New Tax Plan…So Many New Decisions To Be Made (29:46)
New tax season, new tax laws. How do you decide whether you should choose a tax preparer or a tax consultant to help you file? Along with discussing the key differences in this selection, Ryan Drake and Erin Alexander of Mariner Wealth Advisors break down how filing has changed in the first year after the tax law update, and how that may impact the way you file and your refund. In addition, they discuss common filing mistakes and how to avoid them.
Brian Leitner: Thank you for downloading this episode of Your Life, Simplified. My name is Brian Leitner, and I’ll be your host on today’s podcast. This podcast aired during tax season, and tax season brings about stress for a lot of us. It is obviously trying to get our taxes done, not only the right way but have them done by the specific deadlines such as April 15, and longer, if you extend that into August and so forth. But again, it creates stress for individuals and for those who are preparing the taxes themselves because this is just a really busy time of the year. But in light of that and understanding the feelings that people have as it relates to tax filing, what I thought we would do is talk about a few of the things that generally come up around this time, especially in light of tax law changes. And, at the time of this recording, it is the first year in which we’re filing based upon those tax changes in 2018. So, in today’s episode we’ll talk a little bit about the changes that have been made and maybe how to plan or prepare your taxes based upon those changes in tax law. We’ll also talk about mistakes that are made and about ways in which to find a professional who can help you prepare your taxes and also delineate between tax preparers and those who truly provide tax advice. So on today’s show, I’m really excited to introduce Erin and Ryan from Mariner Wealth Advisors. Thanks for joining us on the show. Erin, would you just take a minute to introduce yourself and your background?
Erin Alexander: Yes, of course, thanks Brian. My name is Erin Alexander. I’m a senior tax manager here at Mariner Wealth Advisors. Typically my job is to work with clients, tax strategies, a lot of compliance work and year-end planning.
Brian Leitner: Thanks Erin. Ryan?
Ryan Drake: My name is Ryan Drake. I work at Mariner Wealth Advisors alongside Erin. I would say my background is pretty similar. We do primarily high-net-worth, individual planning, family partnerships and investment partnerships and a lot of projections and consulting throughout the year just to help people save as much on taxes as they can.
Brian Leitner: First and foremost, I do want to thank you. I know it is the beginning of tax season. You guys are about to get very, very, very busy. So I appreciate you being here, and I appreciate your expertise. I think there are a lot of folks who can benefit from the knowledge that you guys have as they begin to dive into this year’s tax season. So Ryan, maybe we’ll start the first question with you. This is the first tax season that folks are dealing with under the new tax law. So can you provide us a broad overview on some of the changes that people need to be thinking about?
Ryan Drake: Yes, it’s kind of a daunting overhaul. You keep hearing for the last year, or year in three months or so, that this is the biggest change since 1986. And you know, for those of us in the industry, we certainly understand that. For those who are just everyday clients, though, a little bit more insight is helpful. You know, everyone’s really focused on schedule A itemized deductions and some new concepts on investor relations with what they can do with capital gains or what their charitable deductions are going to look like, which goes back to the itemized deductions. But there are a lot of nuances that have come out over the last year. And one of the biggest problems with any kind of sweeping tax reform is that the guidance can be lacking. So as we go through this podcast today, we’re going to talk about a lot of different things that you can do and think about and what a good tax consulting versus preparer will do.
But just kind of just start off to think about this. If you haven’t had a conversation with the tax consultant or even a tax preparer about what your deductions are, your income really means under this new tax law, the next month or so before everyone gets really busy, in the true avalanche or tax season, it might be a good idea to pick up someone you know in your personal network, talk to your wealth advisor, talk to someone that you trust and say, “This is what I saw last year. What should I be expecting for this coming year?” And in that, when we’ve had those conversations with clients, we’ve been able to identify some misconceptions, some misunderstandings of what the new tax law really is and is not and what it does mean to them. And Erin, do you have any thoughts on what you’ve talked about in the last year?
Erin Alexander: I do Ryan, thank you. Because of the increase in the standard deductions, you have $12,000 for singles and $24,000 for married filing jointly. You know, what does that mean as far as itemizing deductions? In the past, many people have always itemized but, now going forward, will they? And a part of itemized deductions, you know, a big part of it is your charitable donations. So now some people are thinking, if I’m limited to $10,000, for a real estate property taxes and income taxes, if I don’t have a mortgage, I’m going to automatically get a $24,000 deduction standard. So should I make any donations to charity? But I think what a lot of people don’t understand is, does the charitable deduction no longer benefit me? And I think that’s a wrong way to think about it. I mean there were some strategies around charities that we can we can talk about probably a little later. Charitable deductions are still a benefit and are still good to do for tax purposes.
Brian Leitner: Erin, that’s a great point too. And when I hear people say that the charities are now going to suffer because people aren’t getting the exact tax break they did in the past. Generally speaking, with folks I’ve worked with in the past, people are donating not simply for the tax deduction. In general, people want to give back and so while we may see, potentially, a bit of a decrease, I think for the most part, people are going to continue to give because that’s what’s in their hearts.
