Marquette Associates, Inc. (“MAI”) is an investment adviser registered with the
Securities and Exchange Commission. MAI’s primary service is to provide investment
consulting services to institutions, individuals, families, trusts, and charitable
organizations or other business entities. The firm was founded and began providing
investment advice in 1986 under the same name.
MAI is headquartered at 180 N. LaSalle Street, Suite 3500, Chicago, IL 60601 and has
an additional office located in Baltimore, Maryland. MAI has two wholly-owned
subsidiary advisers: 1. Fiduciary Consultants, Inc. (“FCI”) located in St. Louis, Missouri,
and 2. Peirce Park Group, Inc. (“PPG”) located in West Chester, Pennsylvania.
Marquette also maintains an office in Milwaukee, Wisconsin. MAI is 100% employee
owned; all 19 owners work full-time at the firm. The principal owners of the firm are
Brian Wrubel and Tim Fallon, CIMA®.
Investment Consulting Services MAI offers both non-discretionary and discretionary investment consulting services,
although MAI provides primarily non-discretionary consulting services. These services
include:
▪ Asset allocation modeling / asset-liability studies
▪ Manager search, selection, and oversight
▪ Performance reporting and attribution analysis
▪ Firm-conducted research and educational training for clients
▪ Investment policy development and oversight
▪ Fee negotiation and cost advisement
▪ Custom benchmark development and peer comparison
▪ Review and selection of custodial bank
MAI provides customized services to its clients and no two investment programs are
alike. Our consultants take into consideration factors such as the client’s risk tolerance,
forecasted liability, and return expectations when making recommendations. Clients are
allowed to designate reasonable restrictions on their accounts.
In addition, MAI will provide fiduciary services which allows MAI to have the
discretionary authority to rebalance accounts and hire and fire third party managers.
Lastly, MAI may also work on special projects for prospective clients wherein MAI is
retained to provide certain, discrete consulting services.
MAI does not participate in wrap fee programs or accept soft dollar payments for its
services.
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QPAM Services/Consulting In addition to MAI’s investment consulting business, MAI serves on a regular basis as a
consultant to various pension plans and as a Qualified Professional Asset Manager
(“QPAM”) under the Employee Retirement Income Act of 1974, as amended (“ERISA”)
with regard to various matters in which the services of a QPAM are required. This service
may be outsourced to a third-party. Such services include:
▪ reviewing and advising on the client’s proposed real estate transactions;
▪ evaluating and advising on conflicts of interest in real estate related
transactions;
▪ providing oversight of the development of real estate construction projects;
▪ conducting due diligence for potential real estate investments;
▪ providing analysis of various strategic decisions associated with leases,
investments, development, dispositions and evaluation of investment decisions;
▪ evaluating real estate investments which have been completed to determine
whether they meet various industry and fiduciary standards; and
▪ overseeing the operations of two real estate properties.
Investment Supervisory Services MAI provides investment supervisory services in the direct management of client
portfolios to individuals, pension and profit sharing plans, trusts, estates, charitable
organizations, corporations and business entities on a discretionary basis. In addition,
MAI has the authority to invest assets with various investment managers that are within
the parameters of the Client’s Investment Policy Statement.
Prior to engaging MAI to provide any of the foregoing investment advisory services, the
client will be required to enter into one or more written agreements with MAI setting
forth the terms and conditions under which MAI shall render its services. Likewise, MAI
will use certain investment tools to determine the clients’ risk parameters, time horizon
and investment objectives. These include in person meetings, a risk profile, client
questionnaire and other documentation.
MAI’s clients are advised to properly notify MAI if there are ever any changes in their
financial situation or investment objectives or if they wish to impose any reasonable
restrictions upon MAI’s management services. In general, MAI does permit restrictions
upon the type of security or particular security that the client requests.
Assets Under Management and Assets under Advisement As of December 31, 2018, MAI had $4,323,164,904 in client assets under management
on a discretionary basis and as of the same date, Marquette provided traditional
investment consulting services to $155,435,761,060 in client assets under advisement.
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Investment Consulting and Management Fees MAI charges fees in three separate ways: 1) as a flat fee, 2) as a percentage of assets
under advisement or management and 3) billed at an hourly rate. Fees are negotiable.
