orders in your account, we seek
“best execution” for client trades, which is a combination of a number of factors including, without
limitation, quality of execution, services provided, and commission rates. Therefore, we may use or
recommend the use of brokers who do not charge the lowest available commission in the recognition
of research and securities transaction services or quality of execution. Research services received
with transactions can include proprietary or third-party research (or any combination) and can be
used in servicing any or all of our clients. Therefore, research services received can at times be used
for other accounts and not for the account for which the particular transaction was effected.
Receiving research or other products or services can create an incentive to select or recommend a
broker-dealer based on our interest in receiving the research or other products or services, rather
than on our clients’ interest in receiving best execution. While we recommend that you establish a
brokerage account with Charles Schwab & Co., Inc. (“Schwab”), a FINRA registered broker-dealer,
member SIPC, as the qualified custodian to maintain custody of your assets, we will effect trades for
your account at Schwab or can in some instances, consistent with our duty of best execution and
specific agreement with you, elect to execute trades elsewhere. Although we may recommend that
Page 11
you establish an account at Schwab, it is ultimately your decision to custody assets with Schwab. We
are independently owned and operated and are not affiliated with Schwab.
Schwab Advisor Services provides us with access to institutional trading, custody, reporting and
related services, which are typically not available to Schwab retail investors. Schwab also makes
available various support services. Some of those services help us manage or administer your
account, while others help us manage and grow our business. These services generally are available
to independent investment advisors on an unsolicited basis at no charge to them. Schwab’s
brokerage services for our clients include the execution of securities transactions, custody, research,
and access to mutual funds and other investments that are otherwise generally available only to
institutional investors or that would require a significantly higher minimum initial investment.
For our client accounts maintained in its custody, Schwab generally does not charge separately for
custody services but is compensated by account holders through commissions or other fees on trades
that it executes or that settle into your Schwab account. Certain trades at Schwab do not incur
commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested
cash in your account. Schwab Advisor Services also makes available to us other products and services
that benefit us but do not necessarily directly benefit our clients’ accounts. We use some of these
products and services to benefit all or a substantial number of our clients’ accounts, including
accounts not maintained at Schwab. These services are not soft dollar arrangements and are part of
the institutional platform offered by Schwab.
Schwab’s products and services that assist us in managing and administering clients’ accounts
include software and other technology that (i) provide access to client account data (such as trade
confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade
orders for multiple client accounts; (iii) provide pricing and other market data; (iv) facilitate payment
of our fees from our clients’ accounts; and (v) assist with back-office functions, recordkeeping and
client reporting.
Schwab Advisor Services also offers other services intended to help us manage and further develop
our business enterprise. These services may include: (i) technology, compliance, legal and business
consulting; (ii) publications and conferences on practice management and business succession; and
(iii) access to employee benefits providers, human capital consultants and insurance providers.
Schwab may make available, arrange and/or pay third-party vendors for the types of services
rendered to us. Schwab Advisor Services can discount or waive fees it would otherwise charge for
some of these services or pay all or a part of the fees of a third party providing these services to us.
Schwab Advisor Services also provides other benefits such as educational events or occasional
business entertainment for our personnel. In evaluating whether to recommend that clients custody
their assets at Schwab, we take into account the availability of some of the foregoing products and
services and other arrangements as part of the total mix of factors we consider and not solely the
nature, cost or quality of custody and brokerage services provided by Schwab.
Receiving products, services and fee discounts or waivers from Schwab or any broker-dealer poses a
conflict of interest, as it creates an incentive to recommend a custodian that provides products,
services, and fee discounts or waivers over those who do not. We address these conflicts by disclosing
them to our clients and by periodically reviewing the quality and cost of the services and execution
quality provided to our clients by the custodian broker-dealer we recommend.
Page 12
Directed Brokerage
You may direct us to use a particular broker for custodial or transaction services on behalf of your
portfolio. In directed brokerage arrangements, you are responsible for negotiating the commission
rates and other fees to be paid to the broker. Accordingly, if you choose to direct brokerage, you
should consider whether such designation may result in certain costs or disadvantages to you, either
because you may pay higher commissions or obtain less favorable execution or because the
designation limits the investment options available to you.
