View Document Text
Montis Financial, LLC
230 Third Avenue
Waltham, MA 02451
Phone (781) 541-5057
Fax: (781) 547-5596
Firm CRD#: 163986
SEC File No. 801-76534
March 28, 2025
FORM ADV PART 2A
BROCHURE
This brochure provides information about the qualifications and business practices of Montis Financial,
LLC. If you have any questions about the contents of this brochure, please contact us at (781) 541-
5057 or via email at jyanchek@montisfinancial.com.
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. Please note, where this brochure
may use the terms "registered investment adviser" and/or "registered", registration itself does not imply
a certain level of skill or training.
Additional information about our firm also is available on the SEC's website at
www.adviserinfo.sec.gov.
Item 2 Material Changes
Form ADV Part 2 requires registered investment advisers to amend their brochure when information
becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure,
the adviser is required to notify you and provide you with a description of the material changes.
ANY QUESTIONS: Montis’ Chief Compliance Officer, John Yanchek, remains available to address any
questions regarding any portion of this Brochure.
Since our last annual updating amendment dated March 19, 2024, we have not materially amended
this Disclosure Brochure.
Item 3 Table Of Contents
Item 2 Material Changes .............................................................................................................. 2
Item 3 Table Of Contents ............................................................................................................. 3
Item 4 Investment Advisory Business .......................................................................................... 4
Item 5 Fees and Compensation ................................................................................................... 9
Item 6 Performance-Based Fees and Side by Side Management .............................................. 11
Item 7 Types of Clients .............................................................................................................. 11
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ......................................... 11
Item 9 Disciplinary Information ................................................................................................... 13
Item 10 Other Financial Industry Activities and Affiliations ......................................................... 13
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ... 13
Item 12 Brokerage Practices ...................................................................................................... 14
Item 13 Review of Accounts ....................................................................................................... 15
Item 14 Client Referrals and Other Compensation ..................................................................... 16
Item 15 Custody ......................................................................................................................... 16
Item 16 Investment Discretion .................................................................................................... 17
Item 17 Voting Client Securities ................................................................................................. 17
Item 18 Financial Information ..................................................................................................... 17
Montis’ Chief Compliance Officer, John Yanchek, remains available to address any questions
regarding this Part 2A. ........................................................................................................................ 17
Item 4 Investment Advisory Business
Established in 2012, Montis Financial, LLC ("Montis") provides investment advice to clients through a
combination of financial planning and investment asset management services. Montis is owned by
Montis HoldCo LLC.
Comprehensive Planning & Asset Management Service
Clients with $2 million or more in assets may receive our comprehensive planning and asset
management service, tailored specifically to a client's investment needs. We work with you to assess a
variety of personal factors including your goals and objectives, sources of income, insurance and
estate needs, asset distribution and risk tolerance. We then develop a financial plan which may include
an analysis of your current assets, risk management, financial independence, retirement planning,
estate planning, asset allocation and diversification. Once we deliver your financial plan to you, we
work with you to determine the best asset management strategy and investments to implement this
plan. The investments we may recommend include short-term cash instruments, mutual funds, money
managers, limited partnerships, real estate investment trusts (often known as REITs), government
securities, corporate/municipal debt (bonds) and equity securities (stocks). You may impose
restrictions on our services at any time.
Montis also offers comprehensive planning and asset management services to clients regarding assets
on which Montis does not provide continuous and regular supervisory or management services. These
assets, known as "assets under advisement", are maintained at the issuer or custodian designated by
the product sponsor, and may include, but are not limited to, certain variable annuity products, 529
college savings plans, limited partnerships, and individual employer-sponsored retirement and deferred
compensation plans. For
these assets, while Montis may provide asset management
recommendations, Montis does not have the authority to place transactions. In such situations, the
client will be responsible for arranging the transactions.
For individual retail (i.e., non-institutional) clients, Montis’ annual investment advisory fee shall
generally (exceptions can occur-see below) include investment advisory services, and, to the extent
specifically requested by the client, financial planning and consulting services. In the event that the
client requires extraordinary planning and/or consultation services (to be determined in the sole
discretion of Montis), Montis may determine to charge for such additional services, the dollar amount of
which shall be set forth in a separate written notice to the client.
Retirement Plan Consulting Services
Montis provides retirement plan consulting/management services, pursuant to which it assists
sponsors of self-directed retirement plans organized under the Employee Retirement Security Act of
1974 (“ERISA”). The terms and conditions of the engagement shall be set forth in a Retirement Plan
Services Agreement between Montis and the plan sponsor.
In providing these services, Montis can assist with the selection and/or monitoring of investment
options (generally open-end mutual funds) from which plan participants shall choose in self-directing
the investments for their individual plan retirement accounts. Montis provides these services in its
capacity as an ERISA Section 3(21) fiduciary. To the extent requested by the plan sponsor, Montis
may also create specific asset allocation models, from which plan participants may choose in
managing their individual retirement accounts. To the extent Montis provides these services on a
discretionary basis, it does so in its capacity as an ERISA Section 3(38) investment manager.
Other Consultative Services
Upon request, we evaluate portfolios, and offer specific recommendations about investment strategy,
asset allocation, and diversification separate from our comprehensive planning and asset management
service described above. We may also provide our comprehensive and integrated financial planning
analysis at an hourly rate.
For certain clients such as institutional accounts, trusts, retirement plans and individual clients seeking
only investment consulting and portfolio monitoring services, we perform third-party money manager
searches and consulting on mutual funds independently of the comprehensive and integrated financial
plan described above. Should we recommend a third-party investment adviser to manage all, or a
portion of, a client's assets, the client will be required to enter into a separate written agreement with
the third-party adviser, and as described below, the third-party adviser's fees will be charged
separately from our fees.