For most clients, MAI negotiates a flat fee for its provision of investment consulting
services, dependent upon the value of the client’s assets under advisement, complexity
of portfolio, travel required, number of meetings per year, and various other relevant
factors. Flat fees are billed quarterly in advance or in arrears dependent upon the
client’s choice. In that way, the annual agreed upon fee is billed to the client in four
separate installments. Flat fees may range from $0- 870,000 per year.
For some clients, MAI negotiates a fee based upon a percentage of the client’s assets
under advisement or management. This fee is based upon the same factors used to
determine the flat fee. MAI charges a client quarterly based upon the value of the
client’s assets under advisement or management as of the last day of the previous
quarter. Fees are billed in advance or in arrears dependent upon the client’s choice.
Fee percentages may range from .05% to .90% of assets under advisement or
management on an annual basis.
Lastly, MAI may charge fees based upon an hourly rate negotiated with the client. This
type of fee arrangement is typically used for ad hoc projects pertaining to consulting
services. These fees will be based upon a determination of the specific nature and
circumstances of the relationship between MAI and the client. These hourly charges are
billed upon the conclusion of the services and are payable within 30 days of completion
of the services.
Terminations and Refunds. A client agreement may be canceled at any time and for any
reason, by either party, upon at least 30 days’ written notice. Upon termination, any
paid but unearned fees will be promptly refunded, and any unpaid fees will be due and
payable.
Other Costs Outside of the annual fee paid to MAI, clients may also incur additional charges from
investment service providers, such as investment manager fees, transaction costs, or
custodial fees. If a client invests in mutual funds with the selected manager it may incur
mutual fund ticket charges and other transaction charges. These fees are in addition to
the fees paid by the client to MAI.
None of MAI’s supervised persons receives compensation for the sale of securities or
other investment products, nor by recommending managers for selection. Our firm does
not offer any proprietary products for investment.
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MAI provides independent investment consulting and fiduciary services to pension and
profit-sharing plans, charitable organizations, corporations, state and municipal
government entities, Taft-Hartley plans, high net worth individuals and other individuals.
In addition to pension and profit-sharing plans, MAI provides services to other types of
benefit plans including, health and welfare, annuity, endowment, foundation, and
general funds.
MAI does not have a minimum account size.
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of Loss Methods of Analysis, Investment Strategies and Risk of Loss MAI provides customized investment advice for each of our clients. Typically, we
evaluate an organization’s cash flow needs, spending policy, liquidity constraints, and
operating results to help determine an overall strategic plan.
Our asset allocation studies evaluate potential client portfolios under a variety of
macroeconomic environments, which directly impact the performance of asset classes.
The studies are built to analyze often overlooked – but critical – features of portfolio
construction, including liquidity, rebalancing, and net cash flow. We offer customized
reports and analytics to evaluate circumstances unique to each plan, such as spending
policies for endowments and funding ratios for pension funds. More generally, our asset
allocation studies offer a comprehensive and rigorous analysis that will formulate the
most effective portfolios to achieve client goals. Specifically, the following initiatives
are included in our asset allocation studies:
▪ Identify and quantify sources of risk, beyond the use of standard deviation as the
sole risk metric
▪ Establish a forward looking methodology that is not anchored by pre-determined
expected returns, standard deviations and correlations
▪ Recognize the illiquid nature of alternative asset classes, along with the liquidity
needs of each client
▪ Incorporate the client’s return goals, liabilities, and cash flows
▪ Allow for portfolio re-balancing to keep asset allocations within target ranges
▪ Allow for non-normal return patterns
▪ Reflect current economic conditions in the analysis.
Our software is based on a Monte Carlo simulation of macroeconomic factors, which
are used to model monthly return outcomes of capital markets. The simulations are
created by a powerful economic scenario generator (“ESG”), which is the driving force
behind our asset allocation model. The economic scenario generator simulates the
future performance of the capital markets and macro-economy; the underlying models
are calibrated based on the long-term historical record, so that they will reproduce the
kinds of volatility and stress scenarios that have been observed over the 20th and 21st
centuries. The models are linked and correlated so that the behavior of different asset
classes and economic variables is consistent within each random scenario.
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Portfolio performance over the course of the study reflects projected net cash flows–
using actual benefit payments and contributions / historical cash flows–as well as overall
portfolio composition, rebalancing rules, and beginning market value. When coupled
with the simulated returns, these inputs provide the monthly market value of all asset
classes for each proposed portfolio and of the total fund. We also calculate average
annualized returns and standard deviations for each portfolio. These statistics allow us
to calculate risk adjusted returns that figure heavily into determining the recommended
portfolio.
