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| M2 Financial LLC
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| CRD # | 288829 |
| SEC # | 801-135373 |
| CIK # | 0002104658 |
| AUM | 158.0 M (2026-05-12) |
| Employees | 6 (100% Investors, 0% Brokers) |
| Fees | |
| Minimum | |
| Phone | 661-347-0202 |
| Address | 27441 Tourney Road Valencia, CA 91355 |
| Source | [IAPD] [EDGAR] [Website] [Twitter] |
| Total AUM ($M) |
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| Fees and Compensation — Form ADV Part 2A (5/12/2026) [Brochure] |
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Item 5: Fees and Compensation
A. Fee Schedule
Separately Managed Account (“SMA”) Services Division
Lower fees for comparable services may be available from other sources.
SMA Portfolio Management Fees (Tiered Fee Schedule**)
Total Assets Under Management Annual Fees
$0 - $500,000 1.50%
$500,001 - $1,000,000 1.25%
$1,000,001 - $3,000,000 1.00%
$3,000,001 - $10,000,000 0.65%
$10,000,001 – And Up 0.50%
*fees are annualized and applied to the aggregate household account balance
**When using tiered rates, the portfolio management fee is calculated by applying the different rates to
correlating portions of the portfolio. The stated rate is applied for all dollars within associated range. Only
the value of dollars in that breakpoint range are calculated. See the example below:
(annualized) –Total Value $1,250,000: First $500,000 fee is 1.50%= $7,500, next $500,000 fee is 1.25%=
$6,250, next $250,000 fee is 1.00%=$2,500.
Legacy Fee replaces Performance Based Portfolio Management Fee
M2 has retired/discontinued its Performance Based Management Fee services to qualified clients and has
transitioned those accounts to a flat 0.50% annual fee with a minimum fee of $1,000 per quarter. All M2 Fee
Structures are negotiable.
The Legacy Fee structure is assessed on a Quarterly Fee of 0.125% on the rolling three-month average
account value (0.50% annualized), with a minimum fee of $1,000 per quarter charged in arrears at the end
of each calendar quarter.
Qualified Client Requirement: To have been eligible for the Performance Based Management Fee, the Client
must be a qualified client, as defined by the Securities & Exchange Commission, which as of the date of this
agreement means: (i) A natural person who, or a company that, immediately after entering into an advisory
contract has at least $1,000,000 under the management of the investment adviser; or (ii) A natural person who,
or a company that, the investment adviser reasonably believes prior to entering into the contract, either has a
net worth of more than $2,100,000, exclusive of primary residence and net of any debt secured by Client’s
residence taken out in the last 60 days except for purchase of the residence.
Performance fees will only be charged in accordance with the provisions of the California Code of Regulations
Section 260.234.
Capital-Force ETF - Fund Clients
Non-Unitary Fee (defined below) ETF Fund Clients are responsible for all of expenses, including Advisory
Fees, costs of transfer agency, custody, fund administration, legal, audit and other services, interest, taxes,
brokerage commissions and other expenses related to the execution of portfolio transactions, paying for its
sublicensing fees related to the tracking index, where applicable, any distribution fees or expenses, and
extraordinary expenses. There may be ETF Fund Clients that pay M2 an annual unitary fee (“Unitary Fee”)
at the rate set forth in the Fund Offering Documents.
M2 seeks to serve as investment manager to one or more public U.S. registered ETFs. While each ETF Fund
will have its own investment strategy and other specifications, the arrangements between each Fund and M2,
will generally be the same. In its role as investment manager, M2 allocates Fund assets to a designated sub-
adviser. M2 will receive monthly management fees from each ETF Fund. M2's fees are either calculated
based upon a 365-day year or as stipulated in the Fund's offering documents /prospectus and are exclusive
of brokerage commissions, transaction fees, and other related cost and expenses which shall be incurred by
the ETF Fund either directly or indirectly through the ETF Fund's NAV or expenses. M2’s fees will vary
depending on various factors, including the type of service offered and the strategy and complexity utilized.
