Maslow Wealth Advisors ("MWA") is a SEC-registered investment adviser with its principal place of business
located in Texas. MWA (formerly Durbin Bennett Peterson Private Wealth Management, LLC) began
conducting business in 2001.
Listed below are the firm's equity shareholders:
•Richard Baldwin Bennett, Member/Partner
•Matthew Paul Jachimiak, Chief Investment Officer/Managing Member/Partner
•Paul Darter Lueb, Jr, Member/Partner
•Tylor Bordelon Seaman, Chief Executive Officer/Chief Compliance Officer/Managing Member
•Ashley Kilgust, Managing Member/Partner
•Angela Smith, Member/Partner
•Kevin R. Tiernan, Member/Partner
•Kathryn Turnham Brown, Member/Partner
MWA offers the following advisory services to our clients:
1. INVESTMENT SUPERVISORY SERVICES - INDIVIDUAL PORTFOLIO MANAGEMENT
provides advice to a client regarding the investment of client funds based on the individual needs of the client.
We provide discretionary and non-discretionary asset management services and investment consulting
services to high-net-worth individuals, trusts, estates, foundations, endowments and other related entities. We
manage portfolios of financial assets for clients that may include but is not limited to equities and fixed income
securities, mutual funds, exchange traded funds, separate accounts, and private funds, including hedge funds,
private equity investments and limited partnerships. These private funds will generally be managed by third--
party, professional portfolio managers ("Money Managers").
MWA's portfolio management services are tailored to the individual needs and particular circumstances of the
client. Through personal consultations, we typically develop a personalized, documented Investment Policy
Statement (IPS). The IPS articulates the client's investment objectives, time horizons, risk tolerance, liquidity
needs, and other considerations important to managing the client's assets. We provide portfolio management
services in the context of the client's overall wealth and financial situation, including outside accounts that are
not managed by . The client's portfolio is implemented and managed by the criteria defined in the IPS.
Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry
sectors. Clients will retain individual ownership of all securities.
INVESTMENT PHILOSOPHY
Overview
MWA constructs globally diversified portfolios to help generate long term appreciation while weathering
changing market conditions. strategically and tactically constructs portfolios according to our clients'
Investment Policy Statement, which outlines their needs, goals, and risk tolerances. The investment philosophy
4
and process are continuously scrutinized by the firm's internal investment committee and research staff.
Through rigorous due diligence, MWA endeavors to provide access to proven and progressive investment
management approaches and strategies for our clients.
Core Tenets
Markets are efficient over the long term, however, over the short term, believes that markets can be irrational
or inefficient. Due to this belief, constructs portfolios that have more passive "core" and more active "satellite"
components. The balance between core/satellite is determined through a series of suitability discussions
between the client and .
MWA believes that rebalancing is one of the keys to long-term portfolio performance. Rebalancing forces a
client to trim asset classes that have performed well and reallocate those dollars into asset classes that have
underperformed on a relative basis. Ultimately, employs a sell high and buy low strategy. Rebalancing also
helps to keep the overall risk, as measured by standard deviation, within a specific band.
Rebalancing is performed as needed and is reviewed no less than quarterly. MWA adheres to predetermined
tolerance ranges for various assets classes. Observing tolerance ranges for rebalancing decisions helps to
limit transactions costs as well as capital gain generation within client portfolios.
MWA believes that net return (net of trading fees, market slippage, and taxes) rather than gross return is a
more accurate representation of the performance our clients care most about. As such, when trades are
performed in client accounts, we look to capture losses when possible, but if not, long term gains are
preferable over short term gains. Additionally, when we construct client portfolios, we look to locate tax dis--
advantaged assets (income strategies) within tax deferred accounts (IRAs) to reduce any tax impacts.
Portfolio Implementation
MWA utilizes an allocation model that segments assets into three primary asset classes: Traditional Equities,
Traditional Fixed Income, and Satellites (Alternatives). Those three primary asset classes further break down
into more specific sub asset classes, including: traditional fixed income, traditional equities, real assets (i.e.,
private real estate and natural resources), and alternatives (i.e., private equity, equity alternatives, and fixed
income alternatives). Each asset class provides specific beneficial characteristics to a client portfolio.
Traditional Fixed income includes both domestic and international/emerging market long- only bonds, as well
as sovereign and corporate debt. This asset class is added as a risk mitigation and income generation
strategy. This asset class can be thought of as deflation hedge and tends to have low to moderate volatility.
Traditional Equities includes public and private equity of domestic and international/emerging market
companies. This asset class adds long-term appreciation with the potential of income generation. Equities
have historically captured the return associated with general global economic growth. This asset class tends to
have high volatility.
