Miller Wealth Management Group, LLC

 

 

Form ADV Part 2A – Disclosure Brochure

Effective: August 10, 2020

 

This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Miller Wealth Management Group, LLC (“MWM” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (217) 542-7700.

 

MWM is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about MWM to assist you in determining whether to retain the Advisor.

 

Additional information about MWM and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 297590.

 

 

Miller Wealth Management Group, LLC 3090 N. Main Street, Suite C, Decatur, IL 62526

Phone: (217) 542-7700 * Fax: (217) 542-7701

www.millerwmg.net

 
   

Item 2 – Material Changes

Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of MWM. For convenience, the Advisor has combined these documents into a single disclosure document.

 

MWM believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. MWM encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor.

 

Material Changes

The following material change has been made to this Disclosure Brochure:

  • Ronald E. Miller passed away in March 2020. Please see updates to ownership in Item 4 below.

 

Future Changes

From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs.

 

At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 297590. You may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at (217) 542-7700 or by email.

 
   
 
   

Item 3 – Table of Contents

Item 1 – Cover Page.................................................................................................................................... 1

Item 2 – Material Changes........................................................................................................................... 2

Item 3 – Table of Contents........................................................................................................................... 3

Item 4 – Advisory Services.......................................................................................................................... 4

  1. Firm Information................................................................................................................................................................................ 4
  2. Advisory Services Offered............................................................................................................................................................... 4
  3. Client Account Management.......................................................................................................................................................... 6
  4. Wrap Fee Programs........................................................................................................................................................................ 6
  5. Assets Under Management............................................................................................................................................................ 6

Item 5 – Fees and Compensation................................................................................................................ 6

  1. Fees for Advisory Services............................................................................................................................................................. 6
  2. Fee Billing.......................................................................................................................................................................................... 7
  3. Other Fees and Expenses.............................................................................................................................................................. 7
  4. Advance Payment of Fees and Termination............................................................................................................................... 8
  5. Compensation for Sales of Securities........................................................................................................................................... 8

Item 6 – Performance-Based Fees and Side-By-Side Management............................................................. 9

Item 7 – Types of Clients............................................................................................................................. 9

Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss...................................................... 9

  1. Methods of Analysis......................................................................................................................................................................... 9
  2. Risk of Loss..................................................................................................................................................................................... 10

Item 9 – Disciplinary Information............................................................................................................... 11

Item 10 – Other Financial Industry Activities and Affiliations.................................................................... 11

Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.............. 11

  1. Code of Ethics................................................................................................................................................................................ 11
  2. Personal Trading with Material Interest...................................................................................................................................... 12
  3. Personal Trading in Same Securities as Clients...................................................................................................................... 12
  4. Personal Trading at Same Time as Client................................................................................................................................. 12

Item 12 – Brokerage Practices................................................................................................................... 12

  1. Recommendation of Custodian[s]............................................................................................................................................... 12
  2. Aggregating and Allocating Trades............................................................................................................................................. 13

Item 13 – Review of Accounts................................................................................................................... 13

  1. Frequency of Reviews................................................................................................................................................................... 13
  2. Causes for Reviews....................................................................................................................................................................... 13
  3. Review Reports.............................................................................................................................................................................. 13

Item 14 – Client Referrals and Other Compensation.................................................................................. 13

  1. Compensation Received by MWM.............................................................................................................................................. 13
  2. Client Referrals from Solicitors.................................................................................................................................................... 14

Item 15 – Custody...................................................................................................................................... 14

Item 16 – Investment Discretion................................................................................................................ 14

Item 17 – Voting Client Securities.............................................................................................................. 15

Item 18 – Financial Information................................................................................................................. 15

Form ADV Part 2Bs – Brochure Supplements........................................................................................... 16

Privacy Policy............................................................................................................................................ 23

 
   
 
   

Item 4 – Advisory Services

A.Firm Information

Miller Wealth Management Group, LLC (“MWM” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of Illinois. MWM became a registered investment advisor in October 2018, and is owned by Kathryn Miller and operated by Terry W. Miller (Chief Investment Officer and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by MWM.