IRA Rollover Recommendations
Please Note: Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client
leaving an employer typically has four options regarding an existing retirement plan (and may engage
in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii)
roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll
over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could,
depending upon the client’s age, result in adverse tax consequences). If Montis recommends that a
client roll over their retirement plan assets into an account to be managed by Montis, such a
recommendation creates a conflict of interest if Montis will earn new (or increase its current)
compensation as a result of the rollover. If Montis provides a recommendation as to whether a client
should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Montis is
acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act
and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No
client is under any obligation to roll over retirement plan assets to an account managed by
Montis, whether it is from an employer’s plan or an existing IRA. Montis’ Chief Compliance
Officer, John Yanchek, remains available to address any questions that a client or prospective
client may have regarding the potential for conflict of interest presented by such rollover
recommendation.
Assets Under Management
As of December 31, 2024, we provide continuous management services for $971,558,752 in client
assets on a discretionary basis, and $40,856,437 in client assets on a non-discretionary basis.
Miscellaneous
Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To
the extent requested by the client, Montis will generally provide financial planning and related
consulting services regarding matters such as tax and estate planning, insurance, etc. Montis will
generally provide such consulting services inclusive of its advisory fee set forth at Item 5 below
(exceptions could occur based upon assets under management, extraordinary matters, special
projects, stand-alone planning engagements, etc. for which Firm may charge a separate or additional
fee). Please Note. Montis believes that it is important for the client to address financial planning issues
on an ongoing basis. Montis’ advisory fee, as set forth at Item 5 below, will remain the same regardless
of whether or not the client determines to address financial planning issues with Montis. Please Also
Note: Montis does not serve as an attorney, accountant, or insurance agent, and no portion of our
services should be construed as same. Accordingly, Montis does not prepare legal documents,
prepare tax returns, or sell insurance products. To the extent requested by a client, we may
recommend the services of other professionals for non-investment implementation purpose (i.e.
attorneys, accountants, insurance, etc.). The client is not under any obligation to engage any such
professional(s). The client retains absolute discretion over all such implementation decisions and is
free to accept or reject any recommendation from Montis and/or its representatives. If the client
engages any professional (i.e. attorney, accountant, insurance agent, etc.), recommended or
otherwise, and a dispute arises thereafter relative to such engagement, the client agrees to seek
recourse exclusively from the engaged professional. At all times, the engaged licensed professional[s]
(i.e. attorney, accountant, insurance agent, etc.), and not Montis, shall be responsible for the quality
and competency of the services provided.
Please Note-Use of Mutual and Exchange Traded Funds: Most mutual funds and exchange traded
funds are available directly to the public. Thus, a prospective client can obtain many of the funds that
may be utilized by Montis independent of engaging Montis as an investment adviser. However, if a
prospective client determines to do so, he/she will not receive Montis’ initial and ongoing investment
advisory services. Please Also Note: In addition to Montis’ investment advisory fee described below,
and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund
and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and
other fund expenses).
Please Note-Use of DFA Mutual Funds: Montis utilizes the mutual funds issued by Dimensional Fund
Advisors (“DFA”). DFA funds are generally only available through registered investment advisers
approved by DFA. Thus, if the client was to terminate Montis’ services, and transition to another
adviser who has not been approved by DFA to utilize DFA funds, restrictions regarding additional
purchases of, or reallocation among other DFA funds, will generally apply.
Interval Funds/Risks and Limitations: Where appropriate, Montis Financial, LLC (“Montis”) may
utilize interval funds. An interval fund is a non-traditional type of closed-end mutual fund that
periodically offers to buy back a percentage of outstanding shares from shareholders. Investments in
an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals. During
any time periods outside of the specified repurchase offer window(s), investors will be unable to sell
their shares of the interval fund. There is no assurance that an investor will be able to tender shares
when or in the amount desired. There can also be situations where an interval fund has a limited
amount of capacity to repurchase shares, and may not be able to fulfill all purchase orders. In addition,
the eventual sale price for the interval fund could be less than the interval fund value on the date that
the sale was requested. While an internal fund periodically offers to repurchase a portion of its
securities, there is no guarantee that investors may sell their shares at any given time or in the desired
amount. As interval funds can expose investors to liquidity risk, investors should consider interval fund
shares to be an illiquid investment. Typically, the interval funds are not listed on any securities
exchange and are not publicly traded. Thus, there is no secondary market for the fund’s shares.
Because these types of investments involve certain additional risk, these funds will only be utilized
when consistent with a client’s investment objectives, individual situation, suitability, tolerance for risk
and liquidity needs. Investment should be avoided where an investor has a short-term investing
horizon and/or cannot bear the loss of some, or all, of the investment. There can be no assurance that
an interval fund investment will prove profitable or successful. In light of these enhanced risks, a
client may direct Montis, in writing, not to employ any or all such strategies for the
client’s account.
