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MBL Wealth
FORM ADV PART 2A
BROCHURE
MBL Wealth, LLC
301 S. McDowell Street
Suite 1100
Charlotte, NC 28204
www.mbl-advisors.com
Telephone: 704-333-8461
Email: info@mbl-advisors.com
Brochure Date: March 10, 2025
This Brochure provides information about the qualifications and business practices of MBL
Wealth, LLC (hereinafter, “MBL Wealth,” “Firm,” “Our,” “Us” or “We”). MBL Wealth also
operates under the name MBL Advisors. Our Firm is an investment adviser registered with the
Securities and Exchange Commission. Registration does not imply a certain level of skill or
training, only that We have filed registration documents in the appropriate jurisdictions. The
information in this Brochure has not been approved or verified by the United States Securities
and Exchange Commission (“SEC”) or by any state securities authority.
Additional information about MBL Wealth can be found on the SEC’s website at
www.adviserinfo.sec.gov by using Our identification number referred to as a “CRD Number.”
MBL Wealth’s CRD Number is 305176. If clients have any questions about the contents of
this Brochure, please contact Us at the telephone number or email address shown above.
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MATERIAL CHANGES (ITEM 2)
This section of the Disclosure Brochure addresses only those “material changes” that have
been incorporated since Our last delivery or posting of this Brochure on the SEC’s public
disclosure website (IAPD) at www.adviserinfo.sec.gov.
This version of Our Brochure, dated, March 10, 2025, serves as an annual updating
amendment. The following are the material changes since Our last annual updating
amendment dated February 27, 2024:
MBL Wealth has modified Item 14 of this Brochure to disclose its relationship with a paid
Promoter. For more information, please see Item 14 of this Brochure.
We may, at any time, update this Disclosure Brochure and send a copy to the client with a
summary of material changes, or send the client only a summary of material changes that
includes an offer to send the client a copy of the full Brochure either by electronic means
(email) or in hard copy form.
If a client would like another copy of this Disclosure Brochure, please download it from the
SEC website as indicated above, download it from the MBL Wealth website at www.mbl-
advisors.com or contact Chief Compliance Officer, Stephen Marciniak at 704-335-4531 or via
email at info@mbl-advisors.com.
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TABLE OF CONTENTS (ITEM 3)
FORM ADV PART 2A ........................................................................................................................ 1
MATERIAL CHANGES (Item 2) ......................................................................................................... 2
TABLE OF CONTENTS (Item 3) ......................................................................................................... 3
ADVISORY SERVICES (Item 4) .......................................................................................................... 5
About the Firm ............................................................................................................................ 5
Types of Advisory Services ........................................................................................................ 5
Wealth Management Services .............................................................................................. 5
Selection of Other Advisers ................................................................................................... 7
Financial Planning Services .................................................................................................. 7
Retirement Plan Consulting Services ....................................................................................... 8
Assets Under Management ..................................................................................................... 10
FEES AND COMPENSATION (Item 5) ............................................................................................. 10
Wealth Management Fees ...................................................................................................... 11
Other Types of Fees & Expenses ............................................................................................ 13
PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT (Item 6) ................................... 14
TYPES OF CLIENTS (Item 7)............................................................................................................ 14
METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS (Item 8) ....................... 14
Methods of Analysis and Investment Strategies ................................................................... 14
Investment Strategies: ............................................................................................................. 14
Risk of Investing: ...................................................................................................................... 15
Recommendation of Specific Type of Securities ................................................................... 16
DISCIPLINARY INFORMATION (Item 9) ......................................................................................... 17
OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS (Item 10) ...................................... 17
Registered Representatives of a Broker Dealer .................................................................... 18
Licensed Insurance Agents ..................................................................................................... 18
CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL
TRADING (Item 11) ........................................................................................................................ 18
Code of Ethics .......................................................................................................................... 18
Participation or Interest in Client Transactions ...................................................................... 19
Proprietary Trading................................................................................................................... 19
Simultaneous Trading .............................................................................................................. 19
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BROKERAGE PRACTICES (Item 12) ................................................................................................ 19
Selection and Recommendation ............................................................................................. 19
Research and Other Soft Dollar Benefits ............................................................................... 19
Brokerage for Client Referrals ................................................................................................. 20
Directed Brokerage .................................................................................................................. 20
Order Aggregation .................................................................................................................... 20
REVIEW OF ACCOUNTS (Item 13) ................................................................................................. 21
Periodic Reviews ...................................................................................................................... 21
Client Reports ........................................................................................................................... 21
CLIENT REFERRALS AND OTHER COMPENSATION (Item 14) ........................................................ 22
CUSTODY (Item 15) ....................................................................................................................... 22
INVESTMENT DISCRETION (Item 16)............................................................................................. 23
VOTING CLIENT SECURITIES (Item 17) .......................................................................................... 23
FINANCIAL INFORMATION (Item 18) ............................................................................................ 24
Privacy Policy ................................................................................................................................ 24
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ADVISORY SERVICES (ITEM 4)
About the Firm
MBL Wealth, LLC (hereinafter, “MBL Wealth,” “Firm,” “Our,” “Us” or “We”) is an Investment
Adviser that has applied to register as such with the SEC and expects to begin managing the
wealth of Our clients in 2020. MBL Wealth also operates under the name MBL Advisors. Our
Firm is a North Carolina Limited Liability Corporation with Our principal place of business
located in Charlotte, North Carolina.
The Firm is owned by The Lockwood Organization, LLC, Jonathan Dry, Brian Gift, and Billy
Morton. The Lockwood Organization, LLC is majority owned by Luther Lockwood. Luther is Our
Chief Executive Officer and has the ChFC, CLU, AEP, CEPA and RHU designations. Jonathan is
Our Chief Strategy Officer and holds the CFP, CEPA, and CIMA designations. Brian is Our Chief
Investment Officer and holds the CFA designation. Billy is Our President and has a Juris Doctor,
is a former practicing estate planning attorney, and is licensed to practice law in North
Carolina. Stephen Marciniak is Our Chief Compliance Officer and Chief Operating Officer and
holds the CLU and ChFC. For more information, please see the brochure supplement (Form
ADV Part 2B) for each of the above.
Types of Advisory Services
Wealth Management Services
Wealth management services are provided on a non-discretionary and discretionary basis, at
the direction of the client. Clients engaging Us on either basis will be asked to grant such
authority upon signing Our Investment Advisory Agreement. Members of Our investment team
will meet with the client to develop an understanding of the client’s financial objectives and
goals. We will also discuss concepts related to risk, as well as the client’s ability and
willingness to take on risk in the client’s overall investment portfolio. We will ask the client
questions designed to determine the appropriate investment horizon, risk profile, financial
goals, income and other various items We deem necessary.
