A. Main Line Group Wealth Management, LLC ("MLGWM”) is a limited liability company formed on
July 26, 2009, in the State of Pennsylvania. MLGWM is registered with the Commonwealth of
Pennsylvania and the State of New Jersey. Douglas Kobak, CFP® (“Mr. Kobak”) is the managing
member.
MLGWM works with each of its clients to define financial and investment goals and plan, develop,
and design a specific investment program and strategy customized for each client. MLGWM will
supervise and direct, or make recommendations with respect to, the investment of the account(s)
in accordance with the investment objectives of the client. Investments may be made in, but are
not limited to, stocks, bonds, preferred stocks, structured products, mutual funds, ETF’s, private
equity investments, hedge funds, CD’s and money market funds. The firm may use or recommend
sub-account and/or third-party managers.
MLGWM also provides investment management services on a discretionary basis to private
investment funds(s). The private investment fund clients include:
Private Fund (“Funds”) General Partner (“General Partners”)
MLG Venture Partners LP - RS MLG Venture Partners LLC – RS (Delaware LLC)
MLG Venture Partners LP – F3 MLG Venture Partners LLC – F3 (Delaware LLC)
MLGWM, an affiliate of the General Partners, is the investment manager to the Funds and is
responsible for the management of the Funds pursuant to an investment management
agreement. Mr. Kobak is the managing member of MLG Venture Partners LLC – RS and greater
than 50% owner of MLG Venture Partners LLC – F3.
B. As discussed below, MLGWM offers to its clients (individuals, pension and profit-sharing plans,
business entities, trusts, estates and charitable organizations, etc.) investment advisory services,
and, to the extent specifically requested by a client, financial planning, tax planning and related
consulting services.
WEALTH MANAGEMENT SERVICES
A client can determine to engage MLGWM to provide discretionary investment advisory services
on a fee-only basis. Before engaging MLGWM to provide wealth management services, clients
are required to enter into an Investment Advisory Agreement with MLGWM setting forth the
terms and conditions of the engagement (including termination), describing the scope of the
services to be provided, and the fee that is due from the client. MLGWM ’s annual investment
advisory fee is based upon a percentage (%) of the market value of client assets placed under
MLGWM’s management.
MLGWM’s annual investment advisory fee shall 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 MLGWM), MLGWM 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, or
according to the terms and conditions of a stand-alone Financial Planning and Consulting
Agreement as described below.
MLGWM offers wealth management services tailored to the needs of each client. Before
providing wealth management services, an investment adviser representative will ascertain each
client’s investment objectives. Then, MLGWM will allocate and/or recommend that the client
allocate investment assets consistent with the designated investment objectives. Once allocated,
MLGWM provides ongoing monitoring and review of account performance and asset allocation as
compared to client investment objectives and may periodically rebalance and execute
transactions for the account based upon such reviews.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
MLGWM provides financial planning and/or consulting services on a stand-alone separate fee
basis. MLGWM’s financial planning advice includes, among other things, oral advice, written
analyses and reports, and computer generated analyses and reports on the types of investments
which are compatible with the client’s personal investment constraints and objectives, and
personal and family circumstances and obligations; on specific investments and investment
products, including financial assets and real assets; on income taxes and tax planning; on personal
and business insurance; on qualified benefit plans and non-qualified benefit plans; on estate taxes
and estate planning; on personal and business cash flow management and budgeting; the
acquisition and disposition of business interests; and on other personal and business financial
planning and tax issues.
Before engaging MLGWM to provide planning or consulting services, clients are required to enter
into a Financial Planning and Consulting Agreement with MLGWM 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 MLGWM commencing
services. If requested by the client, MLGWM may recommend the services of other professionals
for implementation purposes. The client is under no obligation to engage the services of any such
recommended professional. The client retains absolute discretion over all such implementation
decisions and is free to accept or reject any recommendation from MLGWM.
If the client engages any such recommended professional, and a dispute arises thereafter relative
to such engagement, the client agrees to seek recourse exclusively from and against the engaged
professional. At all times, the engaged licensed professional[s] (i.e., attorney, accountant,
insurance agent, etc.), and not MLGWM, shall be responsible for the quality and competency of
the services provided.
It remains the client’s responsibility to promptly notify MLGWM if there is ever any change in
their financial situation or investment objectives for the purpose of reviewing, evaluating, or
revising MLGWM’s previous recommendations and/or services.
FINANCIAL PLANNING FOR CORPORATE EXECUTIVES
Financial planning is also offered as “packaged” consulting service for corporate executives. Under
this arrangement, a fixed fee for specific consulting projections within specific time parameters is
established. MLGWM’s financial planning and consulting fees are negotiable.
COMPREHENSIVE REPORTING
MLGWM may also provide comprehensive reporting services which can incorporate all of the
client’s investment assets, including those investment assets that are not part of the assets
managed by MLGWM (the “Excluded Assets”). Should the client receive such reporting services,
the client acknowledges and understands that with respect to the Excluded Assets, MLGWM’s
service is limited to reporting services only and does not include investment management, review,
or monitoring services, nor investment recommendations or advice. As such, the client, and not
MLGWM, shall be exclusively responsible for the investment performance of the Excluded Assets.