Please Note: Inverse/Enhanced Market Strategies. Montis may utilize long and short mutual funds
and/or exchange traded funds that are designed to perform in either an: (1) inverse relationship to
certain market indices (at a rate of 1 or more times the inverse [opposite] result of the corresponding
index) as an investment strategy and/or for the purpose of hedging against downside market risk; and
(2) enhanced relationship to certain market indices (at a rate of 1 or more times the actual result of the
corresponding index) as an investment strategy and/or for the purpose of increasing gains in an
advancing market. There can be no assurance that any such strategy will prove profitable or
successful. To the contrary, such funds and/or strategy(ies) can suffer substantial losses. In light of
these enhanced risks/rewards, a client may direct Montis, in writing, not to employ any or all such
strategies for his/her/their/its accounts
Cybersecurity Risk. The information technology systems and networks that Montis and its third-party
service providers use to provide services to Montis’ clients employ various controls that are designed
to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause
significant interruptions in Montis’ operations and/or result in the unauthorized acquisition or use of
clients’ confidential or non-public personal information. In accordance with Regulation S-P, Montis is
committed to protecting the privacy and security of its clients' non-public personal information by
implementing appropriate administrative, technical, and physical safeguards. Montis has established
processes to mitigate the risks of cybersecurity incidents, including the requirement to restrict access
to such sensitive data and to monitor its systems for potential breaches. Clients and Montis are
nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur
financial losses and/or other adverse consequences. Although Montis has established processes to
reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be
successful, especially considering that Montis does not control the cybersecurity measures and
policies employed by third-party service providers, issuers of securities, broker-dealers, qualified
custodians, governmental and other regulatory authorities, exchanges, and other financial market
operators and providers. In compliance with Regulation S-P, Montis will notify clients in the event of a
data breach involving their non-public personal information as required by applicable state and federal
laws.
to Bitcoin,
Bitcoin, Cryptocurrency, and Digital Assets. For clients who want exposure
cryptocurrencies, or digital assets, Montis, will advise the client to consider a potential investment in
corresponding exchange traded securities, or an allocation to separate account managers and/or
private funds that provide cryptocurrency exposure. Bitcoin and cryptocurrencies are digital assets that
can be used for various purposes, including transactions, decentralized applications, and speculative
investments. Most digital assets use blockchain technology, an advanced cryptographic digital ledger
to secure transactions and validate asset ownership. Unlike conventional currencies issued and
regulated by monetary authorities, cryptocurrencies generally operate without centralized control, and
their value is determined by market supply and demand. While regulatory oversight of digital assets
has evolved significantly since their inception, they remain subject to variable regulatory treatment
globally, which may impact their risk profile and liquidity. Given that cryptocurrency investments are
speculative and subject to extreme price volatility, liquidity constraints, and the potential for total loss of
principal, Montis does not exercise discretionary authority to purchase cryptocurrency investments for
client accounts. Any investment in cryptocurrencies must be expressly authorized by the client. Montis
does not recommend or advocate for the purchase of, or investment in, Bitcoin, cryptocurrencies, or
digital assets. Such investments are considered speculative and carry significant risk. Clients who
authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity
constraints, extreme price volatility, regulatory risk, technological risk, security and custody risk, and
complete loss of principal.
Independent Managers. Montis may allocate a portion of a client’s investment assets among
unaffiliated independent investment managers in accordance with the client’s designated investment
objective(s). In such situations, the Independent Manager[s] shall have day-to- day responsibility for
the active discretionary management of the allocated assets, including , to the extent applicable, proxy
voting responsibility. Montis shall continue to render investment supervisory services to the client
relative to the ongoing monitoring and review of account performance, asset allocation and client
investment objectives. Factors which Montis shall consider in recommending Independent Manager[s]
include the client’s designated investment objective(s), management style, performance, reputation,
financial strength, reporting, pricing, and research. Please Note: The investment management fee
charged by the Independent Manager[s] is separate from, and in addition to, Montis’ advisory fee as
set forth in the fee schedule at Item 5 below.
Unaffiliated Private Investment Funds. Montis also provides investment advice regarding private
investment funds. Montis, on a non-discretionary basis, may recommend that certain qualified clients
consider an investment in private investment funds, the description of which (the terms, conditions,
risks, conflicts and fees, including incentive compensation) is set forth in the fund’s offering documents.
Montis’ role relative to unaffiliated private investment funds shall be limited to its initial and ongoing due
diligence and investment monitoring services. If a client determines to become an unaffiliated private
fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under
management” for purposes of Montis calculating its investment advisory fee. Montis’ fee shall be in
addition to the fund’s fees. Montis’ clients are under absolutely no obligation to consider or make an
investment in any private investment fund(s).
Please Note: Private investment funds generally involve various risk factors, including, but not limited
to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete
discussion of which is set forth in each fund’s offering documents, which will be provided to each client
for review and consideration. Unlike liquid investments that a client may own, private investment funds
do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a
Subscription Agreement, pursuant to which the client shall establish that the client is qualified for
investment in the fund, and acknowledges and accepts the various risk factors that are associated with
such an investment.
Please Also Note: Valuation. In the event that Montis references private investment funds owned by
the client on any supplemental account reports prepared by Montis, the value(s) for all private
investment funds owned by the client shall reflect the most recent valuation provided by the fund
sponsor. However, if subsequent to purchase, the fund has not provided an updated valuation, the
valuation shall reflect the initial purchase price. If subsequent to purchase, the fund provides an
updated valuation, then the statement will reflect that updated value. The updated value will continue
to be reflected on the report until the fund provides a further updated value.
Please Also Note: As result of the valuation process, if the valuation reflects initial purchase price or
an updated value subsequent to purchase price, the current value(s) of an investor’s fund holding(s)
could be significantly more or less than the value reflected on the report. Unless otherwise indicated,
Montis shall calculate its fee based upon the latest value provided by the fund sponsor.
Custodian Charges-Additional Fees. As discussed below at Item 12 below, when requested to
recommend a broker-dealer/custodian for client accounts, Montis generally recommends that Charles
Schwab and Co., Inc. (“Schwab”) or Fidelity Brokerage Service, LLC and National Financial Services,
LLC (collectively “Fidelity”), serve as the broker-dealer/custodian for client investment management
assets. The specific broker-dealer/custodian recommended could depend upon the scope and nature
of the services required by the client. Broker-dealers such as Schwab and Fidelity charge brokerage
commissions, transaction, and/or other type fees for effecting certain types of securities transactions
(i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for
fixed income transactions, etc.). The types of securities for which transaction fees, commissions,
and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-
dealer/custodian (while certain custodians, including Schwab and Fidelity, do not currently charge fees
on individual equity transactions, others do. Please Note: there can be no assurance that Schwab
and/or Fidelity will not change their transaction fee pricing in the future). ANY QUESTIONS: Montis’
Chief Compliance Officer, John Yanchek, remains available to address any questions that a
client or prospective client may have regarding the above.