After We meet with a client, We will develop a portfolio customized to the specific needs of
the client as We understand them based on Our discussions with the client and review of the
client questionnaire. Clients are given the ability to impose reasonable restrictions on their
accounts, including specific investment selections and sectors. However, MBL Wealth will not
enter into an investment advisor relationship with a client whose investment objectives may
be considered incompatible with MBL Wealth's investment philosophy or strategies or where
the prospective client seeks to impose unduly restrictive investment guidelines.
This portfolio may be comprised of stocks, bonds, preferred securities, publicly traded
partnerships, ETFs, mutual funds, separately managed accounts, listed options on ETFs and
stocks, cash or cash equivalents and select alternative investments.
If the client selects a non-discretionary basis, the client grants the Firm ongoing and
continuous non-discretionary authority to make its investment recommendations in
accordance with the client’s investment profile. However, the Firm must obtain the client’s
prior approval of each specific recommendation, as well as for the selection and retention of
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sub-advisers for the account, prior to entering orders with a broker-dealer for the execution of
its investment recommendations.
If the client selects a discretionary basis, the client grants the Firm ongoing and continuous
discretionary authority to make, and to enter orders with a broker/dealer for the execution of,
its investment recommendations in accordance with the client’s investment profile without
the client’s prior approval of each specific transaction. All transactions in the clients’ account
shall be made in accordance with the directions and preferences provided to the Firm by the
client. The client will execute instructions regarding the Firm’s trading authority as required by
each account custodian.
We will also monitor the client’s accounts to ensure that they are meeting the client’s
investment objectives and other requirements. If any changes are needed to the client’s
investments, We will either make the changes or recommend the changes to the client. These
changes may involve selling a security or group of investments and buying others or keeping
the proceeds in cash or some liquid alternative. The client may at any time place reasonable
restrictions on the types of investments We may use on the client’s behalf, or on the
allocations to each security asset class or industry. The client will receive written or electronic
confirmations from the client’s account custodian after any changes are made to the client’s
account. The client will also receive statements at least quarterly from the client’s account
custodian. Our Investment Advisory Agreement outlines the responsibilities of both the client
and MBL Wealth.
Financial Concierge Services We offer financial concierge services to certain clients who have
at least $25 million in assets under management with our Firm. This minimum may be waived
at the sole discretion of MBL Wealth. These services may include the following:
• Assistance with bill payment;
• Payment of tax filings (quarterly and annually);
• Assistance with Subscription Documents for private placements;
• Review of 401k/retirement plans held at their company; change elections according
to financial planning objectives;
• Discuss their personal banking affairs with their personal/private bankers upon
introduction and request;
• Completing mortgage applications;
• Access to bank accounts to initiate transactions upon instruction or coordinate bank
bill payment; or
• Download of banking transactions to provide to CPAs for quarterly/annual tax
planning.
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For more information on this service, please see Items 5 and 15 of this Brochure.
Selection of Other Advisers
As part of our investment advisory services, we may recommend that the client use the
services of an unaffiliated, third-party investment adviser ("TPA") to manage the entire, or a
portion of the investment portfolio. After gathering information about specific financial
situation and objectives, we may recommend that the client engage a specific TPA or
investment program. The TPA will actively manage the client’s portfolio and will assume
discretionary investment authority over the account. Factors that we take into consideration
when making our recommendation(s) include, but are not limited to, the following: the TPA's
performance, methods of analysis, fees, financial needs, investment goals, risk tolerance, and
investment objectives. We will periodically monitor the TPAs' performance to ensure
management and investment style remains aligned with the client’s investment goals and
objectives.
If a TPA is recommended to the client, the client will be required to sign an agreement directly
with the recommended TPAs. The client may terminate their advisory relationship with the TPA
according to the terms of the agreement with the TPA. The client should review each TPA's
brochure for specific information on how to terminate the advisory relationship with the TPA
and how to receive a refund, if applicable. Contact the TPA directly for questions regarding an
advisory agreement with the TPA.
Financial Planning Services
We provide comprehensive financial planning to our asset management clients. Financial
planning is a comprehensive relationship which incorporates many different aspects of a
client’s financial status into an overall plan that intends to meet their goals and objectives.
The financial planning relationship consists of face‐to‐face meetings and ad hoc meetings
with clients and/or the client’s other advisors (attorneys, accountants, etc.) as necessary.
In performing financial planning services, we typically examine and analyze a client’s overall
financial situation, which may include issues such as taxes, insurance needs, overall debt,
credit, business planning, retirement savings and reviewing the current investment program.
Our services may focus on all or only one of these areas depending upon the scope of our
engagement.
It is essential that a client provide the information and documentation we request regarding
income, investments, taxes, insurance, estate plan, etc. We will discuss investment
objectives, needs and goals, but the client is obligated to inform us of any changes. We do not
verify any information obtained from a client, their attorney, accountant or other professionals.
Clients are under no obligation to implement recommendations through us. A client may
implement their financial plan through any financial organization of their choice.
We obtain information from a wide variety of publicly available sources. We do not have any
recommended. All
inside private
information about any
investments
that are
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recommendations developed by us are based upon our professional judgment. We cannot
guarantee the results of any of our recommendations.
Retirement Plan Consulting Services
We provide prudent advice and guidance to both ERISA and non-ERISA retirement plan
sponsors through our retirement plan consulting services. Our retirement plan consulting
services include, but are not limited to, the following services:
Fiduciary Consulting Services
•
Investment Policy Statement Preparation. The Firm assists clients in the development
or review of an investment policy statement (“IPS”). The IPS establishes the investment
policies and objectives for the plan. Clients have the ultimate responsibility and
authority to establish such policies and objectives and to adopt and amend the
investment policy statement.
• Non-Discretionary Investment Advice. The Firm provides clients with general, non-
discretionary investment advice regarding specific investments to be held by the plan
or, in the case of a participant-directed defined contribution plan, to be made available
as investment options under the plan, consistent with the plan’s IPS. Clients have final
decision-making authority regarding the selection, retention, removal or addition of
investments or investment options.
•
Investment Monitoring. The Firm assists in monitoring of investment options by
preparing periodic investment reports that document investment performance,
consistency of fund management and conformance to the guidelines set forth in the
IPS. The Firm will make recommendations to maintain or remove and replace
investment options. The Firm will provide updated investment reports on a quarterly
basis with investment recommendations to adhere to the investment standards in the
IPS.
• Qualified Default Investment Alternative Advice. The Firm provides clients with non-
discretionary investment advice to assist in developing qualified default investment
alternative(s) (“QDIA”), as defined in DOL Reg. Section 2550.404c-5(e)(4)(i), for
participants who are automatically enrolled in the plan or who otherwise fail to make
an investment election. Clients retain the sole responsibility to provide all notices to
participants required under Section 404(c)(5) of the Employee Retirement Income
Security Act of 1974 (“ERISA”).
