About Mariner Platform Solutions
Mariner Platform Solutions, LLC (the “Firm,” “we,” or “us”) is an investment adviser registered
with the SEC. We are a limited liability company organized under the laws of Delaware. We are
wholly owned by Mariner Advisor Network, LLC (referred to herein as the “Network”). The
Network is wholly owned by Mariner Wealth Advisors, LLC (referred to herein as “Mariner”).
MWA Midco, LLC (“Midco”) is the manager of Mariner. MWA Holdco, LLC (“Holdco”) is the
manager of Midco. Holdco is owned by 1248 Holdings, LLC ( “1248”), the Martin C. Bicknell
Revocable Trust dated August 7, 1996, as amended and restated, and GEI VIII MW Aggregator
LLC (“MW Aggregator”). We are headquartered in Overland Park, Kansas.
The Firm provides advisory services through its Investment Adviser Representatives (“IARs”).
IARs are independent contractors of the Firm. IARs of the Firm generally have their own business
entities with trade names, logos, and websites that they use in marketing the services they provide
through the Firm. Such business entities are generally owned by one or more IARs of the Firm,
not the Firm itself. The names of these business entities are set out in the Firm’s Form ADV Part
1. Clients should understand that the businesses are generally legal entities of the IAR and not of
the Firm or the custodian. Additionally, the business entities owned by the IAR may provide
services other than investment advice. IARs may choose to use AdvicePeriod, a d/b/a of the Firm
instead of setting up their own business entity. In this case, the IARs are not owners of
AdvicePeriod. All IARs are under the supervision of the Firm and the advisory services of the IAR
are provided through the Firm.
The Firm will maintain the direct contractual relationship with each client and obtain, through such
agreements, the authority to engage independent third-party managers or other service providers,
as applicable, for services rendered through the platform in service of such client.
Investment Advisory Services
Through the Firm, IARs provide personal financial planning, reporting, consulting, and investment
advisory services to individuals, pension and profit-sharing plans, trusts, estates, charitable
organizations, corporations and business entities. IARs employ a variety of investment strategies
when working with clients to construct a client’s portfolio. Investment management and advisory
services are generally offered for a fee based on assets under management or advisement as further
described in the agreement with the client. In certain cases, IARs provide financial planning,
reporting and/or consulting services for an additional fee, which can be based on a percentage of
assets or a flat or hourly rate.
Typically, when providing investment advisory services, we have full discretion to select securities
to buy and sell for a client’s account. However, from time-to-time clients impose reasonable
restrictions, limitations or other requirements with respect to their individual accounts. IARs work
with each client in order to tailor their accounts to address their specific goals, objectives and
constraints. IARs consider a range of factors that can impact the investment management process,
including risk tolerance, investment time horizon, current and future cash needs and such other
circumstances deemed relevant.
For clients of IARs utilizing model portfolios provided by the Firm, the Firm constructs investment
models using an appropriate mix of mutual funds or exchange traded funds, with asset allocation
determined based on the risk level of each respective model. The IAR works with the client to
understand the client’s objectives, goals, risk tolerance, constraints and other relevant criteria, and
will select the appropriate model(s) based upon this review. The Firm is supported by the
investment resources of its affiliate, Mariner, LLC (“Mariner Wealth”). This includes access to
equity models, options, structured notes and fixed income strategies. Additionally, IARs have
access to models developed and managed by other third-party investment managers for use in
client accounts.
IARs of the Firm can utilize Portfolio Consulting (“PC”) services, which is a separate offering
consisting of portfolio design, investment consulting, trade execution, and portfolio re-balancing
services. The PC Team can access client accounts through an advisor’s existing custodian as well
as provide sub-advisory services through a separate custodial relationship. In addition, the PC team
has established a relationship to provide these services through Orion Technologies via their
“Communities” platform. IARs are under no obligation to utilize PC services. Clients whose IARs
utilize PC services are not charged a separate fee for such services. IARs pay for the services of
PC themselves as a business expense.
