A. MDFP is a Wisconsin Limited Liability Company formed in June 2002. MDFP has been
registered as an investment adviser with the United States Securities and Exchange
Commission since July 5, 2016. MDFP is principally owned by Michael A. Dubis, who is
MDFP’s Managing Director, and Chief Compliance Officer.
B. MDFP offers combined financial planning and discretionary investment management
services to its clients (generally, individuals and high net worth individuals) as described
below.
INVESTMENT ADVISORY SERVICES
MDFP offers to provide clients with a broad range of financial planning services in
coordination with discretionary investment management services on a fee-only basis. The
specific financial planning services vary depending upon the client’s specific situation, but
commonly focus on such issues as: cash flow planning, retirement planning, education
planning, estate and tax awareness, business influence decisions, and insurance planning.
Before MDFP provides financial planning and/or discretionary investment management
services on a fee-only basis, clients are required to enter into an Agreement with MDFP
setting forth the terms and conditions of the engagement (including termination),
describing the scope of the services, and the fee that is due from the client. MDFP will
then coordinate with each client to develop their financial planning and investment
objectives. MDFP will then prepare the financial plan and recommend that the client
allocate investment assets consistent with the designated financial plan and investment
objectives. MDFP will then offer to implement or assist the client in implementing the
financial plan objectives. Once the financial plan is agreed upon and implemented, MDFP
provides ongoing monitoring and review of asset allocation, financial planning, and
consulting services based upon each client’s individual requests or needs and may execute
account transactions as a result of those reviews or upon other triggering events.
MISCELLANEOUS
Limitations of Financial Planning and Non-Investment Consulting/Implementation Services.
In extremely limited circumstances and only to the extent requested by a client, MDFP
may provide financial planning and related consulting services outside the scope of the
combined financial planning and discretionary investment management engagement
described immediately above. MDFP does not serve as an attorney, accountant, or
insurance agency, and no portion of its services should be construed as legal, accounting,
or insurance brokerage services. Accordingly, MDFP does not prepare estate planning
documents, tax returns, or sell insurance products. Unless specifically agreed in writing,
MDFP is not responsible for implementing any financial planning or consulting advice.
MDFP’s financial planning and consulting services are completed upon communicating its
recommendations to the client, upon providing an agreed-upon written report, or upon
termination of the applicable agreement for ongoing services. To the extent requested by
a client, MDFP may recommend the services of other professionals for certain non-
investment implementation purposes (i.e., attorneys, accountants, insurance agents, etc.).
Clients are under no obligation to engage the services of any recommended professional,
who are responsible for the quality and competency of the services they provide.
Retirement Plan Rollovers – No Obligation / Conflict of Interest. A client or prospective
client leaving an employer 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 MDFP recommends that a client roll over their retirement
plan assets into an account to be managed by MDFP, such a recommendation creates a
conflict of interest if MDFP will earn a new (or increase its current) advisory fee as a
result of the rollover. No client is under any obligation to roll over retirement plan assets
to an account managed by MDFP.
ERISA / IRC Fiduciary Acknowledgment. When MDFP provides investment advice to a
client about the client’s retirement plan account or individual retirement account, it does
so as a fiduciary within the meaning of Title I of the Employee Retirement Income Security
Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws
governing retirement accounts. Because the way MDFP makes money creates some
conflicts with client interests, MDFP operates under a special rule that requires it to act
in the client’s best interest and not put its interests ahead of the client’s. Under this special
rule’s provisions, MDFP must: meet a professional standard of care when making
investment recommendations (give prudent advice); never put its financial interests ahead
of the client’s when making recommendations (give loyal advice); avoid misleading
statements about conflicts of interest, fees, and investments; follow policies and
procedures designed to ensure that MDFP gives advice that is in the client’s best interest;
charge
no more than is reasonable for MDFP’s services; and give the client basic
information about conflicts of interest.