• Annual Meeting. The Firm holds an Annual Meeting to review the plan and document
any action that needs to be taken by the plan’s investment committee. The Firm
prepares the following information for the investment committee to review:
Investment Review and Market Commentary
•
Style and Holding Allocations
•
Comparative Fund Performance
•
Fund-specific commentary as needed
•
Monitoring and Investment Reports
•
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Peer and Benchmarking Analysis
•
Not all of the above services are provided to all clients. The particular services to be provided
are described in a written agreement between the client and the Firm.
The Firm acknowledges that in performing the services listed above it is acting as a “fiduciary”
as such term is defined under ERISA Section 3(21)(A)(ii) for purposes of providing non-
discretionary investment advice only. MBL Wealth acts in a manner consistent with the
requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such
services cause the Firm to be a fiduciary as a matter of law. However, in providing the fiduciary
consulting services, the Firm (a) has no responsibility and does not (i) exercise any
discretionary authority or discretionary control respecting management of the client’s
retirement plan, (ii) exercise any authority or control respecting management or disposition of
assets of the client’s retirement plan or (iii) have any discretionary authority or discretionary
responsibility in the administration of the client’s retirement plan or the interpretation of the
client’s retirement plan documents; (b) is not an “investment manager” as defined in Section
3(38) of ERISA and does not have the power to manage, acquire or dispose of any plan assets;
(c) is not a “fiduciary” under ERISA with respect to any particular participant’s plan assets; (d)
is not the “administrator” of the client’s retirement plan as defined in ERISA.
Retirement plan consulting services are not investment management services, and the Firm
does not serve as administrator or trustee of the plan. The Firm does not act as custodian for
any client account or have access to client funds or securities (with the exception of having
written authorization from the client to deduct advisory fees). In addition, the Firm does not
implement any transactions in a retirement plan’s account. All recommendations of
investment options and portfolios are submitted to the client for ultimate approval or rejection.
The retirement plan which elects to implement any recommendations made by us is solely
responsible for implementing all transactions.
Non-Fiduciary Services
• Education Services to Plan Committee. The Firm provides education, training, and/or
guidance for the members of the plan committee with regard to plan features,
retirement readiness matters, or duties and responsibilities of the committee,
including education with respect to fiduciary responsibilities.
• Participant Enrollment. The Firm assists clients with group enrollment meetings
designed to increase retirement plan participation among employees and investment
and financial understanding by the employees. These meetings do not include
recommendations with respect to any specific investment alternatives or options
available to participants.
• Participant Education. The Firm arranges education sessions for plan participants
about general investment principles and the investment alternatives available under
the plan. Such education services may include preparation, edit or review of education
materials and/or conducting investment education seminars and meetings for plan
participants. Meetings may be on a group or individual basis. Education presentations
do not take into account the individual circumstances of each participant and do not
refer to the appropriateness of any specific investment alternatives or options for the
participants.
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• Change in Control Consulting. If requested by the client, the Firm may provide
additional consulting services as necessary based on the needs of the plan. These
services may include, but are not limited to, assisting in the implementation of a plan
termination, merger or any changes in control resulting therefrom. In such cases, the
Firm does not act on a discretionary basis nor exercise independent judgement.
Although an investment adviser is considered a fiduciary under the Investment Advisers Act
of 1940 (the “Advisers Act”) and is required to meet the fiduciary duties required of an
investment adviser, the services listed above as “Non-Fiduciary” are not considered fiduciary
services for the purposes of ERISA since MBL Wealth is not acting as a fiduciary to the plan
as the term “fiduciary” is defined in Section 3(21)(A)(ii) of ERISA. The exact services provided
to clients are listed and detailed in the Retirement Plan Consulting Agreement.
We have the flexibility to tailor our services to the specific needs of our clients. This is open
for discussion with each client but may include inclusion or exclusion of particular types of
investments based on asset class, geographical, political or socio-economic factors.
Retirement Plan Rollovers
When we provide investment advice to you regarding your retirement plan account or
individual retirement account, we are 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. The way we make money creates some conflicts with
your 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. A client or prospective client leaving an employer
typically has four options regarding an existing retirement plan (and may engage in a
combination of these options): (i) leave the money in the former employer’s plan, if permitted,
(ii) roll over the assets to the new employer’s plan, if one is available and rollovers are
permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account
value (which could, depending upon the client’s age, result in adverse tax consequences). If
We recommend that a client roll over their retirement plan assets into an account to be
managed by the Firm, such a recommendation creates a conflict of interest as We will earn a
new (or increase Our current) advisory fee as a result of the rollover. We address this conflict
of interest by reviewing any such recommendation to ensure it is in the best interest of the
client. No client is under any obligation to roll over retirement plan assets to an account
managed by Us.
Assets Under Management
As of December 31, 2024, MBL Wealth manages $1,142,902,910 of discretionary assets
under management. MBL Wealth also advises another $128,903,839of assets under
advisement.
FEES AND COMPENSATION (ITEM 5)
In addition to the information provided in Item 4, this section provides additional details
regarding Our Firm’s services along with descriptions of each service’s fees and compensation
arrangements. It should be noted that lower fees for comparable service may be available
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from other sources. The exact fees and other terms will be outlined in the agreement between
the client and the Firm.
Wealth Management Fees
MBL Wealth charges fees to investment management clients based on a percentage of assets
under management. The specific fees charged by the Firm for its advisory services will be
outlined in each client’s Investment Advisory Agreement. Asset management fees are
calculated and paid quarterly in advance or in arrears, depending on the type of relationship,
and are negotiable depending upon the complexity of the client’s financial situation and the
scope of services rendered.
The percentage fee may increase or decline depending on the value of the assets in the
client’s account(s). At our discretion, We may combine the account values of family members
living in the same household to determine the applicable investment management fee. For
example, We may combine account values for the client and the client’s minor children, joint
accounts with the client’s spouse, and other types of related accounts. Combining account
values may increase the asset total, which may result in the client paying a reduced advisory
fee. Our minimum wealth management relationship annual fee is $40,000, which may be
negotiable under certain circumstances.
The typical fee schedule for the annual tiered management fee charged by MBL Wealth is:
$0 to $2,000,000
0.90%
$2,000,001 to $5,000,000
0.75%
$5,000,001 to $10,000,000
0.60%
$10,000,001 to $25,000,000
0.40%
Over $25,000,000
0.25%
Payment of management fees will be deducted from the client’s account(s) by the qualified
custodian. We will only receive payment from the custodian if the client supplies written
authorization permitting the fees to be paid directly from the account. MBL Wealth will not
have access to client funds for payment of fees without written consent by the client.