Please Note: Cash Positions. Montis continues to treat cash as an asset class. As such, unless
determined to the contrary by Montis, all cash positions (money markets, etc.) shall continue to be
included as part of assets under management for purposes of calculating Montis’ advisory fee. At any
specific point in time, depending upon perceived or anticipated market conditions/events (there being
no guarantee that such anticipated market conditions/events will occur), Montis may maintain cash
positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could
miss market advances. Depending upon current yields, at any point in time, Montis’ advisory fee could
exceed the interest paid by the client’s money market fund. ANY QUESTIONS: Montis’ Chief
Compliance Officer, John Yanchek, remains available to address any questions that a client or
prospective may have regarding the above fee billing practice.
Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account
transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated
sweep account. The yield on the sweep account will generally be lower than those available for other
money market accounts. When this occurs, to help mitigate the corresponding yield dispersion, Montis
shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money
market fund (or other type security) available on the custodian’s platform, unless Montis reasonably
anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase
additional investments for the client’s account. Exceptions and/or modifications can and will occur with
respect to all or a portion of the cash balances for various reasons, including, but not limited to the
amount of dispersion between the sweep account and a money market fund, the size of the cash
balance, an indication from the client of an imminent need for such cash, or the client has a
demonstrated history of writing checks from the account
Please Note: The above does not apply to the cash component maintained within a Montis actively
managed investment strategy (the cash balances for which shall generally remain in the custodian
designated cash sweep account), assets allocated to an unaffiliated investment manager, and cash
balances maintained for fee billing purposes.
Please Also Note: The client shall remain exclusively responsible for yield dispersion/cash balance
decisions and corresponding transactions for cash balances maintained in any Montis unmanaged
accounts. ANY QUESTIONS: Montis’ Chief Compliance Officer, John M. Yanchek, remains
available to address any questions that a client or prospective client may have regarding the
above.
Client Retirement Plan Assets. If requested to do so, Montis shall provide investment advisory
services relative to the client’s 401(k) plan assets. In such event, unless otherwise agreed upon,
Montis shall recommend that the client allocate the retirement account assets among the investment
options available on the 401(k) platform. Montis shall be limited to making recommendations regarding
the allocation of the assets among the investment alternatives available through the plan. Montis will
not receive any communications from the plan sponsor or custodian, and it shall remain the client’s
exclusive obligation to notify Montis of any changes in investment alternatives, restrictions, etc.
pertaining to the retirement account.
Portfolio Activity. Montis has a fiduciary duty to provide services consistent with the client’s best
interest. As part of its investment advisory services, Montis will review client portfolios on an ongoing
basis to determine if any changes are necessary based upon various factors, including, but not limited
investment performance,
fund manager
to,
tenure, market conditions, style drift, account
additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors,
there may be extended periods of time when Montis determines that changes to a client’s portfolio are
neither necessary nor prudent. Of course, as indicated below, there can be no assurance that
investment decisions made by Montis will be profitable or equal any specific performance level(s).
Socially Responsible (ESG) Investing Limitations. Socially Responsible Investing involves the
incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment
due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential
investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e.,
the manner in which a company manages relationships with its employees, customers, and the
communities in which it operates); and Governance (i.e., company management considerations). The
number of companies that meet an acceptable ESG mandate can be limited when compared to those
that do not, and could underperform broad market indices. Investors must accept these limitations,
including potential for underperformance. As with any type of investment (including any investment
and/or investment strategies recommended and/or undertaken by Montis), there can be no assurance
that investment in ESG securities or funds will be profitable, or prove successful. Montis generally
relies on the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or
separate account manager to determine that the fund’s or portfolio’s underlying company securities
meet a socially responsible mandate.
in his/her/its
for
Client Obligations. In performing our services, Montis shall not be required to verify any information
received from the client or from the client's other professionals and is expressly authorized to rely
thereon. Moreover, it remains each client’s responsibility to promptly notify Montis if there is ever any
change
the purpose of
investment objectives
financial situation or
reviewing/evaluating/revising our previous recommendations and/or services.
Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and it
should not be assumed that future performance of any specific investment or investment strategy
(including the investments and/or investment strategies recommended or undertaken by Montis) will be
profitable or equal any specific performance level(s).
Item 5 Fees and Compensation
Comprehensive Planning & Asset Management Service
We charge an asset-based fee for this service. The fees are charged based on the average daily
balance under Montis’ management/advisement per a tiered schedule set forth in the agreement
between Montis and the client. Certain Clients are grandfathered in based on a percentage of the
market value of the portfolio managed. Certain legacy clients are billed based upon the value in their
accounts at semi -annual intervals.
The fee for our Comprehensive Planning & Asset Management Service ranges from 0.48% to a
maximum of 1.50% of assets under management/advisement.
We deduct our fees, at the beginning of the applicable period, from your account(s), unless we have
agreed to another payment arrangement. Should you terminate your arrangement with us, you will
receive a pro-rata refund of fees collected for services not rendered. We may reduce or waive our fees
from time to time in our discretion. In addition, we require a minimum fee of $2,500/quarter regardless
of asset size for all new clients, which may be waived from time to time. See disclosure at Item 7
below.