In the event the client desires that MLGWM provide investment management services with
respect to the Excluded Assets, the client may engage MLGWM to do so for a separate and
additional fee pursuant to the terms and conditions of an Investment Advisory Agreement
between MLGWM and the client.
Miscellaneous
Limitations of Financial Planning and Non-Investment Consulting/ Implementation Services. As
indicated above, to the extent requested by the client, MLGWM will generally provide financial
planning and related consulting services inclusive of its advisory fee, as set forth in Item 5 below
(exceptions may occur based upon assets under management, special projects, etc. for which
MLGWM may charge a separate fee).
MLGWM does not serve as an attorney, accountant or insurance agent, and no portion of our
services should be construed as legal, accounting or insurance services. Accordingly, MLGWM
does not prepare estate planning documents or prepare tax returns. MLGWM or their associated
persons provide insurance related services.
To the extent requested by a client, we may recommend the services of other professionals for
certain non-investment implementation purposes (i.e. attorneys, accountants, insurance, etc.).
The client is under no obligation to engage the services of any such recommended professional.
The client retains absolute discretion over all such implementation decisions and is free to accept
or reject any recommendation from MLGWM and/or its representatives.
If the client engages any unaffiliated 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
MLGWM, shall be responsible for the quality and competency of the services provided.
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 MLGWM
recommends that a client roll over their retirement plan assets into an account to be managed
MLGWM, such a recommendation creates a conflict of interest if MLGWM will earn new (or
increase its current) compensation as a result of the rollover. No client is under any obligation to
rollover retirement plan assets to an account managed by MLGWM.
Unaffiliated Private Investment Funds. MLGWM may provide investment advice regarding
unaffiliated private investment funds. MLGWM, on a non-discretionary basis, may recommend
that certain qualified clients consider an investment in unaffiliated private investment funds.
MLGWM’s role relative to the private investment funds shall be limited to its initial and ongoing
due diligence and investment monitoring services. If a client determines to become a private
fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets
under management” for purposes of MLGWM calculating its investment advisory fee. MLGWM’s
clients are under absolutely no obligation to consider or make an investment in a private
investment fund(s).
Affiliated Private Investment Funds. MLGWM may provide investment advice regarding
affiliated private investment funds. MLGWM, on a non-discretionary basis, may recommend that
certain qualified clients consider an investment in affiliated private investment funds. MLGWM,
an affiliate of the General Partner, is the investment manager to the Fund and is responsible for
the management of the fund pursuant to an investment management agreement. MLGWM’s
clients are under absolutely no obligation to consider or make an investment in a private
investment fund(s).
Valuation. In the event that MLGWM references private investment funds owned by the client on
any supplemental account reports prepared by MLGWM, the value(s) for all private investment
funds owned by the client shall reflect the most recent valuation provided by the fund sponsor.
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, the client’s advisory fee shall be based
upon the value reflected on the report.
Structured Notes. MLGWM may purchase structured notes for client accounts. A structured note
is a financial instrument that combines two elements, a debt security and exposure to an
underlying asset or assets. It is essentially a note, carrying counter party risk of the issuer. However,
the return on the note is linked to the return of an underlying asset or assets (such as the S&P 500
Index or commodities). It is this latter feature that makes structured products unique, as the
payout can be used to provide some degree of principal protection, leveraged returns (but usually
with some cap on the maximum return), and be tailored to a specific market or economic view. In
addition, investors may receive long- term capital gains tax treatment if certain underlying
conditions are met and the note is held for more than one year. In the event that a client has any
questions regarding the purchase of structured notes for their account MLGWM’s Chief
Investment Officer, Mr. Kobak, remains available to address them.
Independent Managers. MLGWM may allocate (and/or recommend that the client allocate) a
portion of a client’s investment assets among unaffiliated independent investment managers
(“Independent Manager(s)”) in accordance with the client’s designated investment objective(s). In
such situations, the Independent Manager(s) will have day-to- day responsibility for the active
discretionary management of the allocated assets according to the terms and conditions of a
separate agreement executed between the client and the Independent Manager(s). MLGWM will
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.
MLGWM generally considers the following factors when recommending Independent Manager(s):
the client’s designated investment objective(s), management style, performance, reputation,
financial strength, reporting, pricing, and research. The investment advisory fees charged by the
designated Independent Manager(s), together with the fees charged by the corresponding
designated broker-dealer/custodian of the client’s assets, are exclusive of, and in addition to,
MLGWM’s ongoing investment advisory fee, which will be disclosed to the client at the point of
entering into the Independent Manager engagement.
Mutual and Exchange Traded Funds: Most mutual funds and exchange traded funds are available
directly to the public. Therefore, a prospective client can obtain many of the funds that may be
utilized by MLGWM independent of engaging MLGWM as an investment advisor. However, if a
prospective client determines to do so, he/she will not receive MLGWM’s initial and ongoing
investment advisory services.