The fees and compensation associated with the investment advisory services M2 may offer are detailed
below. Please refer to and review carefully each ETF’s applicable Prospectus for a more detailed list of the
fees, charges, and expenses along with risks and other important disclosures prior to making any investment in
such an Investment Product
ETF Unitary fee: M2 provides or causes to be furnished, all supervisory, administrative and other services
reasonably necessary for the operation of the ETF Fund(s) which are part of the Capital-Force ETF(s) issued
by the Trust. In this structure, M2 is responsible for each Unitary Fee ETF Fund Client’s expenses, including
the cost of transfer agency, custody, fund administration, legal, audit and other services, and licensing, but
excluding fee payments under the Unitary Fee Advisory Agreement, interest, taxes, acquired fund fees and
expenses (if any), brokerage commissions and other expenses connected with the execution of portfolio
transactions, distribution and service fees payable pursuant to a Rule 12b-1 plan, if any, and extraordinary
expenses. The Advisory Fees paid by ETF Fund(s) are not negotiable and stipulated in each ETF Fund’s
Offering Documents (Prospectus).
The Supervision and Administration Agreement also requires M2 to provide investment advisory services
to the Capital-Force ETFs pursuant to an Investment Advisory Agreement. Both the Supervision and Fund
Administration Services Agreement and the Investment Advisory Agreement are subject to annual review
and approval by the members of the Trust’s Board of Trustees. Each Capital-Force ETF pays a fee
(“Management Fee”) in return for providing investment advisory, supervisory and administrative services
under a unitary fee structure. The fee is based on the daily net asset value (“NAV”) of each Capital-Force
... |
| Account Minimums and Types of Clients — Form ADV Part 2A (5/12/2026) [Brochure] |
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Item 7: Types of Clients
Separately Managed Account (“SMA”) Services Division
For its SMA accounts, M2 seeks to provide advisory services to the following types of clients:
• Individuals
• High-Net-Worth Individuals
• Pension and Profit-Sharing Plans
• Charitable Organizations
• Corporations or Business Entities
• There is no account minimum for any of M2’s SMA services.
Capital-Force ETF Division
M2 is in the registration process to provide portfolio management services to SEC registered Exchange Traded
Funds (“ETFs”). In connection with the marketing of Capital-Force ETF Funds, certain M2 employees review the
ETF portfolios with registered broker dealers and investment advisers and discuss how the ETF funds could be
added to their client’s portfolio to optimize the investors’ investment objectives. No fees are charged in
connection with the portfolio marketing of the registered ETF funds, and the broker dealers or investment advisers
have not entered into any investment advisory contract or otherwise with M2. |
| AUM Breakdown | Accounts | AUM ($M) |
|---|---|---|
| By Client Type | ||
| (a) Individuals (other than high net worth individuals) | 36 | 6.6 |
| (b) Individuals (high net worth individuals) | 11 | 4.2 |
| (c) Banking or thrift institutions | 0 | 0.0 |
| (d) Investment companies | 2 | 103.5 |
| (e) Business development companies | 0 | 0.0 |
| (f) Pooled investment vehicles | 0 | 0.0 |
| (g) Pension and profit sharing plans | 5 | 40.1 |
| (h) Charitable organizations | 1 | 3.5 |
| (i) State or municipal government entities | 0 | 0.0 |
| (j) Other investment advisers | 0 | 0.0 |
| (k) Insurance companies | 0 | 0.0 |
| (l) Sovereign wealth funds and foreign official institutions | 0 | 0.0 |
| (m) Corporations or other businesses not listed above | 2 | 0.2 |
| (n) Other | 0 | 0.0 |
| Total | 57 | 158.0 |
| By Discretionary | ||
| Discretionary | 49 | 144.0 |
| Non-Discretionary | 8 | 14.0 |
| Total | 57 | 158.0 |
| By Non-United States Persons | ||
| Non-United States Persons | 0.0 | |
| United States Persons | 158.0 | |
| Total | 57 | 158.0 |
| Firm Profile (Form ADV) | |
|---|---|
| Discretionary AUM | $0.0B |
| Serves | Institutional, Retail |
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|---|---|---|
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