Alternatively, certain IARs of the Firm who determine not to utilize the models developed by the
Firm will instead create a customized portfolio management program geared toward the client’s
specific investment goals, in a discretionary fashion. In this scenario, the IAR acts as the client’s
portfolio manager and is responsible for investment oversight and due diligence, allocation
decisions, rebalancing and risk management, without the structure provided by the Firm’s
investment models. Utilizing information obtained regarding the client’s objectives, goals, risk
tolerance, constraints and other relevant criteria, the IAR will determine the specific investments
to utilize in a client’s portfolio.
We also provide our clients with access to third-party managers (each a “third-party manager”),
including managers in which Mariner or a related entity holds an ownership stake as well as
managers of private funds that are affiliated with, but operationally independent of, the Firm. This
service provides clients access to a wide range of investment opportunities and asset classes,
including international equities, emerging market equities, global fixed income, high-yield fixed
income, private equity, commodities, hedge funds, digital assets, structured notes and real assets.
By combining third-party managers with our in-house resources, we seek to optimize our
customized portfolio management capabilities for clients. Unless otherwise set forth in the third-
party manager’s agreement, the third-party manager shall have discretionary authority for the day-
to-day management of the assets that are allocated to it by the Firm or the client. The third-party
manager shall continue in such capacity until such arrangement is terminated or modified by the
Firm. For certain accounts, the Firm utilizes private funds (including through access to a platform
which provides access to various alternative investments), third-party providers of unified
managed accounts, separately managed accounts and model programs to access third-party money
managers.
AssetMark Platform
The Firm may offer advisory services to Clients by selecting the AssetMark Platform. For more
information regarding the AssetMark Platform, refer to AssetMark Platform Disclosure Brochure.
The minimum investment required on the AssetMark Platform depends upon the Investment
Solution chosen for a Client’s account and is generally $10,000 for Mutual Fund and $25,000 for
ETF Accounts and from $25,000 to $1,000,000 for Privately Managed and Unified Managed
Accounts, depending on the investment strategy selected for the account. These minimums are
described in more detail in the Fees & Minimums Page in the AssetMark Platform Disclosure
Brochure. Accounts below the stated minimums may be accepted on an individual basis at the
discretion of AssetMark.
Sub-Advisory Agreement with SEI Investment Management Corporation
We have a Sub-Advisor Agreement with SEI Investments Management Corporation (“SIMC”), a
registered investment advisor affiliated with SEI Private Trust Company (“SPTC”). This
agreement allows us to allocate client assets for participation in SIMC’s Sub-Advised Program.
We are responsible to determine whether participation in the program is appropriate for our clients.
Under the program, SIMC provides discretionary investment management services to us and
makes available investment strategy models of SIMC, or investment managers appointed by
SIMC. These models seek to achieve particular investment goals and are not tailored to individual
clients. We may allocate client assets to one or more of SIMC’s models which match a client’s
objectives. SIMC then invests the allocated funds in accordance with the selected models as
updated from time to time by SIMC or investment managers appointed by SIMC. In most cases,
SIMC will implement those models and execute transactions; in others, the investment manager
will do so.
SIMC charges us an investment management fee for participation in the program. We have
instructed SPTC to operationally facilitate the deduction of the investment management fees direct
from our clients’ accounts held at SPTC.
Clients with assets allocated to the program are subject to certain risks, including the investment
manager implementing its model for its other accounts before implementing it for our clients. In
that case, securities may be traded by our clients at prices different than those obtained by the
manager’s other clients. The risk of price deviations is greater for large orders and thinly traded
securities. Additional performance of our client’s investments in a model may deviate from the
performance of other accounts in such models or those managed by SIMC or the investment
manager.