The qualified custodian agrees to deliver an account statement, at least quarterly, directly to
the client, showing all disbursements from the account. The client is encouraged to review all
account statements for accuracy. MBL Wealth will receive access to a duplicate copy of the
statement that was delivered to the client.
For the initial period of portfolio management services, the first period’s fees will be calculated
on a pro-rata basis at the end of the initial quarter. The client may terminate the agreement
within five days of entering into the agreement and obtain a full refund. After the five- day
period, either party may terminate the agreement upon a written notice to the other party. Any
pre-paid, unearned fees will be promptly refunded to the client.
Client acknowledges and agrees that there may be variations in the account values used to
calculate the Advisory Fee and the account values on the last day of the previous quarter or
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other period as reflected on the account statement the Client receives from the custodian.
These variations are due to differences in methodologies between the account custodian and
the third-party vendor with whom MBL contracts to calculate fees due for each account. The
variations include, but are not limited to, variations resulting from: (1) unsettled trades; (2)
accrued income; (3) pricing of securities; and (4) dividends earned but not received. Usually,
any differences in account values due to these variations will be relatively small. MBL will not
make any adjustments, refunds, or further assessments of fees based on these differences.
Any Client who has a question about any such difference or any other issue relating to the
calculation of fees is encouraged to contact MBL for an explanation.
Please note that Our receipt of fees for managing client accounts results in several conflicts
of interest. For example, the more assets there are in a client’s advisory account, the more a
client will pay in asset-based fees, and We may, therefore, have an incentive to encourage
clients to increase the assets in their accounts. We address this conflict by ensuring that all
recommendations are in the client’s best interest. Additional conflicts, and how We address
them, are described throughout this Brochure.
Fees for Financial Concierge Services
Financial concierge services are included in the investment management fee for clients who
have $25 million in assets under management with our Firm. This minimum may be waived
at the sole discretion of MBL Wealth.
Fees for Financial Planning Services
Comprehensive financial planning services are included within the investment management
fee, as described in the Wealth Management Fees section above.
Selection of Other Advisers
If we recommend a TPA for a client account, the client will pay both a TPA advisory fee and
our firm's advisory fee which is separate and in addition to the TPA fees. The specific fee due
to the TPA will be disclosed in the client’s agreement with the TPA.
Retirement Plan Consulting Fees
MBL Wealth’s annual investment advisory fee for nondiscretionary retirement plan consulting
services does not usually exceed 1.25% of the total plan assets placed under MBL Wealth’s
advisement with a minimum annual fee of $7,000. If elected by the client, MBL Wealth will
instead charge a flat fee not to exceed $10,000 per month. The exact advisory fee will be
specified in the Retirement Plan Consulting Agreement. Fees are negotiable. Fees are
deducted from the plan assets on a quarterly or monthly basis, in arrears, based upon the
agreed annual percentage rate. Fees may also be invoiced directly to the plan sponsor if
elected by the client.
As fees are typically paid in arrears, there is normally not a circumstance for a refund due to
services rendered. Should a situation occur where a refund is warranted (potentially due to
error or miscalculations of fees) refunds will be processed in the most timely and prudent
manner available given the circumstances under which a refund is warranted.
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Other Types of Fees & Expenses
Clients will incur transaction charges for trades executed in their accounts. These transaction
fees are separate from Our Firm’s advisory fees and will be disclosed by the chosen custodian.
Clients will typically pay charges imposed directly by a mutual fund, index fund, or exchange
traded fund, which shall be disclosed in the fund’s prospectus (i.e., fund management fees,
initial or deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender charges,
variable annuity fees, IRA and qualified retirement plan fees, and other fund expenses). Our
Firm does not receive a portion of these fees. For more information regarding brokerage
practices, see Item 12.
Where MBL Wealth works with corporate 401k and qualified plans, MBL Wealth reserves the
right to charge a reasonable flat fee which will not exceed $10,000 per event for non-fiduciary
advice in change in control situations around corporate acquisitions, mergers, dispositions or
plan terminations. Such fees would be clearly described in the Retirement Plan Consulting
Agreement and are negotiable prior to engagement with MBL Wealth. Under no circumstances
will MBL Wealth charge termination fees for individual wealth management clients.
Commissionable Insurance Sales
Some of our investment adviser representatives (“IARs”) are licensed to sell insurance and
related products with MBL Advisors Inc., an affiliated entity of MBL Wealth. IARs in such cases
will earn typical and customary commission for the sale of insurance products purchased for
a client’s account. This represents a conflict of interest in that IARs may recommend
purchasing insurance products based on compensation rather than on the needs of the client.
To mitigate this conflict of interest, We require all representatives who are licensed to offer
insurance products to Our clients to assure that the issuing insurer reviews the potential sale
of any products for the purpose of determining adherence to applicable insurance suitability
standards, We fully disclose to a client when a particular transaction will result in the receipt
of commissions or other associated fees and We require all representatives to seek prior
approval of any outside employment activity so that We may ensure that any conflicts of
interest in such activities are properly disclosed. Insurance products may be available through
other channels, and as a client, the client is not obligated to purchase products recommended
by Our representatives. Clients may purchase insurance products through agents We
recommend who are not affiliated with Us.
Commissionable Securities Sales
Our Firm and representatives do not sell securities for a commission in advisory accounts.
Some of Our IARs are registered representatives of M Holdings Securities, Inc. (“M Holdings”),
Member FINRA/SIPC. MBL Wealth and M Holdings are not affiliated. The client’s IAR may
recommend securities and earn commissions in his or her separate capacity as a registered
representative of M Holdings. This represents a conflict of interest in that IARs may
recommend purchasing securities based on compensation rather than on the needs of the
client. We mitigate this conflict of interest by disclosing it here and reviewing the suitability of
any such recommendations. These securities may be available through other channels and
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as a client, the client is not obligated to purchase securities recommended by Our
representatives.
PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT (ITEM 6)
Performance-based fees are based on a share of capital gains on or capital appreciation of
the client’s assets. Side-by-side management occurs when advisers manage both accounts
that are charged a performance-based fee and accounts that are charged another type of fee,
such as an hourly or flat fee or an asset-based fee. We do not accept performance-based fees,
nor do we engage in side-by-side management.
TYPES OF CLIENTS (ITEM 7)
MBL Wealth provides investment advisory services to individuals, high net worth individuals,
trusts, estates, charitable organizations, businesses, and retirement plans. Our minimum
relationship opening balance is $5,000,000, which may be negotiable based upon certain
circumstances.
METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS (ITEM 8)
Methods of Analysis and Investment Strategies
MBL Wealth uses the following methods of analysis in formulating and executing our
investment strategy:
Macro-Economic Analysis: We study multiple economic variables in order to strive to help us
improve our understanding of the current economic situation and the potential investment
related outcomes which that may have.
