Midway Wealth Partners, LLC (“MWP” or the “Firm”) was established in 2022 and applied for
registration as an Registered Investment Adviser in 2022. Richard S. Babjak, Todd Rollins, and Dennis P.
Ryan are the principal owners of MWP.
In addition to the programs described in this brochure, MWP also offers a wrap fee program, which is
disclosed in separate Wrap Fee Brochure. In a wrap fee program, clients are charged an all-inclusive
wrap fee on Program Assets that covers advisory, execution, custodial and reporting services on Eligible
Assets. A portion of these fees will be paid to MWP for advisory services. In a non-wrap fee program,
MWP’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and
expenses which shall be incurred by the client. Clients could incur certain charges imposed by
custodians, brokers, third party investment and other third parties such as fees charged by managers,
custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic
fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and
exchange traded funds also charge internal management fees, which are disclosed in the fund’s
prospectus. Such charges, fees and commissions are exclusive of and in addition to MWP’s fee, and
MWP shall not receive any portion of these commissions, fees, and costs.
MWP provides advisory services, giving continuous advice based on the client’s individual needs.
Through personal discussions in which goals and objectives based upon the client’s personal objectives
are established, the Firm will develop a personal investment policy based upon an investment objective
questionnaire and manage the portfolio according to the criteria.
Our advisory process starts with a conversation with a prospective client in order to fully understand
their goals. When making your investment plan, the client’s goals are considered, including where they
currently are, and where they want to be in the future. A plan is crafted around these goals, their risk
tolerance, and their other financial needs. The investment plan is made by looking at the client
holistically. Once the client is satisfied with their plan, it is implemented, monitored, and adjusted as
needed.
Crystal Capital Partners
Through a relationship with Crystal Capital Partners, LLC (“Crystal”) MWP may provide qualified clients
with customized hedge fund portfolios. Crystal specializes in building customized hedge fund portfolios
that help complement the existing holdings of client investments. Through Crystal’s services, clients will
have access to high level hedge fund managers, detailed analytics, reporting and due diligence that is
typically only available to the largest institutions. Most customized accounts will be invested with
investment managers or investment funds through a series fund organized by Crystal. The
investment managers and investment funds that are recommended will be selected from a list that has
been developed by Crystal, based on its quantitative and qualitative research of the managers and funds.
After the client approves the customized portfolio that is recommended, the client will invest in a series
or portfolio of Crystal Capital Fund Series, LLC (the “Crystal Fund”), that is managed by Crystal. The Crystal
Fund is a private investment fund that has several segregated portfolios. Each portfolio is a separate pool
of assets constituting a separate fund with its own investment objectives and policies.
This program is only available to
Accredited Investors as defined by the SEC in Rule 501 of Regulation D.
There are a variety of ways individuals or entities can qualify as Accredited Investors, but they are
typically individuals with net worth over $1 million (excluding primary residence; or having income over
$200,000 (individually) or $300,000 (with spouse or partner) in each of the prior two years, with a
reasonable expectation of the same for the current year.
IRAs and other ERISA Covered Accounts
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries 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. 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.
Restrictions imposed by clients
Each client has the ability to impose reasonable restrictions on the management of his/her account,
including the designation of particular securities or types of securities that should not be purchased for
the account, or that should be sold if held in the account. If a client’s instructions are unreasonable or an
Investment Advisor Representative believes that the instructions are inappropriate for the client, MWP
will notify the client that, unless the instructions are modified, it will cancel the instructions in the
client’s account. A client will not be able to provide instructions that prohibit or restrict the Investment
Adviser of an open-end or closed-end mutual fund or ETF with respect to the purchase or sale of specific
securities or types of securities within the fund.
Retirement Planning
The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which Plan
Fiduciaries may retain investment advisers for various types of services with respect to Plan assets. MWP
acts as a fiduciary under ERISA Section 3(38). Retirement Planning Services are comprised one or more
of the following services:
Investment Policy Statement Preparation - MWP will meet with the client (in person or over the
telephone) to assess the client’s investment needs and goals. MWP will then prepare a written
Investment Policy Statement (IPS) stating those needs and goals and creating a policy to help achieve
these goals. The IPS will also list the criteria for selection of investment vehicles and the procedures
and timing interval for monitoring of investment performance.
Selection of Investments - MWP will review various investments, consisting of one or all of the
following: individual equities, bonds, other investment products and mutual funds (both index and
managed) to determine which of these investments are appropriate to implement the client’s IPS. The
number of investments recommended will be determined by the client, based on the IPS.
Monitoring of Investment Performance - Client investments will be monitored continuously, based
on the procedures and timing intervals outlined in the Investment Policy Statement. Although MWP will
not be involved in any way in the purchase or sale of these investments, MWP will monitor the client’s
portfolio and will make recommendations to the client as market factors and the client’s needs dictate.
Employee Communications - For pension, profit sharing, 403(b) and 401(k) plans where the
individual account participant exercises control over assets in his/her account (from now own self-
directed plans), MWP also provides educational support and investment workshops designed for the
Plan participants. The nature of the topics to be covered will be determined by MWP and the client
under the guidelines established in ERISA Section 404(c). The educational support and investment
workshops will not provide plan participants with individualized, tailored investment advice or
individualized, tailored asset allocation recommendations.
Other retirement planning services are available on request. All retirement planning services,
whether general or customized, will be outlined in an agreement that shows the services that will
provided and the fees that will be charged for those services.
As of April 2023, MWP has $ 203,000,000.00 assets under management. MWP manages all assets on a
discretionary basis.