We may also invest client assets into model portfolios of mutual funds and exchanged-traded funds
created by SIMC. This includes the SEI Asset Allocation Models that consist of allocations to SEI
Funds and SEI ETFs and the Independent Funds Models Program which consists of model
portfolios of allocations to certain families of third-party mutual funds or ETFs. We have a Sub-
Advisor Agreement with SEI Investments Management Corporation (“SIMC”), a registered
investment advisor affiliated with SEI Private Trust Company (“SPTC”). This agreement allows
us to allocate client assets for participation in SIMC’s Sub-Advised Program. We are responsible
to determine whether participation in the program is appropriate for our clients.
Participant Account Management
We use a third-party platform to facilitate management of held away assets such as defined
contribution plan participant accounts, with discretion. The platform allows us to avoid being
considered to have custody of client funds since we do not have direct access to client log-in
credentials to affect trades. We are not affiliated with the platform in any way and receive no
compensation from them for using their platform. A link will be provided to the client allowing
them to connect an account(s) to the platform. Once client account(s) is connected to the platform,
we will review the current account allocations. When deemed necessary, we will rebalance the
account considering client investment goals and risk tolerance, and any change in allocations will
consider current economic and market trends. The goal is to improve account performance over
time, minimize loss during difficult markets, and manage internal fees that harm account
performance. Client account(s) will be reviewed at least quarterly and allocation changes will be
made as deemed necessary.
Financial Planning and Consulting
To the extent specifically requested by a client, IARs of the Firm will provide financial planning
and/or consulting services (including investment and non-investment related matters, such as
estate planning, insurance planning, education savings, tax consulting and preparation, etc.). The
Firm may charge an additional fee for such services depending on the level of service provided
and other considerations deemed relevant by IARs in their sole discretion. IARs of the Firm are
also able to provide financial planning and consulting services on a stand-alone basis. Prior to
engaging the Firm to provide these services and to the extent a client has not entered into an
investment advisory agreement (also referred to as an investment management agreement) with
the Firm, clients are generally required to enter into a Financial Planning or Consulting Agreement
with the Firm setting forth the terms and conditions of the engagement (including termination),
describing the scope of the services to be provided, and the portion of the fee that is due from the
client prior to the Firm commencing services if applicable.
Please Note: While certain IARs and associates of the Firm are licensed attorneys, they do not
provide legal services to the Firm’s clients through the Firm and no attorney-client relationships
exist. IAR’s are required to report such activity as an Outside Business Activity and are supervised
accordingly.
Tax Compliance, Planning, Preparation and Consulting
To the extent specifically requested by a client, IARs are able to provide coordinated tax
compliance, planning, preparation, and consulting services (collectively referred to as “tax
services”) to investment advisory clients as an integrated part of our investment advisory services,
including through the use of the Mariner Wealth tax team. Certain IARs also provide tax services
on a stand-alone basis, pursuant to a separate tax engagement agreement, to individuals,
businesses, and family offices. Although the Firm is a registered investment adviser under the
Investment Advisers Act of 1940 (“Advisers Act”), the Firm and Mariner Wealth are not serving
in a fiduciary capacity in the provision of stand-alone tax services and will not provide ongoing
investment advisory services with respect to stand-alone tax clients’ assets or accounts. For clients
who receive separate tax services, IARs may recommend the Firm be retained as their investment
adviser pursuant to a separate investment advisory agreement; however, such clients are under no
obligation to do so. IARs may also recommend the services of other, non-affiliated professionals
to provide tax services. Our clients are under no obligation to engage the services of any such
recommended professional. It is solely up to our clients as to whether they accept or reject any
recommendation made by an IAR.
Please Note:
Our clients agree that, if any dispute arises between our client and any other professional
recommended by an IAR and/or the Firm, they will seek recourse exclusively from and against the
engaged qualified professional.
While certain investment adviser representatives of the Firm are licensed CPAs or EAs, they are
not responsible for providing tax services unless the client’s Agreement specifically sets forth that
such tax services will be provided. The Firm typically charges an additional or separate fee for tax
services.