The arrangement that we have with Schwab is designed to maximize efficiency and be cost effective.
By directing brokerage arrangements, you acknowledge that these economies of scale and levels of
efficiency are generally compromised when alternative brokers are used. While every effort is made
to treat clients fairly over time, the fact that a client chooses to use the brokerage and/or custodial
services of an alternative service provider can result in a certain degree of delay in executing trades
for their account(s) and otherwise adversely affect management of their account(s).
By directing us to use a specific broker or dealer, clients who are subject to ERISA confirm and agree
with us that they have the authority to make the direction, that there are no provisions in any client
or plan document which are inconsistent with the direction, that the brokerage and other goods and
services provided by the broker or dealer through the brokerage transactions are provided solely to
and for the benefit of the client’s plan, plan participants and their beneficiaries, that the amounts paid
for the brokerage and other services have been determined by the client and the plan to be
reasonable, that any expenses paid by the broker on behalf of the plan are expenses that the plan
would otherwise be obligated to pay, and that the specific broker or dealer is not a party in interest
of the client or the plan as defined under applicable ERISA regulations.
Aggregated Trade Policy
We enter some trades as a block where possible and when advantageous to multiple clients whose
accounts have a need to buy or sell shares of the same security. This method permits trading
aggregate blocks of securities composed of assets from multiple client accounts, which allows us to
execute trades in a timely, equitable manner in an effort to reduce overall costs to clients.
We only aggregate transactions when we believe that aggregation is consistent with our duty to seek
best execution (which includes the duty to seek best price) for you and is consistent with the terms
of our Investment Advisory Agreement with you for which trades are being aggregated. No advisory
client will be favored over any other client. Each client that participates in an aggregated order will
participate at the average share price for all MIM’s transactions in a given security on a given business
day. Transaction costs for participating accounts will be assessed at the custodian’s commission rate
applicable to each account; therefore, transaction costs can vary among accounts. Sometimes
accounts are excluded from a block due to tax considerations, client direction or other factors that
make the account’s participation ineligible or impractical.
Before entering an aggregated order, we prepare a written statement (“Allocation Statement”)
specifying the participating client accounts and how we intend to allocate the order among those
clients. If the aggregated order is filled in its entirety, it gets allocated among clients in accordance
with the Allocation Statement. If the order is partially filled, it is generally allocated pro rata, based
on the Allocation Statement, or randomly in certain circumstances. Notwithstanding the foregoing,
an order can be allocated on a basis different from that specified in the Allocation Statement if all
client accounts receive fair and equitable treatment and the reason for different allocation is
Page 13
explained in writing and is approved by an appropriate individual/officer of MIM. Our books and
records will separately reflect, for each client account included in a block trade, the securities held by
and bought and sold for that account. When funds and securities of clients whose orders are
aggregated will be deposited with one or more banks or broker-dealers, neither the clients’ cash nor
their securities will be held collectively any longer than is necessary to settle the transaction on a
delivery versus payment basis. Cash or securities held collectively for clients will be delivered out to
the custodian bank or broker-dealer as soon as practicable following the settlement, and we will
receive no additional compensation or remuneration of any kind as a result of the proposed
aggregation.
We direct trading in your account as and when trades are appropriate based on your Investment Plan,
without regard to activity in other client accounts.
Item 13 - Review of Accounts
Managed portfolios are reviewed at least quarterly but can be reviewed more often if requested by
you, upon receipt of information material to the management of your portfolio, or at any time such
review is deemed necessary or advisable by us. These factors generally include, but are not limited
to, the following: change in your general circumstances (marriage, divorce, retirement) or economic,
political or market conditions. Our team of Portfolio Managers, described in Part 2B of this Brochure,
reviews accounts.
Account custodians are responsible for providing monthly or quarterly account statements which
reflect the positions (and current pricing) in each account as well as transactions in each account,
including fees paid from an account. Account custodians also provide prompt confirmation of all
trading activity and provide year-end tax statements, such as 1099 forms. In addition, we provide a
report at least annually for each managed portfolio. This written report normally includes a
summary of portfolio holdings and performance results. You are encouraged to compare reports
from account custodians to the reports we provide. There may be small differences due to
variations in the reporting of accrued interest, pending dividends, fractional shares or other similar
issues. Additional reports are available at your request.