Please Note: Fee Differentials. Montis shall generally price its advisory services based upon various
objective and subjective factors. As a result, our clients could pay diverse fees based upon the type,
amount and market value of their assets, the anticipated complexity of the engagement, the anticipated
level and scope of the overall investment advisory and consulting services to be rendered. Additional
factors affecting pricing can include related accounts, employee accounts, referrals from existing
clients, competition, and negotiations. Please Also Note: As a result of these objective and subjective
factors, similarly situated clients could pay diverse fees, and the services to be provided by Montis to
any particular client could be available from other advisers at lower fees. All clients and prospective
clients should be guided accordingly. ANY QUESTIONS: Montis’ Chief Compliance Officer, Name of
CCO, remains available to address any questions regarding advisory fees.
Cash Balances Policy
It is the Firm’s policy that cash and cash equivalents (i.e., money market accounts) are an asset class.
Absent approved mitigating circumstances and/or deviations, it is the Firm’s policy to include cash
balances as part of assets under management for fee billing purposes. Exceptions or modifications
shall be approved by the Chief Compliance Officer. Reasons for exceptions include, but are not limited
to:
• Segregation of cash needed for short-term purposes (i.e., house purchase, medical expenses,
college tuition, etc.);
• Competition;
• Negotiations with the client; and,
• Hardship
The Firm, at its discretion, may suspend and/or modify its policy to bill on cash balances during any
specific billing quarter, including in the event that such billing would result in the client receiving a
negative yield.
Retirement Plan Consulting Services
We charge an asset-based fee for this service. The fees are negotiable and are charged based on a
percentage of the market value of the portfolio under Montis’ management/advisement per a tiered
schedule set forth in the agreement between Montis and the client.
The fee for our Retirement Plan Consulting Services range from 0.3% to a maximum of 0.8% of assets
under management/advisement.
Montis, in its sole discretion, may charge a lesser fee based upon certain criteria (i.e., anticipated
future additional assets, dollar amount of assets in the plan, related plans, plan composition, prior fee
schedules, competition, negotiations with client, etc.). Please Note: As result of the above, similarly
situated plans could pay different fees. In addition, similar advisory services may be available from
other investment advisers for similar or lower fees.
If permitted by a retirement plan’s governing documents, plan clients may elect to have their fees
deducted from plan assets. Both Montis’ Retirement Plan Services Agreement and the
custodial/clearing agreement may authorize the custodian to debit the account for the amount of
Montis’ fee and to directly remit that fee to Montis in compliance with regulatory procedures. In the
limited event that Montis bills the client directly, payment is due upon receipt of Montis’ invoice. Unless
otherwise agreed, Montis shall deduct fees and/or bill clients quarterly in advance. We calculate our
fee twice per year, in December and June, based upon the market value of the plan assets.
The Retirement Plan Services Agreement between Montis and the client will continue in effect until
terminated by either party upon written notice in accordance with the terms of the Retirement Plan
Services Agreement. If an engagement is terminated, and the effective date of termination is in the
middle of a fee period, Montis will either refund the prepaid but unearned portion of the client’s fee (for
plans paying in advance) or assess a final quarterly fee, prorated through the effective date of
termination (for plans paying in arrears). Montis reserves the right to waive this final prorated fee, at its
sole discretion.
Other Consultative Services
in
As described
Item 4 above, upon request, we evaluate portfolios, and offer specific
recommendations about investment strategy, asset allocation, and diversification separate from our
comprehensive planning and asset management service described above. We charge an hourly
rate for this service and typically require pre-payment of a portion of the estimated amount before
performing these services.
We may also provide our comprehensive and integrated financial planning analysis at an hourly rate
and typically require pre-payment of a portion of the estimated amount before performing these
services.
Our standard hourly rate is $350/hour. Rates may be modified at our discretion and will be agreed
upon in writing.
From time to time, when we reasonably determine it is in the best interest of the client (i.e., based upon
the amount of assets to be invested, the non-availability of a lower share class option, etc.), we may
recommend and/or utilize "No Transaction Fee" funds through Schwab or Fidelity. You should be
aware that in order to be considered a No Transaction Fee fund, mutual fund companies will pay
money to Schwab or Fidelity which in turn may increase the annual fund expenses you pay for these
"No Transaction Fee" funds. We do not receive any compensation that Schwab or Fidelity receives
from a mutual fund company.
Unless you direct us otherwise or have unique individual circumstances, we will generally recommend
that Schwab, Fidelity or NATC (see disclosure at Item 10 below) serve as the broker-dealer or
custodian for your investment management assets. Broker-dealers such as Schwab and Fidelity
charge brokerage commissions and/or transaction fees for effecting certain securities transactions.
Usually, transaction fees correspond to investments like no-load mutual funds and commissions relate
to individual equity and fixed income securities transactions. Mutual funds and exchange traded funds
impose their own management fees and other fund related expenses which you will also bear in
addition to our fees and any brokerage commissions and/or transaction fees.
Item 6 Performance-Based Fees and Side by Side Management
We do not charge performance-based fees.
Item 7 Types of Clients
Our clients include individuals, high net worth individuals, and professional associations.
We generally require a minimum fee of $2,500/quarter regardless of account size for all new clients.
The Firm does not have a minimum asset requirement for assets under management.
Fee Dispersion. Montis, in its discretion, may waive its minimum fee, charge a lesser investment
advisory fee, charge a flat fee, waive its fee entirely, or charge fee on a different interval, based upon
certain criteria (i.e. anticipated future earning capacity, anticipated future additional assets, dollar
amount of assets to be managed, related accounts, account composition, complexity of the
engagement, anticipated services to be rendered, grandfathered fee schedules, employees and family
members, courtesy accounts, competition, negotiations with client, etc.). Please Note: As result of the
above, similarly situated clients could pay different fees. In addition, similar advisory services may be
available from other investment advisers for similar or lower fees. ANY QUESTIONS: Montis’ Chief
Compliance Officer, John Yanchek, remains available to address any questions that a client or
prospective client may have regarding advisory fees.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Our main sources of information include financial newspapers and magazines, inspections of corporate
activities, research materials prepared by others, corporate rating services, timing services, annual
reports, prospectuses, filings with the Securities and Exchange Commission, and company press
releases. We also rely on third-party data and analysis providers for both printed and online reports
and analysis. Such providers include Morningstar, Valueline, and Frontier Analytics.