Real Assets include both public and private investments that tend to have physical assets represented as the
underlying investment. Examples would include private real estate, commodities, and energy. This asset class
can be thought of as an inflation hedge along with the potential for income generation. Real Assets tend to
have moderate to high volatility characteristics.
Alternatives include those strategies that do not logically fit into the previous asset classes. Examples would
include global macro, event strategies, currency, and volatility. These strategies are used with the premise that
they have little to no market correlation and can help provide some protection in volatile markets. This asset
class tends to have low to moderate volatility characteristics.
Beyond the two primary asset classes and subsequent sub-asset classes, takes into account two additional
factors: liquidity and domicile. Liquidity is the understanding of how quickly a client's portfolio can be liquidated
in times of market stress. We believe that allocations to semi-liquid and illiquid assets can be beneficial for
5
certain clients, but we also believe that having too much in illiquid assets can present other risks to clients.
Domicile is the understanding of where a client portfolio is allocated globally. maintains relative balance
between investments made domestically versus internationally.
2. SELECTION AND MONITORING SERVICES
MWA provides several advisory services separately or in combination. Our Selection and Monitoring Services
are comprised of three distinct services. Clients may choose to use any or all of these services.
•Investment Policy Statement Preparation (hereinafter referred to as IPS):
We will meet with the client (in person, video, or over the telephone) to determine the client's investment needs
and goals. We will then prepare a written IPS stating those needs and goals and encompassing a policy under
which these goals are to be achieved. 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 Investment Vehicles:
We will review various investments, consisting of mutual funds and ETFs (both index and managed; separate
accounts and private funds if appropriate) to determine which of these investments are appropriate to
implement the client's IPS. The number of investments to be recommended will be determined by the client,
based on the IPS.
• Monitoring of Investment Performance:
For clients that engage us for performance monitoring, client investments will be monitored continuously based
on the procedures and timing intervals delineated in the IPS. Although we will not be involved in any way in the
purchase or sale of these investments, we will supervise the client's portfolio and make recommendations to
the client as market factors and the client's needs dictate.
3. INVESTMENT ADVISEMENT SERVICES
Adviser will provide ongoing access to the firm's investment committee for basic investment analysis. For an
additional project fee (to be negotiated based on an estimated
time commitment), the firm will also provide
project- or investment-specific detailed analysis.
Adviser also provides Client with a login for its portfolio accounting software and where applicable to its
financial planning software where Client can view account values and performance data on-demand for the
period (or from the opening of the Account(s)). Client can elect to review their accounts, including their outside
accounts, in a consolidated format. If requested by Client, Advisor will make available quarterly reports either
via email or by hardcopy mail.
Adviser will provide ongoing access to private deals and investment opportunities that are presented to the
firm. The firm reserves the right to limit or restrict the amount of the investment based on sizing estimates by
the investment committee for the firm's managed assets.
4. STRATEGIC WEALTH PLANNING
We provide financial planning services termed Strategic Wealth Plan (SWP). This service includes a general
review of a client's financial matters, including retirement needs, cash flow, investments, insurance, and tax
matters. Generally, the SWP is designed to be a financial model to assist the client in making current and
future financial decisions to achieve or maintain financial independence.
A SWP may help the client in one or more of the following: (i) determining accumulation of assets needed for
retirement, (ii) developing current and future spending budgets, (iii) quantifying and planning for educational
funding or other significant life events, (iv) identifying insurance or risk management needs, (v) determining a
general investment allocation needed to meet financial objectives, (vi) identifying estate planning needs, and
(vii) addressing other related financial issues. Specific recommendations may be developed based on this
6
planning. Should the client choose to implement the recommendations contained in the plan, we suggest the
client work closely with his/her attorney, accountant, insurance agent, and/or financial consultant.
Implementation of the SWP recommendations is entirely at the client's discretion.
Clients may elect to add more advanced-planning services that may include additional estate planning or tax
planning services, asset management, 401k management, retirement plan advisory services, and/or any of the
other advisory services offered by the Advisor. With these services, clients have the option of receiving
financial planning services for a bundled fee, which could include the development of comprehensive estate
planning documents (trusts, wills, power of attorneys, advance medical directives, etc.) prepared by an
attorney with whom the Advisor has a relationship, advanced tax planning including preparation of tax returns
by an accountant associated with a firm affiliated with the Advisor, or other advanced financial planning
services. Services may also include asset management, 401k plan management, retirement plan advisory
services, among other things. Each service selected by a client will be specified in the Investment Services
Agreement a client signs with our firm. Clients engage affiliated and unaffiliated service providers separately
and in their sole discretion.