Item 14 - Client Referrals and Other Compensation
We have engaged a third-party marketing firm to provide lists of potential client leads to us. The
marketing firm does not recommend us to the potential clients. Rather, it provides to us a list of leads
based on investor inputs into the marketing firm’s online profile tool. The fee we pay for being
provided with potential leads is payable regardless of whether a prospect becomes our advisory
client.
In addition, as noted above, we receive an economic benefit from Schwab in the form of support
products and services it makes available to us and other independent investment advisors that have
their clients maintain accounts at Schwab. These products and services, how they benefit our firm,
and the related conflicts of interest are described in Item 12 - Brokerage Practices. The availability
of Schwab’s products and services to us is based solely on our participation in the programs and not
on the provision of any particular investment advice.
We previously maintained a referral arrangement with Schwab through Schwab’s Advisor Network
(the “Service”). The Service is designed to assist clients in finding an independent investment adviser.
Schwab is not an affiliate of ours and does not supervise us in any way. We pay Schwab legacy fees
on all past referred client accounts custodied at Schwab that we still manage. The fee is a percentage
Page 14
of the value of assets under management and is paid to Schwab quarterly. This fee may be increased,
decreased or waived by Schwab from time to time at Schwab’s discretion. The fee is paid by us and
not by the clients. We do not charge clients referred by Schwab any fees or costs that are higher than
our standard fee schedule. We have agreed not to charge clients referred through the Service any fees
or costs greater than the fees or costs we charge clients with similar portfolios who were not referred
through the Service.
With respect to client accounts referred to us through this service, we generally pay Schwab a
“NonSchwab Custody Fee” if custody of a referred client’s account is not maintained by, or assets in
the account are transferred from, Schwab. This fee does not apply if the client was solely responsible
for the decision not to maintain custody at Schwab. The "Non-Schwab Custody Fee” is a one-time
payment equal to a percentage of the assets placed with a custodian other than Schwab and is higher
than the Participation Fee that we would normally pay in a single year. As noted in Item 12 –
Brokerage Practices, to address these potential conflicts of interest, we have developed and
implemented a Compliance Program that includes ongoing review of the services that Schwab
provides to both our firm and you, as well as the execution quality provided by Schwab.
For accounts held at Schwab under the Service, Schwab will not charge separately for custody but
will receive compensation in the form of commissions or other transaction-related compensation on
securities trades executed through Schwab. Schwab will also receive a fee for clearance and
settlement of trades executed through outside broker-dealers, which is in addition to fees charged by
the other broker-dealer. For clients referred through the Schwab Advisor Network, we have an
incentive to execute trades through Schwab subject to our duty of best execution, as described in
Item 12 – Brokerage Practices. To address these potential conflicts of interest, we have developed
and implemented a Compliance Program, which includes ongoing review of the services that Schwab
provides to our firm and our clients, as well as the execution quality provided by Schwab.
Item 15 - Custody
Schwab is the qualified custodian of nearly all client accounts at MIM. From time to time however,
some clients select an alternate broker to hold accounts in custody. In any case, it is the qualified
custodian’s responsibility to provide you with confirmations of trading activity, tax forms and at least
quarterly account statements. You are advised to review this information carefully and to notify us
of any questions or concerns. You are also asked to promptly notify us if the custodian fails to provide
statements on each account held.
From time to time and in accordance with our agreement with you, we will provide additional reports.
The account balances reflected on these reports should be compared to the balances shown on the
brokerage statements to ensure accuracy. There may at times be small differences due to the timing
of dividend reporting, pending trades or other similar issues.
Item 16 - Investment Discretion
As described above under Item 4 - Advisory Business, we manage your portfolio on a discretionary
basis. After an Investment Plan is developed for your investment portfolio, we execute that plan
without specific consent from you for each transaction. For discretionary accounts, a Limited Power
of Attorney (“LPOA”) is executed by you, giving us the authority to carry out various activities in your
account, generally including the following: executing trades; requesting checks on your behalf; and
Page 15
withdrawing advisory fees directly from your account. We then direct investment of your portfolio
using our discretionary authority. You may limit the terms of the LPOA to the extent consistent with
your investment advisory agreement with us and the requirements of your qualified custodian. The
discretionary relationship is further described in the agreement between you and MIM.