 

B.Advisory Services Offered

MWM offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, and retirement plans (each referred to as a “Client”).

 

The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. MWM’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.

 

Investment Management Services

MWM provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. MWM works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. MWM will then construct an investment portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds or options contracts to meet the needs of its Clients. The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations.

 

MWM’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. MWM will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor.

 

MWM evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. MWM may recommend, on occasion, redistributing investment allocations to diversify the portfolio. MWM may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. MWM may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.

 

At no time will MWM accept or maintain custody of a Client’s funds or securities except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.

 

Use of Independent Managers – When deemed to be in the Client’s best interest, MWM will recommend to Clients that all or a portion of their investment portfolio be implemented by utilizing one or more unaffiliated money managers/investment platforms (collectively “Independent Managers”), which are available through the recommended Custodians. The Client may be required to enter into a separate agreement with the Independent Manager[s]. In these instances, MWM serves as the Client’s primary advisor and relationship manager. However, the Independent Manager[s] will assume discretionary authority for the day-to-day investment management of

those assets placed in their control. MWM will assist and advise the Client in establishing in-vestment objectives for their account[s], the selection of the Independent Manager[s], and defining any restrictions on the account[s]. MWM will continue to provide oversight of the Client’s account[s] and ongoing monitoring of the activities of these unaffiliated parties. The Independent Manager[s] will implement the selected investment strategies based on their investment mandates. The Client may be able to impose reasonable investment restrictions on these accounts, subject to the acceptance of these third parties.

Prior to entering into an agreement with an Independent Manager, the Client will be provided with the Independent Manager’s Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures). MWM is also responsible for determining whether the Independent Manager is properly registered, notice filed or exempt from such filings. MWM does not receive any compensation from these Independent Managers or Investment Platforms, other than MWM’s investment advisory fee, as described in Item 5.

Financial Planning Services

MWM will typically provide a variety of financial planning and consulting services to Clients, either as a component of investment management services or pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives.

Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may

encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs, and other areas of a Client’s financial situation.

A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs.

MWM may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly.

Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor.

 

Retirement Plan Advisory Services

MWM provides advisory services on behalf of company retirement plans (each a “Plan”) and the company/sponsor (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:

  • Vendor Analysis
  • Plan Participant Enrollment and Education Tracking
  • Investment Policy Statements (“IPS”) Design and Monitoring
  • Investment Oversight Services (ERISA 3(21))
  • Investment Management Services (ERISA 3(38))
  • Performance Reporting
  •  
 
   

Ongoing Investment Recommendations and Assistance

 

  • ERISA 404(c) Assistance

 

These services are provided by MWM serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan

Sponsor is provided with a written description of MWM’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement.

 

C.Client Account Management

Prior to engaging MWM to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:

 

  • Establishing an Investment Strategy – MWM, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
  • Asset Allocation – MWM will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk of each Client.
  • Portfolio Construction – MWM will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
  • Investment Management and Supervision – MWM will provide investment management and ongoing oversight of the Client’s investment portfolio.

 

D.Wrap Fee Programs

MWM does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by MWM.

 

E.Assets Under Management

As of December 31, 2019, MWM manages $108,204,922 Client assets, $107,500,000 of which are managed on a discretionary basis and $704,922 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.

 
   

Item 5 – Fees and Compensation

The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more written agreements with the Advisor.

 

A.Fees for Advisory Services

Investment Management Services

Investment advisory fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the agreement. Investment advisory fees are based on the market value of assets under management at the end of the prior calendar quarter. Investment advisory fees range up to 1.75% annually based on several factors, including: the complexity of the services to be provided, the level of assets to be managed, and the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions and other complexities may be charged a higher fee.

 

The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by MWM will be independently valued by the Custodian. MWM will not have the authority or responsibility to value portfolio securities.

 

 

 
   

 

The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs.