Retirement Plan Consulting and Management Services
IARs of the Firm provide consulting and advisory services for employer-sponsored retirement
plans that are designed to assist plan sponsors of employee benefit plans. Generally, such
retirement plan consulting and advisory services consist of managing or otherwise advising
sponsors in establishing, selecting, monitoring, removing and/or replacing the investment options
under the plan, consistent with the objectives, written guidelines and/or investment objectives set
forth in the written investment policy statement adopted by the plan sponsor. As the needs of the
plan sponsor dictate, the Firm
offers the following areas of management or advisement: plan
investment options, asset allocation, plan structure, participant education, and managing model
portfolios. When providing consulting and/or management services to plan sponsors of employee
benefit plans, plan participants should not assume that general informational materials or
educational sessions devised and/or provided by the Firm on behalf of the plan serves as the receipt
of, or as a substitute for, personalized investment advice from the Firm, or from any other
investment professional. To the extent that any participant requires initial or ongoing personalized
investment advice, he/she is encouraged to consult with the investment professional of his/her
choosing.
In addition to the services described above, IARs of the Firm may also provide discretionary
advisory services to client accounts that are governed by the Employment Retirement Income
Security Act of 1974, as amended (“ERISA”).
All retirement plan investment advisory services shall be in compliance with the applicable state
law(s) regulating retirement plan advisory services. This applies to client accounts that are plans
governed by ERISA. If the client accounts are part of the plan, and we accept appointments to
provide our services to such accounts, we acknowledge that we are a fiduciary within the meaning
of section 3(21) of ERISA (but only with respect to the provision of services described in the
applicable agreement). We emphasize continuous and regular account supervision. Once the
appropriate plan investments have been determined, we review the plan investments at least
annually and if necessary, provide advice to or otherwise add, replace or remove investment
options based upon the plan sponsor’s objectives, written guidelines and/or investment objectives.
In certain cases, if deemed appropriate for a client, IARs will refer Plans to utilize the services of
the Firm’s affiliate, Mariner Institutional, for management.
Our Fiduciary Acknowledgement
When we provide investment advice to you regarding your retirement plan account or IRA, we are
fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act
(“ERISA”) and/or Section 4975 of the Internal Revenue Code (the “Code”), as applicable, which
are laws governing retirement accounts. The way we make money creates some conflicts with your
interests, so we operate under a special rule that requires us to act in your best interest and not put
our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give
prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
For purposes of this special rule, covered “plans” include 401(k), 403(b), profit-sharing, pension
and all other plans that are subject to ERISA, together with tax-qualified retirement plans under
the Code (even if not subject to ERISA) such as Solo 401(k) and “Keogh” plans. “IRAs” subject
to the special rule include both traditional and Roth IRAs, individual retirement annuities, health
savings accounts, Archer medical savings accounts and Coverdell education savings accounts.
Our Material Conflicts of Interest
Our material conflicts of interest are described in this brochure.
Investment advisory, financial planning, tax and/or retirement service recommendations as
described above may pose a conflict between the interests of the Firm and the interests of clients.
For example, a recommendation to engage the Firm for investment advisory services or to increase
the level of investment assets with the Firm, including through rollovers or other transfers of
retirement plan accounts or IRAs, would pose a conflict, as it would increase the advisory fees
paid to the Firm. Clients are not obligated to implement any recommendations made by the Firm
or maintain an ongoing relationship with the Firm. If a client elects to act on any of the
recommendations made by the Firm, the client is under no obligation to execute the transaction
through the Firm.
In addition, please note the following:
Advisory Services (the Firm) vs. Brokerage Services. In most cases, the total compensation that
our Firm receives (consisting primarily of advisory fees) for providing investment advisory
services is more than a brokerage firm may receive (consisting primarily of commissions and other
transaction-based payments, including trail compensation) for providing brokerage services. Also,
the advisory fees you would pay to us in an investment advisory account do not decrease even
where the level of investment trading activity in your advisory account is low. IARs receive a
percentage share of the fees they generate.
While we are not prohibited from doing so, if you are an investment advisory client of the Firm,
in most cases we do not expect to recommend that you roll over plan accounts or IRAs into
brokerage IRAs serviced by a brokerage firm, because we generally intend to manage these
accounts on an integrated basis together with your other advisory accounts, and those of your
household (if applicable).