Item 17 - Voting Client Securities
Where we have authority to vote proxies, we will seek to vote proxies in the best interest of the
client(s) holding the applicable securities. In voting proxies, we consider factors that we believe
relate to the client’s investment(s) and factors, if any, that are set forth in written instructions from
the client.
In general, we believe that voting proxies in accordance with the following guidelines, with respect
to such routine items, is in the best interests of our clients. Accordingly, we generally vote for:
• The election of directors (where no corporate governance issues are implicated);
• Proposals that strengthen the shared interests of shareholders and management;
• The selection of independent auditors based on management or director recommendation,
unless a conflict of interest is perceived;
• Proposals that we believe may lead to an increase in shareholder value;
• Management recommendations adding or amending indemnification provisions in charter or
by-laws; and
• Proposals that maintain or increase the rights of shareholders.
We will generally vote against any proposals that we believe will have a negative impact on
shareholder value or rights. If we perceive a conflict of interest, our policy is to notify affected clients
so that they may choose the course of action they deem most appropriate.
We generally do not accept directed votes from you. If you would like to direct our vote in a particular
solicitation, it is your responsibility to contact us in writing prior to the voting deadline.
As stated earlier, our goal is to vote proxies in the best interest of the client(s). To that end, we have
engaged Broadridge, a Voting Agent Service, to facilitate our proxy voting service. A copy of our
complete policy and records of proxies voted are available to you upon request at 404-504-8600. As
required under the Advisers Act, such records are maintained for a period of five (5) years.
Where we do not have authority to vote proxies, clients receive their proxies and solicitations directly
from the custodian. Call us if you have any questions about a particular situation.
Item 18 - Financial Information
We neither require nor solicit prepayment of more than $1,200 in fees per client, six months or more
in advance. No financial condition is likely to impair our ability to meet contractual obligations to
clients.
Page 16
Exhibit A
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Steven S. Marco, CFA
CRD# 2076950
of
Marco Investment Management, LLC
1100 Atlanta Financial Center
3353 Peachtree Road NE
Atlanta, Georgia 30326
(404) 504-8600
www.MarcoInv.com
March 20, 2025
This Brochure Supplement provides information about Steven Marco and supplements the Marco
Investment Management, LLC (“MIM”) Brochure. You should have received a copy of that Brochure.
Please contact us at (404) 504-8600 if you did not receive our Brochure or if you have any questions
about the contents of this Supplement.
Additional information about Steven is available on the SEC’s website at www.AdviserInfo.sec.gov.
Item 2 - Educational Background and Business Experience
Steven S. Marco (year of birth 1969) is Founder and Portfolio Manager at MIM. Steven heads the
Investment Strategy Committee, is responsible for derivative strategies, and oversees the trading
desk. He founded the firm in 1998 after leaving NationsBank (now Bank of America).
While at NationsBank, Steven managed portfolios for high-net-worth and institutional clients and
pioneered the bank’s use of derivative contracts to hedge risk for concentrated equity positions in
taxable accounts. During his studies at Emory University, Steven developed a strong working
knowledge of equity option contracts and authored several research papers on option pricing during
graduate school.
Exhibit A-1
Steven holds undergraduate degrees in Economics and Political Science from Emory University and
a Master of Business Administration, also from Emory University. He holds the Chartered Financial
Analyst® designation* and is a member of CFA Society Atlanta.
* The Chartered Financial Analyst® (“CFA®”) designation is a professional designation given by the
CFA Institute that measures the competence and integrity of financial analysts. The CFA Program is a
graduate-level self-study program that combines a broad-based curriculum of investment principles
with professional conduct requirements. Candidates are required to pass three levels of
examinations covering areas such as accounting, economics, ethics, money management and security
analysis. Before a candidate is eligible to become a CFA charterholder, he/she must meet minimum
experience requirements in the area of investment/financial practice. To enroll in the program, a
candidate must hold a bachelor’s degree.