The SWP may be used as a dynamic model and updated periodically. The scope and term of the planning are
agreed upon in advance with the client.
5. IRA ROLLOVER CONSIDERATIONS
As part of our investment advisory services to you, 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 will manage
on your behalf. If you elect to roll the assets to an IRA that is subject to our management, will charge you an
asset-based fee as set forth in the agreement you executed with the firm. This practice presents a conflict of
interest because persons providing investment advice on behalf of 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 .
6. CONSULTING SERVICES
Clients can also receive investment advice on a specific item. This may include advice on an isolated area(s)
of concern such as estate planning, retirement planning, risk management, or any other particular topic. We
also provide specific consultation and administrative services regarding investment and financial concerns of
the client.
Consulting recommendations are not limited to any specific product or service offered by a broker dealer or
insurance company. All recommendations are of a generic nature.
In certain limited situations as the client's needs dictate, we may also develop and implement hedging
transactions or other unique investment strategies on assets held in a client's portfolio.
7. SUB ADVISORY SERVICES
Under an Investment Sub-Advisory Agreement dated August 1, 2012, between ("Subadvisor") and SALI Fund
Management, LLC ("Investment Advisor"), Investment Advisor appointed Subadvisor to act as an investment
sub-advisor to the Zilker Diversified Insurance Dedicated Fund Series Interests of the SALI Multi-Series Fund,
L.P. (the "Fund"). The Fund is an interest in the SALI Multi-Series Fund, L.P., a Delaware limited partnership
("Partnership"). Pursuant to the Sub-Advisory Agreement, Subadvisor is responsible for: conducting initial and
ongoing due diligence on the underlying funds, managers, and investment strategies; monitoring the
performance of all underlying investments and making changes to the investments, including allocations, as
necessary; providing an investment mandate, which describes the investment style, and details of the potential
risks associated with investments in the Fund; assisting the Investment Advisor in the creation of marketing
materials and, as appropriate, providing periodic client service communication, typically a narrative on past
performance and outlook on future directions.
7
The Partnership's General Partner, SALI Fund Partners, LLC (the "General Partner"), exercises ultimate
authority over the Partnership and is responsible for its day-to-day operations. Investments in the Partnership
are available only to insurance company investors on behalf of certain of their segregated separate accounts
for owners of variable life insurance and variable annuity contracts.
Under an Investment Sub-Advisory Agreement dated 11/15/2023, between ("Sub Advisor") and Spearhead
Administrative Services, L.P. ("Investment Advisor"), Investment Advisor appointed Subadvisor to act as an
investment sub-advisor to the Services that relate to Zilker I & II. Both Zilker I & II are managed by Spearhead
Administrative Services in the same way that Zilker Diversified is managed by SALI.
The series supplement to the Confidential Private Offering Memorandum of the Zilker Series I and Zilker Series
II interests of the Spearhead Administrative Services, L.P. provides a description of the fees to be charged.
Spearhead Administrative Services, LLC will charge a fee to the fund and then pay a portion of that fee to
MWA for its investment sub advisory services. MWA will not charge its clients a fee for assets invested in this
fund.
8. Independent Manager Services
MWA may select or recommend a third party investment manager (the "Independent Managers") to actively
manage a portion of a client's assets. Independent Managers may provide advice to our clients either through
a separately managed account over which the Independent Manager is granted discretion by the firm or the
client (the "SMAs"), or through model portfolios developed by an Independent Manager that either the firm or
its clients select (the "Models"). Independent Managers are engaged either through an agreement between the
firm and the Independent Manager, or in a separate written agreement between the Independent Manager and
the client, which is in addition to the agreement entered into between the client and . will serve as the client's
primary advisor, assisting and advising the client in establishing investment objectives for the account(s), the
selection of the Independent Manager(s), defining any client investment restrictions and other support with
respect to the account[s]. The Independent Manager(s)will have responsibility for the day-to-day discretionary
management of the investments in the account(s) and will manage the account(s) consistent with the stated
mandates of the Models.
The Independent Manager may assume responsibility for fee billing, and fees are generally billed separately
from fees charged by . will not receive different levels of compensation or any additional fees depending on the
Independent Manager selected.
AMOUNT OF MANAGED ASSETS
As of December 31, 2023, we were actively managing $1,483,309,197 of clients' assets on a discretionary
basis and $274,769,864 of clients' assets on a non-discretionary basis.