Your investment strategy is based upon the objectives you state to us during consultations.
You should be aware that different types of investments and strategies involve differing degrees of risk.
You should not assume that future performance of any of your specific investments or investment
strategy, including those we recommend, will be profitable or equal any specific performance levels.
Any investment or investment strategy involves some risk of loss you should be prepared to bear.
Examples of risk you could face are:
• Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For
example, market values of bonds decline when interest rates rise because the rising rate makes
the existing bond yields less attractive.
• Market Risk: External factors independent of a security's particular underlying circumstances
may impact its price. The price of a security, bond, or mutual fund may drop in reaction to
tangible and intangible events and conditions such as a political or social event or an economic
condition.
• Inflation Risk: Inflation means a dollar today will not buy as much as a dollar next year. When
any type of inflation is present your purchasing power decreases at the rate of inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar
against the currency of the investment's originating country. Also known as exchange rate risk,
these risks may be present in international mutual funds for example.
• Reinvestment Risk: The risk that future proceeds from investments may be reinvested at a
potentially lower rate of return is reinvestment risk. This risk primarily relates to fixed income
securities.
• Business Risk: Risks associated with a particular industry or a specific company may impact
the value of investments. For example, oil-drilling companies have more business risk than
electric companies since they depend on finding oil and then refining it efficiently before they
may generate a profit. An electric company generates steady income customers who buy
electricity no matter what the economic environment is like.
• Liquidity Risk: Liquidity means the ability to readily convert an investment into cash. Assets with
a lot of interest from purchasers are generally more liquid. For example, Treasury Bills are
highly liquid, while real estate properties are not.
• Financial Risk: A company with excessive borrowing to finance a business' operations
increases the risk of profitability they may be unable to meet loan obligations during periods of
financial stress.
Our methods of analysis and investment strategies do not present any significant or unusual risks.
However, every method of analysis has its own inherent risks. We rely upon current and new market
information to help perform accurate market analysis for you, but we have no control over how quickly
or how often that market information is communicated. As a result, our analysis may incorporate
outdated market information resulting in us providing a limited analysis to you. You should also
remember that any market analysis can only produce a forecast of the direction of market values.
There are no assurances or guarantees that any forecast will materialize and present profitable
investment opportunities.
Options Strategies.
As discussed above, Montis may engage in options transactions for the purpose of hedging risk and/or
generating portfolio income. The use of options transactions as an investment strategy can involve a
high level of inherent risk. Option transactions establish a contract between two parties concerning the
buying or selling of an asset at a predetermined price during a specific period of time. During the term
of the option contract, the buyer of the option gains the right to demand fulfillment by the seller.
Fulfillment may take the form of either selling or purchasing a security, depending upon the nature of
the option contract. Generally, the purchase or sale of an option contract shall be with the intent of
“hedging” a potential market risk in a client’s portfolio and/or generating income for a client’s portfolio.
Please Note: Certain options-related strategies (i.e. straddles, short positions, etc.), may, in and of
themselves, produce principal volatility and/or risk. Thus, a client must be willing to accept these
enhanced volatility and principal risks associated with such strategies. In light of these enhanced risks,
client may direct Montis, in writing, not to employ any or all such strategies for his/her/their/its
accounts.
Covered Call Writing.
Covered call writing is the sale of in-, at-, or out-of-the-money call options against a long security
position held in a client portfolio. This type of transaction is intended to generate income. It also serves
to create partial downside protection in the event the security position declines in value. Income is
received from the proceeds of the option sale. Such income may be reduced or lost to the extent it is
determined to buy back the option position before its expiration. There can be no assurance that the
security will not be called away by the option buyer, which will result in the client (option writer) to lose
ownership in the security and incur potential unintended tax consequences. Covered call strategies are
generally better suited for positions with lower price volatility.
Long Put Option Purchases.
Long put option purchases allow the option holder to sell or “put” the underlying security at the contract
strike price at a future date. If the price of the underlying security declines in value, the value of the
long put option can increase in value depending upon the strike price and expiration. Long puts are
often used to hedge a long stock position to protect against downside risk. The security/portfolio could
still experience losses depending on the quantity of the puts bought, strike price and expiration. In the
event that the security is put to the option holder, it will result in the client (option seller) to lose
ownership in the security and to incur potential unintended tax consequences. Options are wasting
assets and expire (usually within months of issuance).
Please Note: There can be no guarantee that an options strategy will achieve its objective or prove
successful. No client is under any obligation to enter into any option transactions. However, if the client
does so, he/she must be prepared to accept the potential for unintended or undesired consequences
(i.e., losing ownership of the security, incurring capital gains taxes). ANY QUESTIONS: Montis’ Chief
Compliance Officer, John Yanchek, remains available to address any questions that a client or
prospective client may have regarding options.
Item 9 Disciplinary Information
Our firm has not been the subject of any disciplinary actions.
Item 10 Other Financial Industry Activities and Affiliations
Neither Montis, nor its representatives, are registered or have an application pending to register, as a
broker-dealer or a registered representative of a broker-dealer.
Neither Montis, nor its representatives, are registered or have an application pending to register, as a
futures commission merchant, commodity pool operator, a commodity trading advisor, or a
representative of the foregoing.