Rollovers and Account Type Changes
Regardless of the investments and services you select, the Firm will make more money if you roll
over assets from a retirement plan or IRA for which we do not provide services, to a retirement
plan or IRA for which we do provide services, whether the rollover is from (1) a plan to an IRA,
(2), an IRA to an IRA, (3) a plan to another plan, or (4) an IRA to a plan (as those terms are
described above). As noted above, IARs are compensated based on the total client fees they
generate for the Firm. Therefore, both our Firm and our individual wealth advisors have financial
incentives to recommend plans and/or IRA rollovers to plans and IRAs serviced by us. You are
under no obligation, contractually or otherwise, to complete the rollover. Furthermore, if you do
complete the rollover, you are under no obligation to have the assets in an IRA managed by us.
Closed-end Funds, Exchange Traded Funds (ETFs) and Mutual Fund Portfolios
IARs of the Firm provide advice to client accounts that include as part of the overall client
allocation portfolios of closed-end funds, ETFs and mutual funds.
Managed Accounts – Equity Portfolios
We also offer our clients a variety of equity strategies through separate accounts, including through
a subadvisory relationship with Mariner Wealth. These strategies offer clients access to actively
managed equity strategies. The Firm generally imposes account minimums when offering
managed accounts to clients, ranging from $100,000 to $250,000 depending on the strategy, which
may be adjusted depending on the level of service provided to the client, the investment strategy
employed by the account and other considerations deemed relevant by the Firm in its sole
discretion. The equity strategies vary by mandate, generally with a focus on capital appreciation
as a primary objective. Philosophies include dividend-based strategies, GARP (growth at a
reasonable price), socially conscious and personalized equity portfolios. Mariner Wealth will
recommend individual securities based upon fundamental analysis performed by its research
investment professionals. Mariner Wealth relies primarily on publicly available information in its
analysis, supplemented by third-party research and analytical tools.
Managed Accounts – Fixed Income Portfolios
We also offer our clients a variety of actively managed fixed income strategies, including through
a subadvisory relationship with Mariner Wealth The Firm generally imposes account minimums
when offering managed accounts to clients of $250,000, which may be adjusted depending on the
level of service provided to the client, the investment strategy employed by the account and other
considerations deemed relevant by the Firm in its sole discretion. With respect to Mariner Wealth’s
fixed income strategies, the primary objective is capital preservation. Secondary objectives include
providing a steady, tax-efficient revenue stream and the potential for capital appreciation. Mariner
Wealth’s investment fixed income strategies are formed through a combined top-down and
bottom-up perspective. From the top-down, Mariner Wealth develops its economic outlook and
interest rate strategy using macroeconomic and market data and trends. Mariner Wealth will alter
its duration, sector, and yield curve exposure targets based on this outlook.
Options Strategies
We also offer our clients a variety of options strategies, including through a subadvisory
relationship with Mariner Wealth. These strategies are generally designed to provide clients with
income that is uncorrelated to the performance of their underlying investments held as collateral.
Alternatively, the options strategies may be used to enhance the returns of an underlying
concentrated position or to protect the downside of an equity or an index.
Structured Notes Strategies
We offer our clients structured notes strategies, including through a subadvisory relationship with
Mariner Wealth. These strategies are generally designed to provide clients with an alternative
risk/reward payoff compared to owning the same asset directly. The structured notes objectives
are to offer capital appreciation to equity indices and varying levels of downside protection to the
index. They may also be used to provide income or principal protection.
Alternative Strategies
Our alternative and private fund strategies focus on generating absolute, risk-adjusted returns that
are intended to have lower correlation to the broad equity market. As a result, clients must
affirmatively subscribe for any such investment.
