The Money Advisor Group, LLC is a registered investment adviser primarily based in Columbus, GA.
We are organized as a limited liability company ("LLC") under the laws of the State of Georgia. We
have been providing investment advisory services since 07/14/2015. We are primarily owned by Paul
T. Money.
The following paragraphs describe our services and fees. Refer to the description of each investment
advisory service listed below for information on how we tailor our advisory services to your individual
needs. As used in this brochure, the words "TMAG," "we," "our," and "us" refer to The Money Advisor
Group, LLC and the words "you," "your," and "client" refer to you as either a client or prospective client
of our firm.
Services
Portfolio Management Services - Wrap Fee Program
We are a portfolio manager to and sponsor of a wrap fee program (“Program”), which is a type of
investment program that provides clients with access to several asset allocation models for a single fee
that includes administrative fees, management fees, and commissions. If you participate in our wrap
fee program, you will pay our firm a single fee (“Program Fee”), which includes our money
management fees, certain transaction costs, and custodial and administrative costs. We receive a
portion of the wrap fee for our services. The overall cost you will incur if you participate in our wrap fee
program may be higher or lower than you might incur by separately purchasing the types of securities
available in the program.
Assets for program accounts are held at Charles Schwab and Co., Inc. as custodian. Transactions for
your wrap fee and separately managed accounts must be executed by Charles Schwab, a securities
broker-dealer and a member of the Financial Industry Regulatory Authority and the Securities Investor
Protection Corporation. To compare the cost of the wrap fee program with non-wrap fee portfolio
management services, you should consider the frequency of trading activity associated with our
investment strategies and the brokerage commissions charged by other broker-dealers, and the
advisory fees charged by investment advisers.
Effective October 7, 2019, Schwab has eliminated commissions for online trades of U.S. equities,
ETFs and options (subject to $0.65 per contract fee). We encourage you to review Schwab’s pricing to
compare the total costs of entering into a wrap fee arrangement versus a non-wrap arrangement. You
will still incur commissions and fees for certain types of transactions in a non-wrap fee arrangement.
To see what you would pay for transactions in a non-wrap account please refer to Schwab’s most
recent pricing schedules available at www.schwab.com/aspricingguide.
In addition to other types of investments (see disclosures below in this section), we may invest your
assets according to one or more model portfolios developed by our firm. These models are designed
for investors with varying degrees of risk tolerance ranging from a more aggressive investment
strategy to a more conservative investment approach. Clients whose assets are invested in model
portfolios may not set restrictions on the specific holdings or allocations within the model, nor the types
of securities that can be purchased in the model. Nonetheless, clients may impose restrictions
on investing in certain securities or types of securities in their account. In such cases, this may prevent
a client from investing in certain models that are managed by our firm.
As part of our wrap fee management program, we may use one or more sub-advisers to manage a
portion of your account. The sub-adviser(s) may use one or more of their model portfolios to manage
your account. We will regularly monitor the performance of your accounts managed by sub-adviser(s),
and may hire and fire any sub-adviser without your prior approval. You will not pay our firm a higher
advisory fee as a result of any sub-advisory relationships. Advisory fees charged by sub-advisers are
separate and apart from our advisory fees.
IRA Rollover Considerations
As part of our investment advisory services to you, we may recommend that you withdraw the assets
from your employer's retirement plan and roll the assets over to an individual retirement account
("IRA") that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to our
management, we will charge you an asset-based fee as set forth in the agreement you executed with
our firm. This practice presents a conflict of interest because persons providing investment advice on
our behalf have an incentive to recommend a rollover to you for the purpose of generating fee-based
compensation rather than solely based on your needs. You are under no obligation, contractually or
otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no
obligation to have the assets in an IRA managed by our firm.
Many employers permit former employees to keep their retirement assets in their company plan. Also,
current employees can sometimes move assets out of their company plan before they retire or change
jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options
are available, you should consider the costs and benefits of:
1. Leaving the funds in your employer's (former employer's) plan.
2. Moving the funds to a new employer’s retirement plan.
3. Cashing out and taking a taxable distribution from the plan.
4. Rolling the funds into an IRA rollover account.
Each of these options has advantages and disadvantages and before making a change we encourage
you to speak with your CPA and/or tax attorney.