Fundamental Analysis: We use various absolute and relative metrics to help us determine how
attractive a given security (Index / ETF / mutual fund / individual security) may be. We
evaluate this kind of an analysis from historical context by comparing a security to itself over
time. In addition, we also access things from a relative perspective through comparing the
perceived relative attractiveness of various assets classes to one another in the current
environment.
Technical Analysis: We use technical analysis to help gain a better understanding of a given
market or index’s internal strength / weakness, intermediate and long term trend, investor
sentiment, investor positioning and other factors. Technical analysis has a broad range of
uses by market participants. The largest way in which MBL Wealth applies technical analysis
to their client portfolio is as a risk management technique.
Investment Strategies:
MBL Wealth constructs and implements long term, goals based investment strategies for their
clients. A given investors need, ability and willingness to assume market risk are the primary
driving factors to high level asset allocation decisions. This assessment includes but is not
limited to investment goals, risk profile, liquidity needs, client specific tax circumstances,
special circumstances and generational planning.
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MBL Wealth strongly believes in modern portfolio theory by where we strive to maximize
expected returns for a given level of risk and / or minimize risk for a given level of expected
return. Most investors are risk adverse and therefore need to be compensated if they are
going to assume incremental market risk within their portfolio.
MBL Wealth constructs portfolios which are broadly diversified by asset class. This includes
stocks, bonds and uncorrelated assets. Within stocks we recommend gaining exposure to U.S.
large cap equities, U.S. small cap equities, and foreign equities along with some additional
equity sub asset classes. MBL Wealth also achieves ample diversification at the security level
within all asset classes which are held within a client portfolio.
Risk of Investing:
There are always risks to investing. Clients should be aware that all investments are subject
to the potential loss of principal that clients should be prepared to bear. It is impossible to
describe all possible types of risks which may affect investments. Among the risks are the
following:
• Market Risks. Markets can, as a whole, go up or down on various news releases or for
no understandable reason at all. This sometimes means that the price of specific
securities could go up or down without real reason and may take some time to recover
any lost value. Adding additional securities does not help to minimize this risk since all
securities may be affected by market fluctuations.
• Currency Risk. Overseas investments are subject to fluctuations in the value of the
dollar against the currency of the investment’s originating country. This is also referred
to as exchange rate risk.
•
Interest Rate Risk. Movements in interest rates may directly cause prices of fixed
income securities fluctuate. For example, rising interest rates can cause “high quality,
relatively safe” fixed income investments to lose principal value.
• Credit Risk. If debt obligations held by an account are downgraded by ratings agencies
or go into default, or if management action, legislation or other government action
reduces the ability of issuers to pay principal and interest when due, the value of those
obligations may decline, and an account’s value may be reduced. Because the ability
of an issuer of a lower-rated or unrated obligation (including particularly “junk” or “high
yield” bonds) to pay principal and interest when due is typically less certain than for an
issuer of a higher-rated obligation, lower rated and unrated obligations are generally
more vulnerable than higher-rated obligations to default, to ratings downgrades, and
to liquidity risk.
• Purchasing Power Risk. Purchasing power risk is the risk that an investment’s value
will decline as the price of goods rises (inflation). The investment’s value itself does
not decline, but its relative value does. Inflation can happen for a variety of complex
reasons, including a growing economy and a rising money supply.
• Liquidity Risk. Liquidity is the ability to readily convert an investment into cash. For
example, Treasury Bills are highly liquid, while real estate properties are not. Some
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securities are highly liquid while others are highly illiquid. Illiquid investments carry
more risk because it can be difficult to sell them.
• Political Risks. Most investments have a global component, even domestic stocks.
Political events anywhere in the world may have unforeseen consequences to markets
around the world.
• Regulatory Risk. Changes in laws and regulations from any government can change
the value of a given company and its accompanying securities. Certain industries are
more susceptible to government regulation. Changes in zoning, tax structure or laws
impact the return on these investments.
• Risks Related to Investment Term. If the client requires a liquidation of their portfolio
during a period in which the price of the security is low, the client will not realize as
much value as they would have had the investment had the opportunity to regain its
value, as investments frequently do, or had it been able to be reinvested in another
security.
• Business Risk. Many investments contain interests in operating businesses. Business
risks are risks are associated with a particular industry or a particular company within
an industry. For example, oil-drilling companies depend on finding oil and then refining
it, a lengthy process, before they can generate a profit. They carry a higher risk of
profitability than an electric company, which generates its income from a steady
stream of customers who buy electricity no matter what the economic environment is
like.
• Financial Risk. Many investments contain interests in operating businesses. Excessive
borrowing to finance a business’ operations decreases the risk of profitability, because
the company must meet the terms of its obligations in good times and bad. During
periods of financial stress, the inability to meet loan obligations may result in
bankruptcy and/or a declining market value.
• Default Risk. This risk pertains to the ability of a company to service their debt. Ratings
provided by several rating services help to identify those companies with more risk.
Obligations of the U.S. government are said to be free of default risk.
Recommendation of Specific Type of Securities
As noted in Item 4 above, a portfolio may be comprised of stocks, bonds, preferred securities,
publicly traded partnerships, ETFs, mutual funds, separately managed accounts, listed
options on ETFs and stocks, cash or cash equivalents and select alternative investments.
Among the risks are the following:
• Large-Cap Stock Risk. Investment strategies focusing on large-cap companies may
underperform other equity investment strategies as large cap companies may not
experience sustained periods of growth in the mature product markets in which they
operate.
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• Small/Mid-Cap Stock Risk. Investment strategies focusing on small- and mid-cap
stocks involve more risk than strategies focused on larger more established
companies because small- and mid-cap companies may have smaller revenue,
narrower product lines, less management depth, small market share, fewer financial
resources and less competitive strength.
• Fixed-Income Market Risk. Economic and other market developments can adversely
affect fixed-income securities markets in Canada, the United States, Europe and
elsewhere. At times, participants in debt securities markets may develop concerns
about the ability of certain issuers to make timely principal and interest payments, or
they may develop concerns about the ability of financial institutions that make markets
in certain debt securities to facilitate an orderly market which may cause increased
volatility in those debt securities and/or markets.
• Risks of Investment in Futures, Options and Derivatives. Such strategies present
unique risks. For example, should interest or exchange rates or the prices of securities
or financial indices move in an unexpected manner, the Firm may not achieve the
desired benefits of the futures, options and derivatives or may realize losses. Thus, the
client would be in a worse position than if such strategies had not been used. In
addition, the correlation between movements in the price of the securities and
securities hedged or used for cover will not be perfect and could produce unanticipated
losses.