 

Use of Independent Managers – As noted in Item 4, the Advisor will implement all or a portion of a Client’s investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an Independent Manager. The Advisor will only earn its investment advisory fee as described above. Independent Managers typically do not offer any fee discounts but may have a breakpoint schedule which will reduce the fee with an increased level of assets placed under management with an Independent Manager. The terms of such fee arrangements are included in the Independent Manager’s disclosure brochure and applicable contract[s] with the Independent Manager. The total blended fee, including the Advisor’s

fee and the Independent Manager’s fee, will not exceed 3.00% annually.

 

Financial Planning Services

MWM offers financial planning services either on an hourly basis or a fixed engagement fee. Hourly engagements range up to $300 per hour. Fixed engagement fees range up to $2,500. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours and total costs will be provided to the Client prior to engaging for these services.

 

Retirement Plan Advisory Services

Fees for retirement plan advisory services are charged an annual asset-based fee of up to 1.75%, billed quarterly, in advance of each calendar quarter, pursuant to the terms of the agreement. Retirement plan advisory fees are based on the market value of assets under management at the end of the prior calendar quarter. Fees may be negotiable depending on the size and complexity of the Plan.

 

B.Fee Billing

Investment Management Services

Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the beginning of the respective quarter. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with MWM at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide written authorization permitting advisory fees to be deducted by MWM to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian.

 

Use of Independent Managers – For Client accounts implemented through an Independent Manager, the Client’s overall fees will include MWM’s investment advisory fee (as noted above) plus investment management fees and/or platform fees charged by the Independent Manager. The Independent Manager will assume the responsibility for calculating the Client’s fees and deducting all fees from the Client’s account[s].

 

Financial Planning Services

Financial planning fees may be invoiced up to fifty percent (50%) of the expected total fee upon execution of the financial planning agreement. The balance shall be invoiced upon completion of the agreed upon deliverable[s].

 

Retirement Plan Advisory Services

Fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement.

 

C.Other Fees and Expenses

 
   

Clients may incur certain fees or charges imposed by third parties, other than MWM, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and

 

conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. The fees charged by MWM are separate and distinct from these custody and execution fees.

 

In addition, all fees paid to MWM for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of MWM, but would not receive the services provided by MWM which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by MWM to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information.

 

D.Advance Payment of Fees and Termination

Investment Management Services

MWM may be compensated for its services in advance of the quarter in which investment management services are rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. The Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s investment advisory agreement with the Advisor is non- transferable without the Client’s prior consent.

 

Use of Independent Managers – In the event that a Client should wish to terminate their relationship with an Independent Manager, the Advisor will generally remove the assets from the Independent Manager and either place the assets with a new Independent Manager or manage the assets directly.

 

Financial Planning Services

MWM may be partially compensated for its financial planning services in advance. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for actual hours logged on the planning project times the contractual hourly rate or in the case of a fixed fee engagement, the percentage of the engagement scope completed by the Advisor. The Advisor will refund any unearned, prepaid planning fees from the effective date of termination. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent.

 

Retirement Plan Advisory Services

MWM may be compensated for its services in advance of the quarter in which investment management services are rendered. Either party may terminate the retirement plan advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the retirement plan advisory agreement within five

(5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. The Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s retirement plan advisory agreement with the Advisor is non-transferable without the Client’s prior consent.

 

E.Compensation for Sales of Securities

MWM does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above.

 
   

Mr. Miller is a registered representative of Private Client Services, LLC ("PCS"), a securities broker-dealer, and a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). In Mr. Miller’s separate capacity as a registered representative of PCS, Mr. Miller will implement securities transactions under PCS and not through MWM. In such instances, Mr. Miller will receive commission-based compensation in connection with the purchase and sale of securities, including 12b-1 fees for the sale of investment company products. Compensation earned by Mr. Miller, in his capacity as a registered representative is separate from and in addition to MWM’s advisory fees. Please see Item 10 – Other Financial Industry Activities and Affiliations.