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser. In March 2016, Marco Investment Management
(“MIM”) and Steven Marco entered into a settlement with the U.S. Securities and Exchange
Commission (the "SEC") to resolve certain aspects of our operations that the SEC alleged violated the
Investment Advisers Act of 1940 and two related rules with respect to recordkeeping, calculation of
assets under management, and the adequacy of compliance policies and procedures. Primarily, the
settlement concerned the manner in which we calculated management fees for certain clients. We
contacted each affected client and refunded any fees the SEC alleged to be excessive, without regard
to any underbillings to the same client. In addition, for a period of three years, Mr. Marco was not
permitted to serve as Chief Compliance Officer or compliance officer for any broker, dealer,
investment adviser, municipal securities dealer, municipal advisor, transfer agent, or nationally
recognized statistical rating organization. The Order Instituting Proceedings, which sets forth the
SEC's allegations as well as the administrative and monetary sanctions imposed, can be found at
https://www.sec.gov/litigation/admin/2016/ia-4348.pdf. MIM and Mr. Marco neither admitted nor
denied its allegations.
Item 4 - Other Business Activities
Steven is not engaged in any other business activities.
Item 5 - Additional Compensation
Steven has no other income or compensation to disclose.
Item 6 - Supervision
Steven is the President and Sole Owner of MIM. He is a Portfolio Manager and leads the Investment
Strategy Committee. Overall investment decisions are made as a team by the Investment Strategy
Committee, and portfolio activity based on these decisions will be carried out by these individuals,
as assisted by other staff members of the firm.
Mark Burton, Chief Compliance Officer, is responsible for providing compliance oversight for Steven
and for reviewing accounts. Mark can be reached at (404) 504-8600.
Exhibit A-2
Item 1 - Cover Page
of
Brochure Supplement for
Kenneth M. Ezell, CFA
CRD# 1233609
of
Marco Investment Management, LLC
1100 Atlanta Financial Center
3353 Peachtree Road NE
Atlanta, Georgia 30326
(404) 504-8600
www.MarcoInv.com
March 20, 2025
This Brochure Supplement provides information about Ken Ezell and supplements the Marco
Investment Management, LLC (“MIM”) Brochure. You should have received a copy of that Brochure.
Please contact us at (404) 504-8600 if you did not receive our Brochure or if you have any questions
about the contents of this Supplement.
Additional information about Ken is available on the SEC’s website at www.AdviserInfo.sec.gov.
Item 2 - Educational Background and Business Experience
Kenneth M. Ezell (year of birth 1957) is a Portfolio Manager at MIM and is responsible for the
management of equity, balanced, and fixed income accounts. Ken also serves on our Investment
Strategy Committee.
Ken has over forty years of investment management experience. Prior to joining NewCrest Advisors
in 1995, he spent ten years as a Senior Portfolio Manager at NationsBank Investment Management
handling both high-net-worth and institutional accounts. Ken began his career in 1981 as a Portfolio
Manager at Deposit Guaranty National Bank.
Exhibit A-3
Ken is a graduate, with honors, of Millsaps College with both undergraduate and Master’s degrees in
Business Administration. In addition, he holds the Chartered Financial Analyst® designation* and is
a member of CFA Society Atlanta. Ken has held the Uniform Investment Adviser license (Series 65).
Previously in his career, Ken has held licenses as General Securities Representative, Uniform
Securities Agent, and Municipal Securities Principal (Series 7, 63, and 53).
Ken has an interest in historic preservation and photography. He and his family live in a restored
Victorian home near downtown Atlanta.
* The Chartered Financial Analyst® (“CFA®”) designation is a professional designation given by the
CFA Institute that measures the competence and integrity of financial analysts. The CFA Program is a
graduate-level self-study program that combines a broad-based curriculum of investment principles
with professional conduct requirements. Candidates are required to pass three levels of
examinations covering areas such as accounting, economics, ethics, money management and security
analysis. Before a candidate is eligible to become a CFA charterholder, he/she must meet minimum
experience requirements in the area of investment/financial practice. To enroll in the program, a
candidate must hold a bachelor’s degree.
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Ken has no such disciplinary
information to report.
Item 4 - Other Business Activities
Ken is not engaged in any other business activities.
Item 5 - Additional Compensation
Ken has no other income or compensation to disclose.
Item 6 - Supervision
Ken is a Portfolio Manager and serves on the Investment Strategy Committee. Overall investment
decisions are made as a team by the Investment Strategy Committee, and portfolio activity based on
these decisions will be carried out by these individuals, as assisted by other staff members of the
firm.