• ETF Risk. The returns from the types of securities in which an ETF invests may
underperform returns from the various general securities markets or different asset
classes. The securities in the underlying indexes (the “Underlying Indexes”) may
underperform fixed-income investments and stock market investments that track
other markets, segments and sectors. Different types of securities tend to go through
cycles of out-performance and underperformance in comparison to the general
securities markets.
DISCIPLINARY INFORMATION (ITEM 9)
MBL Wealth is required to disclose the facts of any legal or disciplinary events that are
material to a client’s evaluation of Our advisory business or the integrity of Our
management. We do not have any required disclosures to report in response to this Item.
OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS (ITEM 10)
MBL Wealth is not a registered broker-dealer and does not have an application pending for
registration as a broker-dealer. Furthermore, the Firm is not registered as, and does not have
applications pending to register as, a Futures Commission Merchant, Commodity Pool
Operator, or Commodity Trading Adviser, nor are our management or supervised persons
registered or have applications pending to register as associated persons thereof. Certain
supervised persons of the Firm are involved in other financial industry businesses, as
described below.
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Registered Representatives of a Broker Dealer
Some of Our IARs are registered representatives of M Holdings Securities, Inc. (“M Holdings”),
Member FINRA/SIPC. MBL Wealth and M Holdings are not affiliated. Our IARs may
recommend securities and earn commissions in his or her separate capacity as a registered
representative of M Holdings. This represents a conflict of interest in that IARs may
recommend purchasing securities based on compensation rather than on the needs of the
client. We mitigate this conflict of interest by disclosing it here and reviewing the suitability of
any such recommendations. These securities may be available through other channels and
as a client the client is not obligated to purchase securities recommended by Our
representatives. For more information about outside business activities of IARs, please see
the individual’s brochure supplement (ADV Part 2B).
Licensed Insurance Agents
Some of Our IARs are licensed to sell insurance and related products with MBL Advisors Inc.,
an affiliated entity of MBL Wealth. IARs in such cases will earn typical and customary
commission for the sale of insurance products purchased for a client’s account. This
represents a conflict of interest in that IARs may recommend purchasing insurance products
based on compensation rather than on the needs of the client. To mitigate this conflict of
interest, We require all representatives who are licensed to offer insurance products to Our
clients to assure that the issuing insurer reviews the potential sale of any products for the
purpose of determining adherence to applicable insurance suitability standards, We fully
disclose to a client when a particular transaction will result in the receipt of commissions or
other associated fees and We require all representatives to seek prior approval of any outside
employment activity so that We may ensure that any conflicts of interest in such activities are
properly disclosed. Insurance products may be available through other channels and as a
client the client is not obligated to purchase products recommended by Our representatives.
The client may purchase insurance products through agents We recommend who are not
affiliated with Us. For more information about outside business activities of IARs, please see
the individual’s brochure supplement (ADV Part 2B).
CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL
TRADING (ITEM 11)
Code of Ethics
The Firm, its management and supervised persons (collectively “personnel”), subscribe to a
strict Code of Ethics. The Code of Ethics is designed to comply with the investment advisory
laws and regulations that require firms to act as fiduciaries in transactions with their clients.
The Firm’s inherent fiduciary duty requires that the Firm act solely in its clients’ best interest
and adhere to standards of utmost integrity in its communications and transactions. These
standards ensure that clients’ interests are preeminent.
Accordingly, the Firm has implemented extensive policies, guidelines, and procedures that
promote ethical practices and conduct by all of the Firm’s personnel. The Firm’s Code of Ethics
specifies and prohibits certain types of transactions deemed to create conflicts of interest (or
perceived conflicts of interest), as well as to establish reporting requirements and
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enforcement procedures relating to personal transactions by its personnel. The Code of
Ethics, which specifically deals with professional standards, insider trading, personal trading,
gifts and entertainment, and fiduciary duties, establishes the Firm’s ideals for ethical conduct
based upon fundamental principles of openness, integrity, honesty, and trust. The Firm will
provide a copy of the complete Code of Ethics to any client or prospective client upon request.
Participation or Interest in Client Transactions
The Firm does not recommend that clients buy or sell securities in which it or a related person
may have a material financial interest.
Proprietary Trading
The Firm and its representatives are permitted to buy or sell securities for their own accounts
that the Firm also recommends to clients, consistent with the Firm’s policies and procedures.
This presents a conflict of interest because it may be possible for Us or Our representatives
to receive more favorable prices than Our clients. We will always document any transactions
that could be construed as a conflict of interest. To mitigate this conflict of interest, We will
monitor trading reports for adherence to Our Code of Ethics.
Simultaneous Trading
From time to time, the Firm and its representatives may buy or sell securities for their own
accounts at or around the same time as clients. This presents a conflict of interest in that Our
representatives have an incentive to prioritize their own trading over their clients. To mitigate
this conflict of interest, in any instance where such securities are purchased or sold We will
uphold Our fiduciary duty by always ensuring that transactions are beneficial to the interest of
Our clients and that neither the sequence nor timing of execution or any other factor results
in a benefit to the Firm or Our representatives.
BROKERAGE PRACTICES (ITEM 12)
Selection and Recommendation
MBL Wealth recommends that clients utilize the brokerage and clearing services of Charles
Schwab, Inc. (“Schwab”), Interactive Brokers, LLC (“IB”), or SEI Private Trust Company (“SEI”).
Factors which MBL Wealth considers in recommending a broker-dealer to clients include their
respective financial strength, breadth of service, existing relationships, execution, pricing,
research and resources available. Not all investment advisers recommend that a client use a
particular broker-dealer.
Research and Other Soft Dollar Benefits
The SEC has defined “soft dollar” practices as arrangements under which products or
services, other than execution of securities transactions, are obtained by an investment
adviser firm or through a broker-dealer in exchange for the direction by the adviser of client
brokerage transactions to the broker-dealer. MBL Wealth receives research or other products
or services (i.e., soft dollar benefits) from broker-dealers in exchange for placing trades or
processing securities related transactions for clients. Included within these services are
investment-related research, pricing information, along with market data/software/other
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technology that provide access to client account data, compliance and/or practice
management-related publications, free or discounted consulting services, attendance at
conferences/meetings/other educational and/or social events, marketing support, and/or
other products used by MBL Wealth in furtherance of its investment advisory business
operations. In addition to research and soft dollar benefits, SEI provides mutual fund models
and managed account portfolio recommendations to MBL Wealth.
We do not have to pay the broker-dealer for these services and no client is charged for these
services. Therefore, We receive a benefit. The products or services received may benefit all of
Our clients, not just those whose assets are custodied at the broker-dealer who provides the
products or services. This may result in higher transaction costs than those that would have
been incurred but for the soft dollar benefits. This is a conflict of interest, as We have an
incentive to recommend Schwab, IB, or SEI over other broker-dealers/custodians because of
Our existing relationship and the benefits We receive. We mitigate this conflict by conducting
best execution reviews and through application of Our policies and procedures. We have
determined that the transaction charges We incur and charge to the client are reasonable in
relation to the value of the services received.