Montis’ employee, Christiane Delessert, is a shareholder of National Advisor Holdings, Inc. ("NAH").
Ms. Delessert owns less than 2.0% of the outstanding stock of NAH. NAH has chartered an institution
through the Office of Thrift Supervision known as National Advisers Trust Company ("NATC"). NATC
provides custody, banking, and trust services to clients of registered investment advisory firms across
the United States, such as Montis. Because Ms. Delessert, has an ownership interest in NAH, and
therefore indirectly has an interest in NATC, a conflict of interest is present because Montis could have
an economic incentive to recommend NATC’s services. Montis may, and does, recommend NATC to
certain clients for custody and trustee services when Montis believes NATC's services may be
appropriate for those clients. No client is under any obligation to use NATC’s services. ANY
QUESTIONS: Montis’ Chief Compliance Officer, John Yanchek, remains available to address
any questions regarding NATC and the corresponding conflict of interest.
Montis does not recommend or select other investment advisors for its clients for which it receives a
fee.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
We maintain a written code of ethics, in accordance with the Advisers Act, that is intended to create an
ethical culture for our firm. Our code of ethics requires our employees to comply with federal securities
laws, safeguard material non-public information and to report their personal securities holdings. Our
code sets forth standards of business conduct required from our employees when dealing with our
clients. Employees are required to treat sensitive information with confidentiality and are forbidden to
misuse any such information. We will provide a copy of our code of ethics upon request.
We typically do not recommend clients purchase securities in which our firm or employees have a
material financial interest. In no event will we recommend or cause you to enter into transactions for
the purpose of benefiting the direct or indirect securities holdings of our personnel.
We and our representatives may buy or sell securities we recommend to you. Our employees may
invest their own funds in mutual funds, variable annuities, individual issues, private placements and
other similar vehicles which we may also recommend to you. Such investments will be made
independently of your investments and will be based upon our employees' own circumstances.
However, returns of our employees' investments could be higher or lower than your returns, given the
differences in circumstances. This practice could create a conflict of interest since we and our
employees are in a position to materially benefit from the sale or purchase of those securities. Abusive
practices, such as "scalping" and "front-running," could take place if we did not have adequate policies
and procedures in place to detect such activities. Scalping is selling a security for a profit immediately
after a recommendation to purchase that security. Front-running is trading personal accounts prior to
trading client accounts. We address these issues with our code of ethics and written compliance
manual for the firm. Our employees must provide their personal securities holdings to the Chief
Compliance Officer which helps address this conflict.
Item 12 Brokerage Practices
In the event that the client requests that Montis recommend a broker-dealer/custodian for execution
and/or custodial services, Montis generally recommends that investment advisory accounts be
maintained at Schwab and/or Fidelity. Prior to engaging Montis to provide investment management
services, the client will be required to enter into a formal Investment Advisory Agreement with Montis
setting forth the terms and conditions under which Montis shall advise on the client's assets, and a
separate custodial/clearing agreement with each designated broker-dealer/custodian.
Factors that Montis considers in recommending Schwab and/or Fidelity (or any other broker-
dealer/custodian to clients) include historical relationship with Montis, financial strength, reputation,
execution capabilities, pricing, research, and service. Although the transaction fees paid by Montis’
clients shall comply with Montis’ duty to obtain best execution, a client may pay a transaction fee that is
higher than another qualified broker-dealer might charge to effect the same transaction where Montis
determines, in good faith, that the transaction fee is reasonable. In seeking best execution, the
determinative factor is not the lowest possible cost, but whether the transaction represents the best
qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the
value of research provided, execution capability, transaction rates, and responsiveness. Accordingly,
although Montis will seek competitive rates, it may not necessarily obtain the lowest possible rates for
client account transactions. Transaction fees charged by the designated broker-dealer/custodian are
exclusive of, and in addition to, Montis’ investment advisory fee.
Research and Benefits: Although not a material consideration when determining whether to
recommend that a client utilize the services of a particular broker-dealer/custodian, Montis can receive
from Schwab and/or Fidelity (or another broker-dealer/custodian, investment manager, platform or fund
sponsor, or vendor) without cost (and/or at a discount) support services and/or products, certain of
which assist Montis to better monitor and service client accounts maintained at such institutions.
Included within the support services that can be obtained by Montis can be investment-related
research, pricing information and market data, software and other technology that provide access to
client account data, compliance and/or practice management-related publications, discounted or gratis
consulting services, discounted and/or gratis attendance at conferences, meetings, and other
educational and/or social events, marketing support-including client events, computer hardware and/or
software and/or other products used by Montis in furtherance of its investment advisory business
operations.
Certain of the above support services and/or products assist Montis in managing and administering
client accounts. Others do not directly provide such assistance, but rather assist Montis and/or its
representatives.
Montis’ clients do not pay more for investment transactions effected and/or assets maintained at
Schwab and/or Fidelity as a result of this arrangement. There is no corresponding commitment made
by Montis to Schwab and/or Fidelity, or any other any entity, to invest any specific amount or
percentage of client assets in any specific mutual funds, securities or other investment products as
result of the above arrangement.
ANY QUESTIONS: Montis’ Chief Compliance Officer, John Yanchek, remains available to
address any questions that a client or prospective client may have regarding the above
arrangements and the corresponding conflict of interest presented by such arrangements.
Montis does not receive referrals from any broker-dealer.