Robo-Advisory Program
For some clients, our wealth advisors may recommend a web-based electronic investment advisory
program operated and provided by Betterment LLC, a third-party investment adviser
(“Betterment”). Under this arrangement, clients access Betterment exclusively through their
website. Clients provide Betterment with their risk tolerance, financial circumstances and other
information and their portfolio is created with asset allocations in exchange-traded funds (ETFs)
that match tolerance levels and goals. Betterment then provides investment advice to the client and
directs trades to its affiliated broker-dealer, Betterment Securities. In addition to the advisory fee
a client agrees to pay the Firm, clients pay Betterment a fee that covers the investment advice,
execution, and custody of the client’s account in the Betterment Program (the “Program”).
Clients should understand that with Robo-Advisory Services:
• Advice provided by Betterment is computer-generated, and therefore inherently has several
limitations including, but not limited to, the following: (i) neither the Firm nor Betterment
can ensure that the Program can achieve any particular tax result for any client or that the
mathematical algorithms employed are designed properly, updated with new data, and can
accurately predict future security, market, industry, and sector performance; (ii) the
algorithm may rebalance Program accounts without regard to the then-current market
conditions or on a more frequent basis than the client might otherwise expect; and (iii) the
algorithm may not address prolonged market condition changes.
• We will be unable to manage your Program account in a way we may otherwise advise for
advisory accounts we manage. Betterment can amend the terms of the client’s agreement
at any time upon notice to the client. A client’s participation in the web-based electronic
investment advisory program is subject to numerous conditions (as noted on the website);
Clients must agree to arbitration of any disputes they may have with Betterment; and
• Betterment fees are billed in arrears while the Firm bills primarily in advance.
Annuity Products
Clients may grant the Firm discretion to: (a) select investment strategy allocations for clients’
existing or new annuity products; and (b) allocate among the investment strategy allocations
available from the specific annuity sponsor (collectively (a) and (b) are referred to as the “Annuity
Allocation Services”). In performing Annuity Allocation Services, the Firm will only consider the
options available within the specific annuity purchased by the client. If an annuity was purchased
with retirement account assets, client agrees that the Firm did not exercise discretionary control
with respect to the purchase of the annuity. Any changes in a client’s annuity investments (re-
allocations among investment strategy allocations) are subject to the terms and conditions imposed
by the applicable annuity sponsor. The assets invested in any annuity product for which the Firm
is providing Annuity Allocation Services are included in the total assets on which the Firm’s
advisory fee is calculated. The Firm’s advisory fee is separate from, and in addition to, the
management fees and expenses charged on a continuing basis by the annuity sponsor, insurance
company, and/or associated investment manager. Annuities have inherent risks, will fluctuate in
value, incur losses based on the performance of selected investments or investment strategy
allocations, are suitable only as long-term investments, and should not be viewed as short-term
trading vehicles. Clients should carefully review the prospectus and other offering documents for
more information on annuities.
If deemed appropriate for a client, our IARs recommend clients utilize fee-based variable
annuities, including through a third-party provider of a platform of insurance consultation services.
Fee-based variable annuities are not assessed transaction fees since the reallocation of transactions
are placed directly with the variable annuity sponsor. Clients are encouraged to review the variable
annuity prospectus prior to investing.
Other Businesses and Investment Programs
The Firm and our affiliates also offer to our clients a variety of services, including estate and trust
services, and risk management. The Firm earns fees for the services provided by it, and its affiliates
will likewise earn fees directly for services they provide. Please see Item 10 for more information
on the services provided by our affiliates.
Client Agreement
Prior to engaging an IAR of the Firm, the client will be required to enter into one or more written
agreements setting forth the terms, conditions, and objectives under which we shall render our
services (the “Agreement”). Additionally, we will only implement our investment
recommendations after a client has arranged for and furnished all information and authorization
regarding accounts with appropriate financial institutions. Clients are advised to promptly notify
their IAR if there are ever any changes in their financial situation or investment objectives.
Our total assets under management are approximately $4,345,628,317 with $3,902,499,654
managed on a discretionary basis and $443,128,672 managed on a non-discretionary basis as of
December 31, 2023.