Brokerage for Client Referrals
MBL Wealth does not receive client referrals or compensation of any kind from broker-dealers
or other third parties in exchange for using any particular broker-dealer.
Directed Brokerage
We routinely recommend that the client direct Our Firm to execute transactions through
broker-dealers with which we have a business relationship. As such, We may be unable to
achieve the most favorable execution of the client’s transactions and the client may pay higher
brokerage commissions than the client might otherwise pay through another broker-dealer
that offers the same types of services. If clients prefer to utilize their own broker-dealer, We
will not be able to provide wealth management services to those clients.
Order Aggregation
MBL Wealth may occasionally perform block trading in select, peripheral scenarios. Generally,
accounts are traded on an individual basis. However, if the firm is exiting or swapping
positions throughout the book, we may elect to perform this function through a block trade for
operational efficiency and to optimize equitable execution prices fairly across client accounts.
More commonly, the Firm trades individual accounts or households on an individual basis.
Putting new money to work through dollar cost averaging and selectively rebalancing accounts
require precise position sizes to maintain ideal weightings. Customized management on an
individual account basis ensures that we accurately buy/sell securities in proper amounts with
regards to the client’s total portfolio. This is especially vital when one or more separately
managed accounts exist in a client household.
Conversely, merely liquidating all of a position or executing a self-funded buy-sell swap is a
more straightforward task, which can be executed in a sweeping fashion across the entire
book through the use of block trading. In such an instance, this would be the Firm’s preferred
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methodology for several reasons, including maximizing the equitable execution of trades for
all clients, efficiency, and as a hedge against market volatility or other considerations.
Under our current approach, we would only block trade through Schwab. The accounts
custodied at IB would not be part of any block trades. Our portfolio and trading aggregation
software allows us to prepare block trades and organize requisite accounts for shares to be
allocated before importing data to our custodian (Schwab). A filtering step is performed to
exclude Firm accounts that are (i) on margin, (ii) have a settlement trading restriction, or (iii)
do not hold the aforementioned securities to ensure all shares bought/sold at the Master
Account will have a home in each underlying account selected without errors.
Once the data is exported to Schwab, the Allocation page denotes how many shares are
allocated from the Master Account trade to each to individual account’s final destination. This
allows us further to spot-check and safeguard against over/under allocations.
REVIEW OF ACCOUNTS (ITEM 13)
Periodic Reviews
MBL Wealth reviews advisory accounts at least annually, with the cooperation of clients. These
reviews examine the performance of the advisory accounts and also compare them to the
objectives stated by the client in the Investment Advisory Agreement. The reviews of advisory
accounts are done by the Investment Adviser Representatives of MBL Wealth. Intermittent
reviews may be triggered by substantial market fluctuation, economic or political events, or
by changes in the client’s financial status or investment objectives or risk tolerance. It is the
responsibility of the client to notify Us of any change to financial status, investment objectives
or risk tolerance (such as retirement, termination of employment, relocation, or inheritance).
Client Reports
Clients will receive written transaction confirmations from the account custodian shortly after
executing purchases or sales. Additionally, the account custodian will send at least quarterly
written statements for each quarter in which the client has an account under management by
MBL Wealth. These statements will provide details regarding account activity, holdings, and
performance.
MBL Wealth may issue separate written reports regarding accounts to clients. The written
updates may include a performance report, statement of gains and losses, and/or a financial
markets summary. We encourage the client to compare the information on the client’s reports
prepared by MBL Wealth against the information in the statements provided directly from the
account custodian and alert Us of any discrepancies.
For retirement plan consulting clients, MBL Wealth will prepare periodic written investment
reports that document investment performance, consistency of fund management and
conformance to the guidelines set forth in the plan’s IPS. We will provide updated investment
reports on a quarterly basis with investment recommendations to adhere to the investment
standards in the IPS.
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CLIENT REFERRALS AND OTHER COMPENSATION (ITEM 14)
Except as described elsewhere in this Brochure, MBL Wealth does not receive and does not
have any arrangement to receive economic benefits (such as sales awards or other prizes)
from any third party for providing investment advice or other advisory services to Our clients.
(See Research and Other Soft Dollar Benefits, Item 12).
MBL Wealth entered into a promoter agreement with an independent financial services firm
(the “Promoter”) to provide solicitation activities for MBL Wealth, LLC d/b/a MBL Advisors (the
“Firm”). The Promoter and the Firm are not affiliated entities. The Promoter is not a current
client of the Firm. The Promoter has signed a written compensation arrangement with the
Firm. Under the terms of the arrangement, Promoter receives cash compensation from the
Firm for recommendations to use the Firm’s investment advisory services. Full disclosure of
this relationship will be provided to any relevant client.
MBL Wealth does not receive compensation, directly or indirectly, for referring clients to other
advisers.
CUSTODY (ITEM 15)
Other than as described below, MBL Wealth does not maintain physical custody of client funds
or securities. We require that a qualified custodian hold client assets. Information about the
custodian We recommend is fully described in the Brokerage Practices section (Item 12). We
have implemented the safeguard requirements of SEC regulations by requiring safekeeping
of clients’ funds and securities by a qualified custodian.
MBL Wealth shall have the ability to have its advisory fee for each client debited by the
custodian on a quarterly basis. Client account statements are mailed or sent electronically by
the account custodian. At least quarterly, clients are provided written transaction confirmation
notices and regular written summary statements directly from the broker-dealer/custodian
and/or program sponsor for the client accounts. This statement shall disclose to the client the
amount of the fee, the client’s assets upon which the fee was based, and the specific manner
in which the fee was calculated. The account custodian does not verify the accuracy of MBL
Wealth’s advisory fee calculation. Clients are advised to review these statements carefully,
comparing asset values, holdings, and advisory fees on account statements to that in
previously received statements, confirmations, and fee invoices.
MBL Wealth has custody of client funds or securities due to Our standing authority to make
third-party transfers on behalf of Our clients who have granted Us such authority. This
authority is granted to Us by the client through the use of a standing letter of authorization
(“LOA”) established by the client with his or her qualified custodian. The standing LOA
authorizes Our Firm to disburse funds to one or more third parties specifically designated by
the client pursuant to the terms of the LOA and can be changed or revoked by the client at
any time. In addition to Our requirement that a qualified custodian hold client assets, We have
implemented procedures to comply with the requirements outlined by the SEC in its February
21, 2017 No-Action Letter to the Investment Adviser Association. Information about the
custodian that We recommend is fully described in the Brokerage Practices section, Item 12.