Mark Burton, Chief Compliance Officer, is responsible for providing compliance oversight for Ken and
for reviewing accounts. Mark can be reached at (404) 504-8600.
Exhibit A-4
Item 1 - Cover Page
of
Brochure Supplement for
Lisa K. Burton
of
Marco Investment Management, LLC
1100 Atlanta Financial Center
3353 Peachtree Road NE
Atlanta, Georgia 30326
(404) 504-8600
www.MarcoInv.com
March 20, 2025
This Brochure Supplement provides information about Lisa Burton and supplements the Marco
Investment Management, LLC (“MIM”) Brochure. You should have received a copy of that Brochure.
Please contact us at (404) 504-8600 if you did not receive our Brochure or if you have any questions
about the contents of this Supplement.
Item 2 - Educational Background and Business Experience
Lisa K. Burton (year of birth 1964) is a Trading Specialist and Analyst at MIM. Lisa’s responsibilities
include lead trading, implementing derivative strategies, and portfolio support. She is also a member
of the Investment Strategy Committee.
A native of North Carolina, Lisa began her career in the financial industry in 1990. Her background
began with Columbia Bank in Columbia, Maryland, as an Accounting Assistant to the CFO. A move to
Georgia transitioned her career to Bank of America as a Portfolio Assistant to the high-net-worth
client group, where she was responsible for trading and portfolio support to several portfolio
managers until 1998, at which time Lisa joined our firm.
Lisa is a 1989 graduate of Appalachian State University with a BSBA in Finance and International
Business.
Exhibit A-5
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Lisa has no such disciplinary
information to report.
Item 4 - Other Business Activities
Lisa is not engaged in any other business activities.
Item 5 - Additional Compensation
Lisa has no other income or compensation to disclose.
Item 6 - Supervision
Lisa Burton is a Trading Specialist and Analyst and serves on the Investment Strategy Committee.
Overall investment decisions are made as a team by the Investment Strategy Committee, and
portfolio activity based on these decisions will be carried out by these individuals, as assisted by
other staff members of the firm.
Mark Burton, Chief Compliance Officer, is responsible for providing compliance oversight for Lisa and
for reviewing accounts. Mark can be reached at (404) 504-8600.
Exhibit A-6
Item 1 - Cover Page
of
Brochure Supplement for
David G. McBride, CFA
CRD# 3025522
of
Marco Investment Management, LLC
1100 Atlanta Financial Center
3353 Peachtree Road NE
Atlanta, Georgia 30326
(404) 504-8600
www.MarcoInv.com
March 20, 2025
This Brochure Supplement provides information about David McBride, and supplements the Marco
Investment Management, LLC (“MIM”) Brochure. You should have received a copy of that Brochure.
Please contact us at (404) 504-8600 if you did not receive our Brochure, or if you have any questions
about the contents of this Supplement.
Additional information about David is available on the SEC’s website at www.AdviserInfo.sec.gov.
Item 2 - Educational Background and Business Experience
David G. McBride (year of birth 1968) is a Portfolio Manager at MIM. David is responsible for the
management of equity, balanced and fixed income accounts and serves on our Investment Strategy
Committee.
David has over 20 years of investment management experience. He began his career as a Research
Analyst with a local money management firm and later worked as a Portfolio Analyst with
PaineWebber. Prior to joining MIM, David spent eight years working as a Portfolio Manager handling
both high-net-worth and institutional accounts.
Exhibit A-7
David holds a BS degree from Auburn University and an MBA with a concentration in Finance from
Georgia State University. He holds the Chartered Financial Analyst® designation* and is a member of
CFA Society Atlanta.
* The Chartered Financial Analyst® (“CFA®”) designation is a professional designation given by the
CFA Institute that measures the competence and integrity of financial analysts. The CFA Program is a
graduate-level self-study program that combines a broad-based curriculum of investment principles
with professional conduct requirements. Candidates are required to pass three levels of
examinations covering areas such as accounting, economics, ethics, money management and security
analysis. Before a candidate is eligible to become a CFA charterholder, he/she must meet minimum
experience requirements in the area of investment/financial practice. To enroll in the program, a
candidate must hold a bachelor’s degree.