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MAI has two wholly-owned subsidiaries: Fiduciary Consultants, Inc. (“FCI”), an SEC-
registered investment adviser based in St. Louis, Missouri, and Peirce Park Group, Inc.
(“PPG”), also an SEC-registered investment adviser based in West Chester,
Pennsylvania. MAI may receive fees and income from FCI and PPG from their
consolidated operations as wholly-owned subsidiaries of MAI.
Marquette has partnered with Operose Advisors, LLC, an investment adviser registered
with the State of Wisconsin and organized as a Wisconsin limited liability company. The
adviser is principally owned by Nicholas C. Bauer through his interest in the Adviser’s
holding company, Beulah Holdings LLC (“Beulah Holdings”) of which Marquette is a
minority owner. As part of this partnership, Marquette participates in the Adviser’s
Investment and Operating Committees and provides economic analysis and investment
research and shares the construct of its discretionary portfolios.
In addition, Marquette may receive items of value from advisors that it may recommend
in the form of manager sponsored outings or events that its employees may attend.
Marquette has a Code of Ethics that puts restrictions on the attendance at these events,
including the requirement that a representative from the donor of the tickets to the
events be present at the event. Overall, the value of these outings or events is de
minimis in relation to Marquette’s overall operations.
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Transactions and Personal TradingMAI has adopted a Code of Ethics & Conflict of Interest Policy that sets forth the
standards of conduct expected of its employees and requires compliance with
applicable securities laws. The Code also addresses the issues of the confidentiality of
and the safeguarding of client information, the payment or receipt of gifts by MAI or its
employees, and the recordkeeping requirements for all of the above.
The document establishes firm policies in the following areas:
▪ Standards of behavior regarding financial and vendor relationships, securities
trading, and use of confidential information
▪ Ethics Training Program requirement for all employees
▪ Personal trading (“insider trading”) policy regarding publicly traded companies
for whom we are contracted for investment consulting services
▪ Whistleblower protection
▪ Internal enforcement of and compliance with aforementioned policies
Current employees are required to sign the Code of Ethics & Conflict of Interest Policy
on a quarterly basis, complete an annual Ethics Training Program organized by the CCO, or
his or her designee.
The firm will provide a copy of the Code of Ethics & Conflict of Interest Policy to current
and prospective clients upon request.
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Brokerage Practices Generally.
Generally, MAI clients have independently procured a custodian; nonetheless, in some
instances MAI may institute a custodial search and recommendation for a client. For
certain clients under management, MAI may recommend clients utilize the institutional
division of Charles Schwab & Co. (“Schwab”), Fidelity, TD Ameritrade or other
registered broker-dealers as custodian and broker-dealer for its clients’ trades. Factors
which MAI considers in recommending or utilizing a custodian/broker-dealer to clients
include their respective financial strength, reputation, execution, pricing, research, and
service. Ultimately the client chooses which custodian and/or broker to use. Clients that
direct MAI to use a particular broker should be aware that MAI may be unable to obtain
the most favorable execution of client transactions and that such arrangements may
result in the client paying more fees than client accounts for which MAI selects the
broker.
Clients may incur transaction costs in addition to any commissions charged by the
broker-dealer when securities traded over-the-counter are affected on their behalf
through the broker-dealer on an agency basis. Broker custody of client assets may limit
or eliminate MAI’s ability to obtain best price and execution of transactions in over-the-
counter securities.
MAI does not aggregate client trades since each client account is handled on an
individual basis. Given this practice, clients may incur higher costs per trade in instances
where MAI has the opportunity to do so.
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Client accounts are subject to review by MAI’s consultants and committee research team
on a periodic basis. The overall committee research team oversees this process and
facilitates communication among the consultants and research team on issues relevant
to our clients.
In general, the lead consultant on the relationship reviews the client’s accounts on a
monthly and quarterly basis, as well as when clients are contemplating asset allocation
and/or investment manager changes. These reviews are complemented by proprietary
manager searches and asset allocation studies.
On a quarterly or monthly basis, MAI’s consultants prepare investment reports in hard
copy or electronic form based on the client’s preferences. By the standard consulting
agreement, quarterly reports are made available to clients within a timely fashion of the
quarter end. Monthly “flash” reports are made available to clients soon after month end.