Directed Brokerage. Montis generally recommends that its clients utilize the brokerage and custodial
services provided by Schwab and/or Fidelity. Montis generally does not accept directed brokerage
arrangements (when a client requires that account transactions be effected through a specific broker-
dealer). In such client directed arrangements, the client will negotiate terms and arrangements for their
account with that broker-dealer, and Montis will not seek better execution services or prices from other
broker-dealers or be able to "batch" the client’s transactions for execution through other broker-dealers
with orders for other accounts managed by Montis. As a result, a client may pay higher commissions
or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for
the account than would otherwise be the case. Please Note: In the event that the client directs Montis
to effect securities transactions for the client’s accounts through a specific broker-dealer, the client
correspondingly acknowledges that such direction may cause the accounts to incur higher
commissions or transaction costs than the accounts would otherwise incur had the client determined to
effect account transactions through alternative clearing arrangements that may be available through
Montis. Higher transaction costs adversely impact account performance. Please Also Note:
Transactions for directed accounts will generally be executed following the execution of portfolio
transactions for non-directed accounts.
Order Aggregation. Transactions for each client account generally will be effected independently,
unless Montis decides to purchase or sell the same securities for several clients at approximately the
same time. Montis may (but is not obligated to) combine or “bunch” such orders to obtain best
execution. Should Montis bunch client transactions, such transactions will be averaged as to price and
will be allocated among clients in proportion to the purchase and sale orders placed for each client
account on any given day. Firm shall not receive any additional compensation or remuneration as a
result of such aggregation.
Item 13 Review of Accounts
For those clients to whom Montis provides asset management services, account reviews are
conducted on an ongoing basis by one or more of the Firm’s investment professionals. All asset
management and financial planning clients are advised that it remains their responsibility to
advise Montis of any changes in their investment objectives and/or financial situation. All clients (in
person or telephonically) are encouraged to review financial planning issues, investment objectives
and account performance with Montis on an annual basis, as applicable.
Montis may also conduct account reviews based upon the occurrence of a triggering event, such as a
change in client investment objectives and/or financial situation, market corrections and client request.
Clients are provided, at least quarterly, with summary account statements directly from the broker-
dealer/custodian for the client’s accounts. Montis shall generally also provide a quarterly report
summarizing account activity and performance.
Item 14 Client Referrals and Other Compensation
As indicated at Item 12 above, Montis can receive from Schwab and/or Fidelity (and others) without
cost (and/or at a discount), support services and/or products. Montis’ clients do not pay more for
investment transactions effected and/or assets maintained at Schwab and/or Fidelity (or any other
institution) as result of this arrangement. There is no corresponding commitment made by Montis to
Fidelity, or to any other entity, to invest any specific amount or percentage of client assets in any
specific mutual funds, securities or other investment products as a result of the above arrangements.
ANY QUESTIONS: Montis’ Chief Compliance Officer, John Yanchek, remains available to
address any questions that a client or prospective client may have regarding the above
arrangements and the corresponding conflict of interest presented by such arrangements.
We have entered into a written agreement with SmartAsset Advisors LLC ("SmartAsset") under which
SmartAsset refers potential clients to the us in exchange for a monthly referral fee. We pay referral
fees to SmartAsset regardless of whether you become a client of Montis. The amount of the referral
fees is determined between us and SmartAsset. However, no portion of the referral fees paid to
SmartAsset will be charged to you, and the fees you pay us will not be increased as a result of this
arrangement.
Item 15 Custody
Montis shall have the ability to deduct its advisory fee from the client’s custodial account on a quarterly
basis. Clients are provided with written transaction confirmation notices, and a written summary
account statement directly from the custodian (i.e., Schwab, Fidelity, etc.) at least quarterly. Please
Note: To the extent that Montis provides clients with periodic account statements or reports, the client
is urged to compare any statement or report provided by Montis with the account statements received
from the account custodian. Please Also Note: The account custodian does not verify the accuracy of
Montis’ advisory fee calculation.
Montis engages in other practices and/or services on behalf of its clients that require disclosure at the
Custody section of Part 1 of Form ADV, certain of which practices and/or services are subject to an
annual surprise CPA examination in accordance with the requirements of Rule 206(4)-2 under the
Investment Advisers Act of 1940. In addition, certain clients have established asset transfer
authorizations that permit the qualified custodian to rely upon instructions from Montis to transfer client
funds or securities to third parties. However, in accordance with the guidance provided in the SEC’s
February 21, 2017 Investment Adviser Association No-Action Letter, the affected accounts are not
subject to an annual surprise CPA examination. Custody arrangements are also disclosed at Item 9 of
Part 1 of Montis’ Form ADV. ANY QUESTIONS: Montis’ Chief Compliance Officer, John
Yanchek, remains available to address any questions that a client or prospective client may
have regarding custody-related issues.
Item 16 Investment Discretion
You can engage us to provide asset management services on a discretionary basis. Discretionary
trading authority means placing a trade in your account without your prior approval. You will execute
an agreement with us granting us discretionary trading authority to buy, sell, or otherwise effect
investment transactions involving the assets in your account. Although we may have discretionary
authority, we generally seek (with exceptions) to obtain your approval prior to placing transactions for
your account(s).
You may, at any time, impose restrictions, in writing, on our discretionary authority. For example, you
can limit the types and amounts of particular securities we purchase for your account.
Item 17 Voting Client Securities
We do not vote client proxies. You maintain exclusive responsibility for: (1) directing and voting the
proxies solicited by issuers of securities you own, and (2) making all elections relative to any mergers,
acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to investments in
your accounts. You will receive proxies or other solicitations directly from your account custodian. You
may contact us to discuss any questions you may have with a particular solicitation.
Item 18 Financial Information
We do not solicit fees of more than $1,200, per client, six months or more in advance. We do not have
any financial condition likely to impair us from meeting our contractual commitments to you. We have
not been the subject of a bankruptcy petition.
ANY QUESTIONS:
Montis’ Chief Compliance Officer, John Yanchek, remains available to address any
questions regarding this Part 2A.