DFA Mutual Funds: MLGWM may utilizes mutual funds issued by Dimensional Fund Advisors
(“DFA”). DFA funds are generally only available through registered investment advisers approved
by DFA. Therefore, if the client was to terminate MLGWM’s 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 Fund Liquidity Constraints. MLGWM may utilize certain mutual funds and/or exchange
traded funds that provide for limited liquidity, generally on a quarterly basis (an “Interval Fund”).
Therefore, if we determined that the Interval Fund was no longer performing or if you ever
determined to transfer your account, the Interval Fund may not be able to be sold or transferred
immediately. Rather, sale or transfer may need to wait until the quarterly permitted sale date, or
longer. Moreover, the eventual net asset value for the Interval Fund could be substantially
different (positive or negative) than the Interval Fund value on the date that the sale was
requested. There can be no assurance that any such strategy will prove profitable or successful. In
light of these enhanced risks/rewards, a client may direct MLGWM, in writing, not to employ any
or all such strategies for the client’s account.
Non-Discretionary Service Limitations. Clients that determine to engage MLGWM on a non-
discretionary investment advisory basis must be willing to accept that MLGWM cannot effect
account transactions without obtaining prior consent to such transaction(s) from the client.
Therefore, in the event that MLGWM would like to make a transaction for a client’s account
(including in the event of an individual holding or general market correction), and the client is
unavailable, MLGWM will be unable to effect the account transaction(s) (as it would for its
discretionary clients) without first obtaining the client’s consent.
Portfolio Activity. MLGWM has a fiduciary duty to provide services consistent with the client’s
best interest. As part of its investment advisory services, MLGWM will review client portfolios on
an ongoing basis to determine if any changes are necessary based upon various factors, including,
but not limited to, investment performance, fund manager tenure, 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 MLGWM determines that changes to a
client’s portfolio are neither necessary nor prudent. Clients are still subject to the fees described
in Item 5 below, even during periods of account inactivity. Clients nonetheless remain subject to
the fees described in Item 5 below during periods of account inactivity.
ByAllAccounts and the MoneyGuidePro® Platform. MLGWM, in conjunction with the services
provided by ByAllAccounts, Inc., or an online platform hosted by “Envestnet Inc.”
(“MoneyGuidePro”) may also provide periodic comprehensive reporting services (See Item 4.A
above) which can incorporate all of the client’s investment assets, including those investment
assets that are not part of the assets managed by MLGWM (the “Excluded Assets”). The client
and/or their other advisors that maintain trading authority, and not MLGWM, shall be exclusively
responsible for the investment performance of the Excluded Assets.
Unless otherwise specifically agreed to, in writing, MLGWM’s service relative to the Excluded
Assets is limited to reporting only. The sole exception to the above shall be if MLGWM is specifically
engaged to monitor and/or allocate the assets within the client’s 401(k) account maintained away
at the custodian directed by the client’s employer. As such, except with respect to the client’s
401(k) account (if applicable), MLGWM does not maintain any trading authority for the Excluded
Assets. Rather, the client and/or the client’s designated other investment professional(s) maintain
supervision, monitoring and trading authority for the Excluded Assets.
If MLGWM is asked to make a recommendation as to any Excluded Assets, the client is under
absolutely no obligation to accept the recommendation, and MLGWM shall not be responsible for
any implementation error (timing, trading, etc.) relative to the Excluded Assets. In the event the
client desires that MLGWM provide investment management services for the Excluded Assets, the
client may engage MLGWM to do so pursuant to the terms and conditions of the Investment
Advisory Agreement between MLGWM and the client.
Client Obligations. In performing our services, MLGWM 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
MLGWM if there is ever any change in their financial situation or investment objectives for the
purpose of reviewing/evaluating/ or revising our previous recommendations and/or services.
Mr. Kobak serves as the Sole Member and of two additional limited liability companies (“LLC”)
one which provides insurance related services and products to businesses and business owners.
The other was created for a specific investment purpose and is expected to be wound down in
2023.
Disclosure Statement. A copy of MLGWM’s written Brochure as set forth on Part 2 of Form ADV
shall be provided to each client prior to, or contemporaneously with, the execution of the
Investment Advisory Agreement or Financial Planning and Consulting Agreement. Any client who
has not received a copy of MLGWM’s written Brochure at least 48 hours prior to executing the
Investment Advisory Agreement or Financial Planning and Consulting Agreement shall have five
business days subsequent to executing the agreement to terminate MLGWM’s services without
penalty.
C. MLGWM shall provide investment advisory services specific to the needs of each client. Prior to
providing investment advisory services, an investment adviser representative will ascertain each
client’s investment objectives. Thereafter, MLGWM shall allocate and/or recommend that the
client allocate investment assets consistent with the designated investment objectives. The client
may, at any time, impose reasonable restrictions, in writing, on MLGWM’s services.
D. MLGWM does not participate in a wrap fee program.
E. As of December 31, 2023, MLGWM managed $102782567 in assets under management on a
discretionary basis, and $0 in a non-discretionary basis.