Clients are urged to compare the reports provided by MAI with those statements that
derive from the client’s custodian of record.
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MAI does not directly or indirectly compensate any non-supervised persons or entities
for client referrals.
MAI receives monetary compensation from its partnership with Operose Advisors, LLC,
for services rendered, including, but not limited to, economic analysis, investment
research and the construction of its discretionary portfolios.
In addition, Marquette may receive items of value from advisors that it may recommend
in the form of manager sponsored outings or sporting events that its employees may
attend. Marquette has a Code of Ethics that puts restrictions on the attendance at these
events, including the requirement that a representative from the donor of the tickets to
the events be present at the event. Overall, the value of these outings or events is de
minimis in relation to Marquette’s overall operations.
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MAI maintains custody of certain client assets for the purpose of assisting in bill paying
and to facilitate the transfer of assets. MAI ensures that clients’ assets are held by
qualified custodians and that the custodian is sending to both the firm and the client
directly statements of the client accounts. In addition, MAI recommends that clients
review these statements and compare data with the reports prepared by MAI for
accuracy. Finally, MAI has a surprise verification audit conducted annually on those client
accounts over which it has a custody arrangement.
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MAI offers a discretionary outsourced investment service option to its clients who want
to delegate decision-making authority for their investment program to our firm. In this
capacity, MAI would be responsible for asset allocation and rebalancing decisions, and
investment manager review and selection.
MAI’s Discretionary Committee meets on a weekly basis internally (or as market actions
warrant) to review our discretionary programs. All decisions are communicated to the
client on a timely basis, ensuring the client is always aware of what decisions have been
made and where their assets are currently invested. Monthly reporting supplements the
flow of information, helping to ensure the appropriate amount of transparency in the
investment process.
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It is the policy of Marquette to not accept any authority to vote proxies on behalf of
clients. Clients retain the responsibility for receiving and voting proxies for any and all
securities maintained in their portfolios. Nevertheless, Marquette may, in limited
circumstances, accept authority to vote proxies in connection with certain investments.
Accordingly, Marquette has adopted this policy to reflect its commitment in such
circumstances to vote all client proxies for which it exercises voting authority in a manner
consistent with the best interest of the client.
When exercising its authority, Marquette will generally vote proxies consistent with
management unless the proxy voting committee determines that voting with
management is not in the best interest of the underlying shareholder.
A copy of MAI’s proxy voting policy is available upon request.
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MAI does not bill clients six months in advance and, as such, is not required to provide
a balance sheet to clients.
MAI has never been the subject of a bankruptcy petition at any time. Neither MAI nor
its owners have any financial circumstances to report. MAI is not aware of any financial
condition that is reasonably likely to impair its ability to meet contractual commitments
to its clients.
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Additional Information/Privacy Policy PRIVACY NOTICE (Regulation S-P) Pursuant to Regulation S-P adopted by the Securities and Exchange Commission, it is
the policy of MAI to keep confidential nonpublic personal information (“information”)
pertaining to each current and former client (i.e., information and records pertaining to
personal background, investment objectives, financial situation, investment holdings,
account numbers, account balances, etc.) unless MAI is (1) previously authorized by the
client to disclose information to individuals and/or entities not affiliated with MAI,
including, but not limited to the client’s other professional advisors and/or service
providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment advisor
account custodian, etc.); (2) required to do so by judicial or regulatory process; or (3)
permitted to do so in accordance with the parameters of regulation S-P. The disclosure
of information contained in any document completed by the client for processing and/or
transmittal by MAI in order to facilitate the commencement/ continuation/ termination
of a business relationship between the client and nonaffiliated third party service
provider (i.e. broker-dealer, investment adviser, account custodian, insurance company,
etc.), including information contained in any document completed and/or executed by
the client for MAI (i.e., advisory agreement, client information form, etc.), shall be
deemed as having been automatically authorized by the client with respect to the
corresponding nonaffiliated third party service provider. Each individual and/or entity
affiliated with MAI is aware of MAI’s privacy policy, and has acknowledged his/her/its
requirement to comply with same. In accordance with the MAI privacy policy, each such
affiliated individual and/or entity shall have access to information to the extent
reasonably necessary for MAI to perform its services for the client, and to comply with
applicable regulatory procedures and requirements.
If you have any questions, please contact Brian Wrubel at (312) 527-5500 or at
[email protected].
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