If you are considering rolling over your retirement funds to an IRA for us to manage here are a few
points to consider before you do so:
1. Determine whether the investment options in your employer's retirement plan address your
needs or whether you might want to consider other types of investments.
a. Employer retirement plans generally have a more limited investment menu than IRAs.
b. Employer retirement plans may have unique investment options not available to the
public such as employer securities, or previously closed funds.
2. Your current plan may have lower fees than our fees.
a. If you are interested in investing only in mutual funds, you should understand the cost
structure of the share classes available in your employer's retirement plan and how the
costs of those share classes compare with those available in an IRA.
b. You should understand the various products and services you might take advantage of
at an IRA provider and the potential costs of those products and services.
3. Our strategy may have higher risk than the option(s) provided to you in your plan.
4. Your current plan may also offer financial advice.
5. If you keep your assets titled in a 401(k) or retirement account, you could potentially delay your
required minimum distribution beyond age 70.5.
6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary.
a. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA
assets have been generally protected from creditors in bankruptcies. However, there
can be some exceptions to the general rules so you should consult with an attorney if
you are concerned about protecting your retirement plan assets from creditors.
7. You may be able to take out a loan on your 401(k), but not from an IRA.
8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax
and may also be subject to a 10% early distribution penalty unless they qualify for an exception
such as disability, higher education expenses or the purchase of a home.
9. If you own company stock in your plan, you may be able to liquidate those shares at a lower
capital gains tax rate.
10. Your plan may allow you to hire us as the manager and keep the assets titled in the plan
name.
It is important that you understand the differences between these types of accounts and to decide
whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment
adviser representative, or call our main number as listed on the cover page of this brochure.
Certain financial planning services and/or the use of eMoney may be provided as part of the wrap fee
program at no additional or separate charge to clients with net worth of $2,500,000 or with a minimum
of assets under management of $1,000,000 with our firm. Minimum account sizes may be negotiated
at the firm's sole discretion.
Changes in Your Financial Circumstances
In providing the contracted services, we are not required to verify any information we receive from you
or from your other professionals (e.g., attorney, accountant, etc.) and we are expressly authorized to
rely on the information you provide. Furthermore, unless you indicate to the contrary, we shall assume
that there are no restrictions on our services, other than to manage your account in accordance with
your designated investment objectives. It is your responsibility to promptly notify us if there are any
changes in your financial situation or investment objectives for the purpose of
reviewing/evaluating/revising our previous recommendations and/or services.
Fees
The Program Fee
We charge an annual wrap-fee (“Program Fee”) for participation in the Program depending upon the
market value of your assets under our management. You are not charged separate fees for the
different components of the services provided by the Program. Our firm pays all trade expenses of
trades placed in your account from the Program Fee. Our Program Fee includes the fee we pay to any
portfolio manager for their management of your account and Charles Schwab and Co., Inc.'s
transaction or execution costs. Assets in each of your account(s) are included in the fee assessment
unless specifically identified in writing for exclusion. In special circumstances, and in our sole
discretion, we may negotiate a lesser management fee based upon certain criteria (i.e., anticipated
future earning capacity, dollar amount of assets to be managed, related accounts, account
composition, pre-existing client relationship, account retention, etc.).
Our Program Fee is based on a percentage of assets under management and is set forth in the
following annual fee schedule:
Up to $500,000 1.50%
$500,001 to $1,000,000 1.35%
$1,000,001 to $2,500,000 1.15%
$2,500,001 to $5,000,000 0.90%
$5,000,001 to $10,000,000 0.675%
$10,000,001 and above 0.50%
Our annual Program Fee is billed and payable, quarterly in advance (certain clients may be charged in
arrears), based on the balance at end of billing period.