 

Advisory Persons are also licensed as independent insurance professionals. As an independent insurance professional, an Advisory Person will earn commission-based compensation for selling insurance products, including insurance products they sell to Clients. Insurance commissions earned by an Advisory Person are separate and in addition to MWM’s advisory fees. This practice presents a conflict of interest because a person providing investment advice on behalf of the Advisor who is also an insurance agent has an incentive to recommend insurance products to Clients for the purpose of generating commissions rather than solely based on Client needs. However, Clients are under no obligation, contractually or otherwise, to purchase insurance products through an Advisory Person. Please see Item 10 – Other Financial Industry Activities and Affiliations.

 
   

Item 6 – Performance-Based Fees and Side-By-Side Management

MWM does not charge performance-based fees for its investment advisory services. The fees charged by MWM are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client.

 

MWM does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients.

 
   

Item 7 – Types of Clients

MWM offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, and retirement plans. The amount of each type of Client is available on MWM’s Form ADV Part 1A. These amounts may change over time and are updated at least annually by the Advisor. MWM generally does not impose a minimum relationship size. However, Independent Managers typically require a minimum level of assets.

 
   

Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss

A.Methods of Analysis

MWM primarily employs fundamental analysis in developing investment strategies for its Clients. Research and analysis from MWM are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others.

 

Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts.

 
   

As noted above, MWM generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. MWM will typically hold all or a portion of a security for more than a year, but may hold for shorter

 

periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, MWM may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class.

 

B.Risk of Loss

Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. MWM will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. Please see Item 8.B. for risks associated with the Advisor’s investment strategies as well as general risks of investing.

 

While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic

indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts.

 

Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis.

 

The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. The following are some of the risks associated with the Advisor’s investment approach:

 

Market Risks

The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets.

 

ETF Risks

The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later.

 

Bond Risks

Bond are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk,

i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of

the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond.

 
   

 

Mutual Fund Risks

The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day.

 

Options Contracts

Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This leverage can compound gains or losses.

 

Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor.

 
   

Item 9 – Disciplinary Information

There are no legal, regulatory or disciplinary events involving MWM or its owner. MWM values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider with whom the Client engages. The backgrounds of the Advisor and its Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 297590.

 
   

Item 10 – Other Financial Industry Activities and Affiliations

Broker-Dealer Affiliation

As detailed in Item 5.E. above, Mr. Miller is also a registered representative of PCS. In Mr. Miller’s separate capacity as a registered representative, Mr. Miller will receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by Mr. Miller. Neither MWM nor Mr. Miller will earn ongoing investment advisory fees in connection with any services implemented in Mr. Miller’s separate capacity as a registered representative. Under supervision by PCS, PCS may have access to certain confidential information of the Client, including, but not limited to financial information, investment objectives, transactions and holdings information.

 

Insurance Agency Affiliations

As noted in Item 5.E. above, Advisory Persons of MWM are also licensed insurance professionals. Implementations of insurance recommendations are separate and apart from an Advisory Person’s role with MWM. As insurance professionals, Advisory Persons will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending insurance products. Clients are under no obligation to implement any recommendations made by an Advisory Person or the Advisor.

 
   

Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading

A.Code of Ethics

MWM has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with MWM (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. MWM and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of MWM’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (217) 542-7700 or via email.

 
   

 

B.Personal Trading with Material Interest

MWM allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. MWM does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. MWM does not have a material interest in any securities traded in Client accounts.

 

C.Personal Trading in Same Securities as Clients

MWM allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities MWM recommends (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, MWM must disclose to Clients and mitigate through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities.

The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by MWM requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information.

 

D.Personal Trading at Same Time as Client

While MWM allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward. At no time will MWM, or any Supervised Person of MWM, transact in any security to the detriment of any Client.

 
   

Item 12 – Brokerage Practices

A.Recommendation of Custodian[s]

MWM does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize MWM to direct trades to the Custodian as agreed upon in the investment advisory agreement.

Further, MWM does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis.