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INVESTMENT DISCRETION (ITEM 16)
Most investment management clients grant MBL Wealth the authority to exercise discretion
on behalf of clients. We are considered to exercise investment discretion over a client’s
account if We can effect transactions for the client without first having to seek the client’s
consent for each transaction. MBL Wealth is given this authority through a power-of-attorney
included in the agreement between Us and the client. Clients may request a reasonable
limitation on this authority (such as certain securities not to be bought or sold). With client
consent, We take discretion over the following activities, among others:
• The securities to be purchased or sold;
• The amount of securities to be purchased or sold; and
• When transactions are made.
If management services are selected to be provided on a non-discretionary basis, MBL Wealth
always contacts clients before implementing any transactions in an account. Clients must
accept or reject MBL Wealth’s investment recommendations, including (1) the security being
recommended, (2) the number of shares or units and (3) whether to buy or sell. Once these
factors are agreed upon, MBL Wealth is responsible for making decisions regarding the timing
of the purchase or sale and the price at which it is bought or sold. Clients should know that if
they are not able to be reached or are slow to respond to MBL Wealth’s request, it can have
an adverse impact on the timing of implementing trades and MBL Wealth may not achieve
the optimal trading price.
VOTING CLIENT SECURITIES (ITEM 17)
In the absence of an agreement to the contrary, MBL Wealth votes proxies on individual
securities held in clients’ accounts that are managed by MBL Wealth directly. The term
“individual securities” refers solely to the securities of individual corporate issuers, and shall
exclude mutual funds, exchange traded funds, other pooled investment vehicles, and the like.
MBL Wealth will not vote proxies in client accounts that are managed in any capacity by any
third-party asset manager or sub-adviser. In cases where a third-party asset manager or sub-
adviser manages the account holding individual securities, MBL Wealth shall delegate its
responsibility for voting in those accounts to the respective third-party asset manager or sub-
adviser.
MBL Wealth will typically not vote any security in circumstances under which casting that vote
would not reasonably be expected to have a material effect on the value of the client’s
investment.
Where MBL Wealth has assumed the authority to vote on behalf of a client, MBL Wealth must
have a reasonable understanding of that client’s objectives and must make voting
determinations that are in the best interest of that client. MBL Wealth shall timely review all
proxies received for that client and assess the potential effect of a vote on the value of that
particular client’s investment. All decisions made as to whether or how to vote a proxy for a
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client will be made on a case-by-case basis by MBL Wealth in its exclusive discretion in light
of that particular client’s best interests and will be documented accordingly.
MBL’s authority and responsibility to vote proxies is described in the agreement between MBL
and the client. Clients whose agreements do not contain that grant of authority will receive
proxies directly from the issuer or the custodian and are solely responsible for making all
relevant elections pertaining to the securities in those accounts.
FINANCIAL INFORMATION (ITEM 18)
MBL Wealth does not require or solicit the prepayment of more than $1,200 in fees six months
or more in advance of services rendered. We do not have a financial condition that is
reasonably likely to impair Our ability to meet contractual commitments to clients and We
have not been the subject of a bankruptcy petition at any time during the past ten years.
PRIVACY POLICY
Effective: December 4, 2019
Our Commitment to You
MBL Wealth is committed to safeguarding the use of personal information of our clients (also
referred to as “you” and “your”) that we obtain as your investment adviser, as described here
in our Privacy Policy.
Our relationship with you is our most important asset. We understand that you have entrusted
us with your private information, and we do everything that we can to maintain that trust. MBL
Wealth (also referred to as "we", "our" and "us”) protects the security and confidentiality of the
personal information we have and implements controls to ensure that such information is
used for proper business purposes in connection with the management or servicing of our
relationship with you.
MBL Wealth does not sell your non-public personal information to anyone. Nor do we provide
such information to others except for discrete and reasonable business purposes in
connection with the servicing and management of our relationship with you, as discussed
below.
Details of our approach to privacy and how your personal non-public information is collected
and used are set forth in this Privacy Policy.
Why you need to know?
Registered Investment Advisers (“RIAs”) must share some of your personal information in the
course of servicing your account. Federal and State laws give you the right to limit some of
this sharing and require RIAs to disclose how we collect, share, and protect your personal
information.
What information do we collect from you?
Driver’s license number
Date of birth
Assets and liabilities
Social security or taxpayer identification
number
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Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Investment experience and goals
Account information (including other
institutions)
What Sources do we use to collect your information?
Custody, brokerage and advisory agreements Account applications and forms
Other advisory agreements and legal
documents
Investment questionnaires and suitability
documents
Transactional information with us or others Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain
physical, procedural and electronic security measures. These include such safeguards as
secure passwords, encrypted file storage and a secure office environment. Our technology
vendors provide security and access control over personal information and have policies over
the transmission of data. Our associates are trained on their responsibilities to protect our
clients’ personal information.
We require third parties that assist in providing our services to you to protect the personal
information they receive from us.
How do we share your information?
An RIA shares client personal information to effectively implement its services. In the section
below, we list some reasons we may share your personal information.
Basis For Sharing
Do we
share?
Can you
limit?
Yes
No
No
Not
Shared
Servicing Our Clients
We may share non-public personal information with non-affiliated
third parties (such as administrators, brokers, custodians, regulators,
credit agencies, other financial institutions) as necessary for us to
provide agreed upon services to you, consistent with applicable law,
including but not limited to: processing transactions; general account
maintenance; responding to regulators or legal investigations; and
credit reporting.
Marketing Purposes
MBL Wealth does not disclose, and does not intend to disclose,
personal information with non-affiliated third parties to offer you
services. Certain laws may give us the right to share your personal
information with financial institutions where you are a customer and
where MBL Wealth or the client has a formal agreement with the
financial institution. We will only share information for purposes of
servicing your accounts, not for marketing purposes. Mobile
information will not be shared with third parties/affiliates for
marketing/promotional purposes. All the above (or below) categories
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Yes
Yes
No
Not
Shared
exclude text messaging originator opt-in data and consent; this
information will not be shared with any third parties.
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent[s] or
representative[s].
Information About Former Clients
MBL Wealth does not disclose and does not intend to disclose non-
public personal information to non-affiliated third parties with respect
to persons who are no longer our clients.
Changes to our Privacy Policy
We will send you a copy of this Privacy Policy annually for as long as you maintain an ongoing
relationship with us.
Periodically we may revise this Privacy Policy and will provide you with a revised policy if the
changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy
Policy to permit the sharing of non-public personal information other than as described in this
notice unless we first notify you and provide you with an opportunity to prevent the information
sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy
Policy by contacting us at 704-333-8461 or via email at info@mbl-advisors.com.
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