Depending upon the agreement with each client, Program Fees are payable quarterly, either in
advance or in arrears. If the portfolio management agreement is executed at any time other than the
first day of a calendar quarter, our fees will apply on a pro rata basis, which means that the Program
Fee is payable in proportion to the number of days in the quarter for which you are a client. Our
Program Fee is negotiable, depending on individual client circumstances. We will deduct our fee
directly from your account through the qualified custodian holding your funds and securities. We will
deduct our Program Fee only when you have given our firm written authorization permitting the fees to
be paid directly from your account. Further, the qualified custodian will deliver an account statement to
you at least quarterly. These account statements will show all disbursements from your account.
As a client, you should be aware that the wrap fee charged by our firm may be higher (or lower) than
those charged by others in the industry, and that it may be possible to obtain the same or similar
services from other firms at lower (or higher) rates. A client may be able to obtain some or all of the
types of services available through our firm's wrap fee program on an individual basis through other
firms and, depending on the circumstances, the aggregate of any separately paid fees may be lower or
higher than the annual fees shown above.
At our discretion, we may combine the account values of family members living in the same household
to determine the applicable Program Fee. For example, we may combine account values for you and
your minor children, joint accounts with your spouse, and other types of related accounts. Combining
account values may increase the asset total, which may result in your paying a reduced Program Fee
based on the available breakpoints in our fee schedule stated above.
Because the Program Fee we charge is based on a client’s assets, a client should be aware that the
more assets that are in a client’s retail account, the more the client will pay in Program Fees. This
presents a conflict of interest in that we are incentivized to encourage clients to increase the assets in
their account. We address this conflict of interest by reviewing any such recommendation to ensure it
is in the best interest of the client.
Advisory fees charged by sub-advisers are separate and apart from our advisory fees. Assets
managed by sub-advisers will be included in calculating our advisory fee, which is based on the fee
schedule set forth above. Advisory fees that you pay to the sub-adviser are established and payable in
accordance with the brochure provided by each sub-adviser to whom you are referred. These fees
may or may not be negotiable. You should review the recommended sub-adviser's brochure and take
into consideration the sub-adviser's fees along with our fees to determine the total amount of fees
associated with this program. You may be required to sign an agreement directly with the
recommended sub-adviser(s). You may terminate your advisory relationship with the sub-adviser
according to the terms of your agreement with the sub-adviser. You should review each sub-adviser's
brochure for specific information on how you may terminate your advisory relationship with the sub-
adviser and how you may receive a refund, if applicable. You should contact the sub-adviser directly
for questions regarding your
advisory agreement with the sub-adviser.
Withdrawal of Assets
You may withdraw account assets on notice to our firm, and subject to the usual and customary
securities settlement procedures. However, we design our portfolios as long-term investments and
asset withdrawals may impair the achievement of your specific investment objectives.
Termination of Advisory Relationship
You may terminate the wrap fee program agreement upon 30 days written notice days' written notice to
our firm. You will incur a pro rata charge for services rendered prior to the termination of the wrap fee
program agreement, which means you will incur advisory fees only in proportion to the number of days
in the quarter for which you are a client. If you have pre-paid advisory fees that we have not yet
earned, you will receive a prorated refund of those fees.
Upon termination of accounts held at Charles Schwab and Co., Inc., they will deliver securities and
funds held in the account per your instructions unless you request that the account be liquidated. After
the wrap fee program agreement has been terminated, transactions are processed at the prevailing
brokerage rates/fees. You become responsible for monitoring your own assets and our firm has no
further obligation to act upon or to provide advice with respect to those assets.
Wrap Fee Program Disclosures
• The benefits under a wrap fee program depend, in part, upon the size of the Account, the
management fee charged, and the number of transactions likely to be generated in the
Account. For example, a wrap fee program may not be suitable for Accounts with little trading
activity. In order to evaluate whether a wrap fee program is suitable for you, you should
compare the Program Fee and any other costs of the Program with the amounts that would be
charged by other advisers, broker-dealers, and custodians, for advisory fees, brokerage and
other execution costs, and custodial services comparable to those provided under the Program.
• In considering the investment programs described in this brochure, you should be aware that
participating in a wrap fee program may cost more or less than the cost of purchasing advisory,
brokerage, and custodial services separately from other advisers or broker-dealers.
• Our firm and Associated Persons receive compensation as a result of your participation in the
Program. This compensation may be more than the amount our firm or the Associated Persons
would receive if you paid separately for investment advice, brokerage, and other services.