 

Where MWM does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the Advisor and will not incur any extra fee or cost associated with using a broker-dealer/custodian not recommended by MWM. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. As registered representatives of PCS, the Advisor may be limited in using other broker-dealers/custodians as PCS must approve the use of any outside broker-dealer/custodian. MWM may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation, and/or the location of the Custodian’s offices. MWM will generally recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified custodian”. MWM maintains an institutional relationship with Schwab, whereby the Advisor receives economic benefits from Schwab. Please see Item 14 below.

 

Following are additional details regarding the brokerage practices of the Advisor:

 

  1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. MWM does not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below.
 
   
  1. Brokerage Referrals - MWM does not receive any compensation from any third party in connection with the recommendation for establishing an account.
  2. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where MWM will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). MWM will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the designated Custodian. The Advisor may not be able to aggregate orders to reduce transaction costs in a Client directed brokerage account.

 

B.Aggregating and Allocating Trades

The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. MWM will execute its transactions through the Custodian as authorized by the Client. MWM may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Client accounts.

 
   

Item 13 – Review of Accounts

A.Frequency of Reviews

Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons of MWM and periodically by Terry W. Miller, Chief Compliance Officer of MWM. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client.

 

B.Causes for Reviews

In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify MWM if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events.

 

C.Review Reports

The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance.

 
   

Item 14 – Client Referrals and Other Compensation

A.Compensation Received by MWM

MWM may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, MWM may receive non-compensated referrals of new Clients from various third-parties.

 
   

 

Participation in Institutional Advisor Platform

MWM has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like MWM. As a registered investment advisor participating on the Schwab Advisor Services platform, MWM receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services.

 

Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments.

 

Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients.

 

Services that May Only Benefit the Advisor – Schwab also offers other services and support to MWM that may not benefit the Client, including: educational conferences and events, financial start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a conflict of interest. MWM believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients.

 

B.Client Referrals from Solicitors

MWM does not engage paid solicitors for Client referrals.

 
   

Item 15 – Custody

MWM does not accept or maintain custody of any Client accounts, except for the authorized deduction of the Advisor’s fees. All Clients must place their assets with a “qualified custodian”. Clients are required to engage the Custodian to retain their funds and securities and direct MWM to utilize that Custodian for the Client’s security transactions. Clients should review statements provided by the Custodian and compare to any reports provided by MWM to ensure accuracy, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices.

 
   

Item 16 – Investment Discretion

MWM generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by MWM. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by MWM will be in accordance with each Client's investment objectives and goals.

 
   
 
   

Item 17 – Voting Client Securities

MWM does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting.

 
   

Item 18 – Financial Information

Neither MWM, nor its management, have any adverse financial situations that would reasonably impair the ability of MWM to meet all obligations to its Clients. Neither MWM, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. MWM is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future.

 
   

 

 

Form ADV Part 2B – Brochure Supplement

for

 

 

Jesse D. Rupp

Vice President of Investments & Secretary, Financial Advisor Effective: August 10, 2020

 

 

This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Jesse D. Rupp (CRD# 6815892) in addition to the information contained in the Miller Wealth Management Group, LLC (“MWM” or the “Advisor”, CRD# 297590) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the MWM Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (217) 542-7700.

 

Additional information about Mr. Rupp is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 6815892.

 
   

 

 Item 2 – Educational Background and Business Experience                                                                

Jesse D. Rupp, born in 1993, is dedicated to advising Clients of MWM as the Vice President of Investments & Secretary, Financial Advisor. Mr. Rupp earned a Bachelor of Science in Finance & Business Economics from Southern Illinois University - Carbondale in 2016. Additional information regarding Mr. Rupp’s employment history is included below.

 

Employment History:

Vice President of Investments & Secretary, Financial Advisor, Miller Wealth Management Group, LLC

01/2019 to Present

Registered Representative, Private Client Services, LLC

01/2019 to 12/2019

Financial Advisor, Wells Fargo Advisors Financial Network, LLC

06/2017 to 12/2018

Student, Southern Illinois University - Carbondale

08/2011 to 04/2016

 

Item 3 – Disciplinary Information

There are no legal, civil or disciplinary events to disclose regarding Mr. Rupp. Mr. Rupp has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Rupp.