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, David has no such disciplinary
information to report.
Item 4 - Other Business Activities
David is not engaged in any other business activities.
Item 5 - Additional Compensation
David has no other income or compensation to disclose.
Item 6 - Supervision
David is a Portfolio Manager and serves on the Investment Strategy Committee. Overall investment
decisions are made as a team by the Investment Strategy Committee, and portfolio activity based on
these decisions will be carried out by these individuals, as assisted by other staff members of the
firm.
Mark Burton, Chief Compliance Officer, is responsible for providing compliance oversight for David
and for reviewing accounts. Mark can be reached at (404) 504-8600.
Exhibit A-8
Item 1 - Cover Page
of
Brochure Supplement for
John V. Hussa
CRD# 3045186
of
Marco Investment Management, LLC
1100 Atlanta Financial Center
3353 Peachtree Road NE
Atlanta, Georgia 30326
(404) 504-8600
www.MarcoInv.com
March 20, 2025
This Brochure Supplement provides information about John Hussa and supplements the Marco
Investment Management, LLC (“MIM”) Brochure. You should have received a copy of that Brochure.
Please contact us at (404) 504-8600 if you did not receive our Brochure or if you have any questions
about the contents of this Supplement.
Additional information about John is available on the SEC’s website at www.AdviserInfo.sec.gov.
Item 2 - Educational Background and Business Experience
John V. Hussa (year of birth 1970) joined MIM in 2004 and is the Director of Marketing. John also
serves on our Investment Strategy Committee.
A graduate of The Citadel in Charleston, South Carolina, John began his career as a Finance Officer in
the US Air Force. In 1997, he entered the investment management business, working at Smith Barney
and at Charles Schwab before joining our firm.
Exhibit A-9
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, John has no such disciplinary
information to report.
Item 4 - Other Business Activities
John is not engaged in any other business activities.
Item 5 - Additional Compensation
John has no other income or compensation to disclose.
Item 6 - Supervision
John Hussa serves on the Investment Strategy Committee. Overall investment decisions are made as
a team by the Investment Strategy Committee, and portfolio activity based on these decisions will be
carried out by these individuals, as assisted by other staff members of the firm.
Mark Burton, Chief Compliance Officer, is responsible for providing compliance oversight for John
and for reviewing accounts. Mark can be reached at (404) 504-8600.
Exhibit A-10
Item 1 - Cover Page
of
Brochure Supplement for
Kristen G. Berndsen
of
Marco Investment Management, LLC
1100 Atlanta Financial Center
3353 Peachtree Road NE
Atlanta, Georgia 30326
(404) 504-8600
www.MarcoInv.com
March 20, 2025
This Brochure Supplement provides information about Kristen Berndsen and supplements the Marco
Investment Management, LLC (“MIM”) Brochure. You should have received a copy of that Brochure.
Please contact Marco at (404) 504-8600 if you did not receive our Brochure or if you have any
questions about the contents of this Supplement.
Item 2 - Educational Background and Business Experience
Kristen G. Berndsen (year of birth 1970) is a Trading Specialist and Analyst at MIM and is responsible
for both equity and fixed income trading, coupled with many day-to-day operations. Kristen is also a
member of the Investment Strategy Committee.
Kristen has over 30 years of industry experience. She embarked on her career working at
PaineWebber in 1992. Kristen began in operations and moved into an analyst position while
achieving an MBA in the evening program at Emory.
Kristen holds both BBA and MBA degrees from Emory University in Atlanta.
Exhibit A-11
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Kristen has no such disciplinary
information to report.
Item 4 - Other Business Activities
Kristen is not engaged in any other business activities.
Item 5 - Additional Compensation
Kristen has no other income or compensation to disclose.
Item 6 - Supervision
Kristen is a Trading Specialist and Analyst and serves on the Investment Strategy Committee. Overall
investment decisions are made as a team by the Investment Strategy Committee, and portfolio
activity based on these decisions will be carried out by these individuals, as assisted by other staff
members of the firm.
Mark Burton, Chief Compliance Officer, is responsible for providing compliance oversight for Kristen
and for reviewing accounts. Mark can be reached at (404) 504-8600.
Exhibit A-12