Description of Firm The Connemara Group is a registered investment adviser primarily based in Gaithersburg, Maryland. We are organized as a limited liability company ("LLC") under the laws of the State of Maryland. We have been providing investment advisory services since 2015. We are owned by Thomas Conway and David Quinn.
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 "we," "our," and "us" refer to The Connemara Group and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm.
The Connemara Group has developed a proprietary program of service that all fall under the umbrella of MATRIX360©. These various offerings have been described below.
MATRIX360© Investment Advisory Services We offer discretionary portfolio management via our MATRIX360© investment advisory services. Our investment advice is tailored to meet our clients' needs and investment objectives. These services are offered as a wrap fee program. We are a portfolio manager to and sponsor of a wrap fee program, which is a type of investment program that provides clients with access to several money managers or mutual fund asset allocation models for a single fee that includes administrative fees, management fees, and commissions. As part of the wrap fee program, you will pay our firm a single 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.
Transactions for your account must be executed by either Charles Schwab & Co. Inc or Fidelity Financial Services, both are securities broker-dealers and members 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 or other broker-dealers, and the advisory fees charged by investment advisers. For more information concerning the Wrap Fee Program, see Appendix 1 to this Brochure.
MATRIX360© investment advisory services have been developed by the Connemara Group to complement and supplement (but never to replace) professional practice standards established by the CFP Board regarding aspects of the financial planning process relating to investment analysis, implementation, and monitoring.
MATRIX360© investment advisory services are provided to clients seeking ongoing professional assistance with personal financial planning services and investment advisory services following completion of an initial comprehensive MATRIX360© financial planning services analysis.
If you participate in our discretionary MATRIX360© investment advisory services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your 4 account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm and the appropriate trading authorization forms.
You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing.
MATRIX360© Financial Planning Services We offer MATRIX360© financial planning services which typically involve providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. These services can range from broad-based financial planning to consultative or single subject planning. If you retain our firm for MATRIX360© financial planning services, we will meet with you to gather information about your financial circumstances and objectives. Once we specify those long-term objectives (both financial and non-financial), we will develop shorter-term, targeted objectives. Once we review and analyze the information you provide to our firm and the data derived from our financial planning software, we will deliver a written plan to you, designed to help you achieve your stated financial goals and objectives.
Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to us. You must promptly notify our firm if your financial situation, goals, objectives, or needs change.
You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm.
Services Included with MATRIX360© As part of the MATRIX360© investment advisory and financial planning services, we also offer the below services for those that require additional advice based on their specific facts and circumstances.
These additional services include:
•MATRIX360 © Retirement Distribution and Estate Planning Services
•Clients approaching the end of the wealth accumulation mode and either nearing or in the wealth distribution mode may have very different risk tolerances, risk preferences, and risk

capacities. Dollar-cost averaging into portfolios during the wealth accumulation mode may have different consequences than dollar-cost averaging out of portfolios during the wealth distribution mode. In retirement distribution planning, many factors take on increasing importance, including household immediate liquidity and spending needs, portfolio sustainability, tax management, portfolio optimization, asset allocation, asset location, volatility, duration risk, inflation, healthcare costs, longevity, lifetime as well as post-mortem intra-family giving and charitable giving, and estate planning.
•MATRIX360 © Federal Retirement Planning Services
•As with most post-retirement decisions involving employer qualified retirement plans, careful consideration must be given, and numerous factors must be weighted in deciding whether to roll over federal Thrift Savings Plan accounts to Individual Retirement Arrangements ("IRAs"). Our MATRIX360© federal retirement planning services incorporate the use of careful questioning and fiduciary software applications to help assess whether full or partial rollovers might be warranted as specific points in time during the retirement phase. 5
•MATRIX360 © Professional and Executive Retirement Planning Services
•This service advises clients on whether or not to roll over all or part of employer qualified retirement plans (401(k)s, etc.) and how to manage and structure various other benefits (deferred compensation arrangements, restricted stock and/or restricted stock units (RSUs), nonqualified stock options (NSOs), incentive stock options (ISOs), performance share awards (PSAs), employee stock purchase plans (ESPPs), Employee Stock Ownership Plans (ESOPs), Net Unrealized Appreciation (NUA) rules, etc.).
•MATRIX360 © Association and Not-for-Profit Executive Retirement Planning Services
•This service advises clients whether or not to roll over all or part of defined contribution employer qualified retirement plans (403(b)s, etc.) and how to manage and structure various other benefits in conjunction with private sector defined benefit pension plans.
•MATRIX360 © Charitable and Philanthropic Services
•Whether or not to use Qualified Charitable Distributions (QCDs) from IRAs post age 70 ½ to manage tax exposure while accomplishing charitable goals, whether or not to use DAFs on a standalone basis or in conjunction with private foundations, and whether or not to use trusts to achieve all or a portion of a clients lifetime or post-mortem charitable and philanthropic goals and objectives are considered and discussed with clients as part of the firm's MATRIX360© financial planning services and MATRIX360© investment advisory services offerings. Types of Investments We offer advice on equity securities, corporate debt securities (other than commercial paper), United States government securities, mutual funds, money market funds, and ETFs. Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
Since our investment strategies and advice are based on each client's specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment.
In general, we manage wrap fee accounts on a discretionary basis. Wrap fee accounts are typically more appropriate for active accounts and are managed accordingly. If you participate in a wrap fee program, we will provide you with a separate Wrap Fee Program Brochure explaining the program and costs associated with the program. You should also review this Part 2A thoroughly to evaluate any differences between the services we offer as wrap versus non-wrap.
IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. 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); 6
•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. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Assets Under Management As of our last annual updating amendment dated, January 31, 2023, the Connemara Group had $236,219,331 million in regulatory assets under management. All of these assets are managed on a discretionary basis.