 

Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Rupp.

 

However, the Advisor does encourage you to independently view the background of Mr. Rupp on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 6815892.

 

Item 4 – Other Business Activities

Insurance Agency Affiliations

Mr. Rupp is also a licensed insurance professional. Implementations of insurance recommendations are separate and apart from Mr. Rupp’s role with MWM. As an insurance professional, Mr. Rupp will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Mr.

Rupp is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by Mr. Rupp or the Advisor.

 

Item 5 – Additional Compensation

Mr. Rupp has additional business activities that are detailed in Item 4 above.

 

Item 6 – Supervision

Mr. Rupp serves as a Vice President of Investments & Secretary, Financial Advisor of MWM and is supervised by Terry Miller, the Chief Compliance Officer. Mr. Miller can be reached at (217) 542-7700.

 
   

MWM has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of MWM. Further, MWM is subject to regulatory oversight by various agencies. These agencies require registration by MWM and its Supervised Persons. As a registered entity, MWM is subject to examinations by regulators, which may be announced or unannounced. MWM is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor.

 

 

 

Form ADV Part 2B – Brochure Supplement

for

 

 

Scott S. Gregory

Chief Marketing Officer, Financial Advisor Effective: August 10, 2020

 

 

This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Scott S. Gregory (CRD# 4426847) in addition to the information contained in the Miller Wealth Management Group, LLC (“MWM” or the “Advisor”, CRD# 297590) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the MWM Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (217) 542-7700.

 

Additional information about Mr. Gregory is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4426847.

 
   

 

Item 2 – Educational Background and Business Experience

Scott S. Gregory, born in 1975, is dedicated to advising Clients of MWM as the Chief Marketing Officer, Financial Advisor. Mr. Gregory earned a Bachelor of Business Administration from Central Michigan University in 2001.

Additional information regarding Mr. Gregory’s employment history is included below.

 

Employment History:

Chief Marketing Officer, Financial Advisor, Miller Wealth Management Group, LLC

01/2019 to Present

Registered Representative, Private Client Services, LLC

01/2019 to 12/2019

Financial Advisor, Wells Fargo Advisors Financial Network, LLC

01/2008 to 12/2018

 

Item 3 – Disciplinary Information

There are no legal, civil or disciplinary events to disclose regarding Mr. Gregory. Mr. Gregory has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Gregory.

 

Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Gregory.

 

However, the Advisor does encourage you to independently view the background of Mr. Gregory on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4426847.

 

Item 4 – Other Business Activities

Insurance Agency Affiliations

Mr. Gregory is also a licensed insurance professional. Implementations of insurance recommendations are separate and apart from Mr. Gregory’s role with MWM. As an insurance professional, Mr. Gregory will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Mr. Gregory is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by Mr. Gregory or the Advisor.

 

Item 5 – Additional Compensation

Mr. Gregory has additional business activities that are detailed in Item 4 above.

 

Item 6 – Supervision

Mr. Gregory serves as the Chief Marketing Officer, Financial Advisor of MWM and is supervised by Terry Miller, the Chief Compliance Officer. Mr. Miller can be reached at (217) 542-7700.

 

MWM has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of MWM. Further, MWM is subject to regulatory oversight by various agencies. These agencies require registration by MWM and its Supervised Persons. As a registered entity, MWM is subject to examinations by regulators, which may be announced or unannounced. MWM is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor.

 
   

 

 

 

Form ADV Part 2B – Brochure Supplement

for

 

 

Terry W. Miller, CFA®

Chief Investment Officer and Chief Compliance Officer Effective: August 10, 2020

 

 

This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Terry W. Miller, CFA® (CRD# 2859939) in addition to the information contained in the Miller Wealth Management Group, LLC (“MWM” or the “Advisor”, CRD# 297590) Disclosure Brochure.  If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the MWM Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (217) 542-7700.