Asset Aggregation / Reporting Services. MDFP may provide access to reporting services
through one or more third-party aggregation / reporting platforms that can reflect all of
the client’s investment assets, including those investment assets that the client has not
engaged MDFP to manage (the “Excluded Assets”). MDFP’s service for the Excluded
Assets is strictly limited to reporting, and specifically excludes investment management or
implementation. Because MDFP does not have trading authority for the Excluded Assets,
the client (or a designated investment professional), and not MDFP, will be exclusively
responsible for directly implementing any recommendations for the Excluded Assets and
the resulting performance or related activity (such as timing and trade errors) pertaining
to the Excluded Assets. The third-party aggregation / reporting platforms may also
provide access to financial planning information and applications, which should not be
construed as services, advice, or recommendations provided by MDFP. Accordingly,
MDFP will not agree to be responsible for any adverse results a client may experience if
the client engages in financial planning or other functions available on the third party
reporting platforms without MDFP’s participation or oversight.
Portfolio Trading Activity / Inactivity. As part of its investment advisory services, MDFP
will review client portfolios on an ongoing basis to determine if any trades are necessary
based upon various factors, including but not limited to investment performance, market
conditions, fund manager tenure, style drift, account additions/withdrawals, the client’s
financial circumstances, and changes in the client’s investment objectives. Based upon
these and other factors, there may be extended periods when MDFP determines that
upon review, trades within a client’s portfolio are not prudent. Clients nonetheless remain
subject to the fees described in Item 5 during periods of portfolio trading inactivity.
Client Obligations. When performing its services, MDFP is not required to verify any
information received from the client or from the client’s designated professionals and is
expressly authorized to rely on that information. Clients are responsible for promptly
notifying MDFP if there is ever any change in their financial situation or investment
objectives for the purpose of reviewing or amending MDFP’s services or previous
recommendations.
Margin Balances. MDFP does not recommend the use of margin for investment purposes.
However, if a client determines to take a margin loan or a securities-based loan that
collateralizes a portion of the assets that MDFP is managing, MDFP’s investment advisory
fee will be computed based upon the full value of the assets, without deducting the amount
of the loan. The client’s use of margin or a securities-based loan presents a conflict of
interest for the MDFP if it gives MDFP the incentive to recommend that the client
continue the use of margin to preserve asset based fees on the value of collateralized
assets. MDFP mitigates that conflict by charging fixed annual fees as described in Item 5.
Cybersecurity Risk. The information technology systems and networks that MDFP and its
third-party service providers use to provide services to MDFP’s clients employ various
controls, which are designed to prevent cybersecurity incidents stemming from
intentional or unintentional actions that could cause significant interruptions in MDFP’s
operations and result in the unauthorized acquisition or use of clients’ confidential or non-
public personal information. Clients and MDFP are nonetheless subject to the risk of
cybersecurity incidents that could ultimately cause them to incur losses, including for
example: financial losses, cost, and reputational damage to respond to regulatory
obligations, other costs associated with corrective measures, and loss from damage or
interruption to systems. Although MDFP has established its systems to reduce the risk of
cybersecurity incidents from coming to fruition, there is no guarantee that these efforts
will always be successful, especially considering that MDFP does not directly control the
cybersecurity measures and policies employed by third-party service providers. Clients
could incur similar adverse consequences resulting from cybersecurity incidents that more
directly affect issuers of securities in which those clients invest, broker-dealers, qualified
custodians, governmental and other regulatory authorities, exchange and other financial
market operators, or other financial institutions.
C. MDFP provides investment advisory services specifically tailored to the needs of each
client. To begin the engagement, MDFP will then coordinate with each client to develop
their financial planning and investment objectives. MDFP will then prepare the financial
plan and recommend that the client allocate investment assets consistent with the
designated financial plan and investment objectives. The client may, at any time, impose
reasonable restrictions in writing to limit MDFP’s services.
D. MDFP does not sponsor a wrap program or offer investment advisory services on a wrap-
fee basis.
E. As of December 31, 2023, MDFP had $228,901,454 in assets under management on a
discretionary basis.