Accordingly, a conflict of interest exists because our firm and our Associated Persons have a
financial incentive to recommend the Program.
• Similar advisory services may be available from other registered investment advisers for lower
fees.
Additional Fees and Expenses
The Program Fee includes the costs of brokerage commissions for transactions executed through the
Qualified Custodian (or a broker-dealer designated by the Qualified Custodian), and charges relating to
the settlement, clearance, or custody of securities in the Account. The Program Fee does not include
mark-ups and mark-downs, dealer spreads or other costs associated with the purchase or sale of
securities, interest, taxes, or other costs, such as national securities exchange fees, charges for
transactions not executed through the Qualified Custodian, costs associated with exchanging
currencies, wire transfer fees, or other fees required by law or imposed by third parties. The Account
will be responsible for these additional fees and expenses.
The wrap program fees that you pay to our firm for portfolio management services are separate and
distinct from the fees and expenses charged by mutual funds or exchange traded funds (described in
each fund's prospectus) to their shareholders. These fees will generally include a management fee and
other fund expenses. To fully understand the total cost you will incur, you should review all the fees
charged by mutual funds, exchange traded funds, our firm, and others.
We recommend the brokerage and custodial services of Charles Schwab (whether one or more
"Custodian"). Your assets must be maintained in an account at a “qualified custodian,” generally a
broker-dealer or bank. In recognition of the value of the services the Custodian provides, you may pay
higher commissions and/or trading costs than those that may be available elsewhere.
We seek to recommend a custodian/broker that will hold your assets and execute transactions on
terms that are, overall, the most favorable compared to other available providers and their services.
We consider various factors, including:
• Capability to buy and sell securities for your account itself or to facilitate such services.
• The likelihood that your trades will be executed.
• Availability of investment research and tools.
• Overall quality of services.
• Competitiveness of price.
• Reputation, financial strength, and stability.
• Existing relationship with our firm and our other clients.
Economic Benefits Generally
TMAG receives certain economic benefits from Charles Schwab (“Schwab”) as described below in
connection with client securities transactions. TMAG also receives benefits from Matrix Trust Company
(also known as “MG Trust Co.”). We receive a benefit because we do not have to produce or pay for
the research, products, or services. These economic benefits are not considered “soft dollar benefits”
under SEC rules. TMAG clients do not pay more for investment transactions effected and/or assets
maintained at Schwab as a result of this arrangement. There is no corresponding commitment made
by TMAG to Schwab or 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
arrangement. Nevertheless, receipt of the benefits described in this section Schwab creates a conflict
of interest in that we have an incentive to recommend them based on receipt of the benefits, rather
than clients’ interest in receiving the most favorable execution. TMAG manages that conflict of interest
by conducting a best execution analysis to assure that the total costs to the client are reasonable in
relation to the value of the services provided.
Specific Economic Benefits
As a registered investment adviser, we have access to the institutional platform of your account
custodian, including Schwab. As such, we will also have access to research products and services
from your account custodian and/or other brokerage firm. These products may include financial
publications, information about particular companies and industries, research software, and other
products or services that provide lawful and appropriate assistance to our firm in the performance of
our investment decision-making responsibilities. We also receive reporting services from MG Trust
Company. Such products and services are provided to all investment advisers that utilize the
institutional services platforms of these firms, and are not considered to be paid for with soft dollars.
However, you should be aware that the commissions charged by a particular broker for a particular
transaction or set of transactions may be greater than the amounts another broker who did not provide
research services or products might charge.
Schwab - Your Custody and Brokerage Costs
For our clients’ accounts it maintains, Schwab generally does not charge you separately for custody
services but is compensated by charging you commissions or other fees on trades that it executes or
that settle into your Schwab account. These fees are in addition to the commissions or other
compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading
costs, we have Schwab execute most trades for your account.
Schwab Advisor Services
Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business serving
independent investment advisory firms like us. They provide us and our clients with access to its
institutional brokerage – trading, custody, reporting and related services – many of which are not
typically available to Schwab retail customers. Schwab also makes available various support services.