 

Additional information about Mr. Miller is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2859939.

 
   

 

Item 2 – Educational Background and Business Experience

Terry W. Miller, CFA® born in 1960, is dedicated to advising Clients of MWM as a Chief Investment Officer and Chief Compliance Officer. Mr. Miller a earned a degree in Finance from Illinois State University in 1982. Mr. Miller also earned an MBA from Illinois State University in 1984. Additional information regarding Mr. Miller’s employment history is included below.

 

Employment History:

Chief Investment Officer and Chief Compliance Officer, Miller Wealth Management Group, LLC

04/2019 to Present

Finance Director, State Farm Mutual Automobile Company

12/1985 to 01/2019

 

 Chartered Financial Analyst (“CFA®”)

The Chartered Financial Analyst (“CFA”) charter is a professional designation established in 1962 and awarded by CFA Institute. To earn the CFA charter, candidates must pass three sequential, six-hour examinations over two to four years. The three levels of the CFA Program test a wide range of investment topics, including ethical and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio management and wealth planning. In addition, CFA charterholders must have at least four years of acceptable professional experience in the investment decision-making process and must commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. CFA® is a trademark owned by CFA Institute.

 

Item 3 – Disciplinary Information

There are no legal, civil or disciplinary events to disclose regarding Mr. Miller. Mr. Miller has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Miller.

 

Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Miller.

 

However, the Advisor does encourage you to independently view the background of Mr. Miller on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2859939.

 

Item 4 – Other Business Activities

Mr. Miller is dedicated to the investment advisory activities of MWM’s Clients. Mr. Miller does not have any other business activities.

 

Item 5 – Additional Compensation

Mr. Miller is dedicated to the investment advisory activities of MWM’s Clients. Mr. Miller does not receive any additional forms of compensation.

 

Item 6 – Supervision

Mr. Miller serves as the Chief Investment Officer and Chief Compliance Officer of MWM and can be reached at (217) 542-7700.

 
   

MWM has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of MWM. Further, MWM is subject to regulatory oversight by various agencies. These agencies require registration by MWM and its Supervised Persons. As a registered

 

entity, MWM is subject to examinations by regulators, which may be announced or unannounced. MWM is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor.

 
   

 

 Privacy Policy                                                                                                                                              

Effective: August 10, 2020

 

Our Commitment to You

Miller Wealth Management Group, LLC (“MWM” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”).

 

Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. MWM (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you.

 

MWM does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below.

 

Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy.

 

Why you need to know?

Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information.

 

What information do we collect from you?

 

Driver’s license number

Date of birth

Social security or taxpayer identification number

Assets and liabilities

Name, address and phone number[s]

Income and expenses

E-mail address[s]

Investment activity

Account information (including other institutions)

Investment experience and goals

 

What Information do we collect from other sources?

 

Custody, brokerage and advisory agreements

Account applications and forms

Other advisory agreements and legal documents

Investment questionnaires and suitability documents

Transactional information with us or others

Other information needed to service account

 

How do we protect your information?

To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information.

 

We require third parties that assist in providing our services to you to protect the personal information they receive from us.

 
   

 

How do we share your information?

An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information.

 

Basis For Sharing

Do we share?

Can you limit?

Servicing our Clients

We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting.

 

We share Client information with Private Client Services, LLC ("PCS"). This sharing is due to the oversight PCS has over Supervised Persons of the Advisor. You may also contact us at any time for a copy of the PCS Privacy Policy.

 

 

 

 

 

Yes

 

 

 

 

 

No

Marketing Purposes

MWM does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where MWM or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for

marketing purposes.

 

 

 

No

 

 

 

Not Shared

Authorized Users

Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s].

 

Yes

 

Yes

Information About Former Clients

MWM does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients.

 

No

 

Not Shared

 

Changes to our Privacy Policy

We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.

 

Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing.

 

Any Questions?

You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (217) 542-7700.