Some of those services help us manage or administer our clients’ accounts while others help us
manage and grow our business.
Services that Benefit You
Schwab’s institutional brokerage services include access to a broad range of investment products,
execution of securities transactions, and custody of client assets. The investment products available
through Schwab include some to which we might not otherwise have access or that would require a
significantly higher minimum initial investment by our clients. Schwab’s services described in this
paragraph generally benefit you and your account.
Services that May Not Directly Benefit You
Schwab also makes available to us other products and services that benefit us but may not directly
benefit you or your account. These products and services assist us in managing and administering our
clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We
may use this research to service all or some substantial number of our clients’ accounts, including
accounts not maintained at Schwab. In addition to investment research, Schwab also makes available
software and other technology that:
• provide access to client account data (such as duplicate trade confirmations and account
statements);
• facilitate trade execution and allocate aggregated trade orders for multiple client accounts;
• provide pricing and other market data;
• facilitate payment of our fees from our clients’ accounts; and
• assist with back-office functions, recordkeeping and client reporting.
Services that Generally Benefit Only Us
Schwab also offers other services intended to help us manage and further develop our business
enterprise. These services include:
• educational conferences and events;
• technology, compliance, legal, and business consulting;
• publications and conferences on practice management and business succession;
• access to employee benefits providers, human capital consultants and insurance providers;
• marketing consulting and support.
Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors
to provide the services to us. Schwab may also discount or waive its fees for some of these services or
pay all or a part of a third party’s fees. Schwab may also provide us with other benefits such as
occasional business entertainment of our personnel.
Our Interest in Schwab’s Services
The availability of these services from Schwab benefits us because we do not have to produce or
purchase them. We don’t have to pay for Schwab’s services so long as we keep a total of at least $10
million of client assets in accounts at Schwab. Beyond that, these services are not contingent upon us
committing any specific amount of business to Schwab in trading commissions or assets in custody.
The $10 million minimum may give us an incentive to recommend that you maintain your account with
Schwab based on our interest in receiving Schwab’s services that benefit our business rather than
based on your interest in receiving the best value in custody services and the most favorable execution
of your transactions. This is a potential conflict of interest. We believe, however, that our selection of
Schwab as custodian and broker is in the best interests of our clients. It is primarily supported by the
scope, quality and price of Schwab’s services (based on the factors discussed above – see “The
Custodian and Broker We Use”) and not Schwab’s services that benefit only us. We do not believe
that maintaining at least $10 million of assets under management at Schwab in order to avoid paying
Schwab quarterly service fees presents a material conflict of interest.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers in exchange for cash or other compensation,
such as brokerage services or research.
Directed Brokerage
We routinely require that you direct our firm to execute transactions through Charles Schwab. As such,
we may be unable to achieve the most favorable execution of your transactions and you may pay
higher brokerage commissions than you might otherwise pay through another broker-dealer that offers
the same types of services. Not all advisers require their clients to direct brokerage.
Block Trades
For discretionary accounts, we sometimes but not always, engage in block trading. We may combine
multiple orders for shares of the same securities purchased for discretionary advisory accounts we
manage (this practice is commonly referred to as "block trading"). We will then distribute a portion of
the shares to participating accounts in a fair and equitable manner. Generally, non-wrap accounts will
pay a fixed transaction cost regardless of the number of shares transacted. In certain cases, each
participating account pays an average price per share for all transactions and pays a proportionate
share of all transaction costs on any given day. If you participate in our wrap fee program described
above, you will not pay any portion of the transaction costs in addition to the program fee. In the event
an order is only partially filled, the shares will be allocated to participating accounts in a fair and
equitable manner, typically in proportion to the size of each client’s order. Accounts owned by our firm
or persons associated with our firm may participate in block trading with your accounts; however, they
will not be given preferential treatment.
We do not block trade for non-discretionary accounts. Accordingly, non-discretionary accounts may
pay different costs than discretionary accounts pay. If you enter into non-discretionary arrangements
with our firm, we may not be able to buy and sell the same quantities of securities for you and you may
pay higher commissions, fees, and/or transaction costs than clients who enter into discretionary
arrangements with our firm.