Erin Alexander: That’s the hope. We as a society are good people and want to do good things.
Brian Leitner: You bet. Another thing to consider is that while the IRS has reduced what you may be able to deduct as it relates to itemized deductions, as it relates to charity, there is something that’s referred to as qualified charitable distributions. And the acronym there is QCDs. And what this does is it enables folks to take distributions directly from their IRA and donate them to a charitable organization. And it has to be done in the right manner. But when$100,000, and they’re able to deduct this because it falls outside of itemized deductions. So again, that might be another strategy, but keep in mind, this strategy is only available for those who are over age 70 ½.
Ryan Drake: I think that’s a great point on society being good, and people still really caring about charitable deductions. I think several of the conversations I’ve had with clients, and with personal friends as well, is around the idea that their charity no longer matters or what they can do about it. And I think, really what’s come away from this conversation is they’re concerned that they’re going to be the losers in this new tax law regime. And the fun part of the conversation really turns to some of the other misconceptions. Like, I was talking to my friend last week and he said, “Well, I’m going to lose $20,000 in my personal exemptions and there’s no way I’m going to make up for that.” And I kind of took the stance “Well that’s probably true. Like you, you’re losing a good amount of your personal exemptions.”
But on the flip side, we have a lower tax bracket in most brackets. So what used to be 25 might be 22 now. What used to be 15 is 12. So, your marginal rate is less, and the amount of taxable income in each of those brackets is wider. So you’re really being taxed less on your same amount of income. In addition to that, your family is in a situation where you’ve historically not gotten your child tax credits. And now you’re going to get child tax credits for, in his case, $6,000. And what that does is your personal exemptions may be lost at a smaller marginal rate of 15%, let’s just say, but your tax credits are now $6,000. When you do the math on that, you’re actually ahead. So there’s just, with this sweeping tax law, there’s so many misconceptions, and it’s so hard if you’re just used to the same old, same old tax profile year to year of what you know for yourself. It’s hard to really judge where you’re at with it.
Brian Leitner: I think what’s really interesting about that is all these areas of tax law are so integrated. And so just like your friend telling you that he’s going to lose this or that. And the reality is, there’s so many different components to what you ultimately end up paying as a tax liability, whether that be the exemptions or that be some of the limitations on that had been removed on the itemized deductions as well. It really begs the question, are people looking at this truly holistically and in its entirety?
Erin Alexander: How did you get to your $6,000 tax credit?
Ryan Drake: Oh, sorry. For the clarification point of that $6,000 is arrived. They have three children that qualify. They’re under 17 years of age. They live with them all year. They provide over half their support, so they are qualifying children for the new increased child tax credit and it’s $2,000 per qualifying child. Three times two is $6,000.
Brian Leitner: Way to hold his feet to the fire on that in terms of you have a disclosure as opposed to just making facts up.
Ryan Drake: Like I said, I just don’t do it as well as she does.
Erin Alexander: I mean, do I get a $6,000 credit? How do I get this? So just….
Brian Leitner: Do you have three kids?
Erin Alexander: I do not. I’m a one. I don’t own anything. I’m standard deduction so this tax law actually is going to benefit me.
Brian Leitner: So guys, I know you come across a lot of different mistakes, whether that be on the new tax law or just mistakes you see on a regular basis. Can you talk a little bit about that so we can learn from that experience?
Erin Alexander: I’ll use an example of a friend of mine when I talk about this, but a mistake that I often see is that people get invested in something and don’t really understand what that means for you tax-wise. Like am I going to get a K-1 issued to me? Am I going to get a 1099? How is that taxable income going to be reported? So you either invest yourself or your wealth advisor gets you invested in something and you want to file your tax return. So you do it in April, and then after April, come June or July, all of a sudden you get a K-1 from some investment that you’re in that you weren’t expecting. So now you’ve got to amend your tax return. Along with K-1 investments, you know, that there might be new state filings that you’ll need. There’s also, you should research, what does this K-1 tell me? Are there footnotes? What do the footnotes mean? So making sure that you’re recording everything correctly on your return and not missing deductions.
Brian Leitner: So, Erin, great points. It’s always critical to understand not only why you’re investing in something, but what you’re investing in. So you can understand what that total rate of return is and what that total investment is from your perspective on even completing the tax returns themselves. Ryan, earlier we were talking about a particular instance as it relates to real estate and real estate investing and the opportunity in terms of where you report that on your tax return. And you have multiple options for argument’s sake as it relates to certain types of real estate. And so, you know, walking us through some of the challenges you’ve seen or areas that people should think about if they are real estate investors.
Ryan Drake: Great question. When you hold real estate, there are always great entity choices to be made. And I’m not going to try and get too technical with this, but what you usually see is someone say, “I’m going to wrap my property in an LLC.” And what they’re saying in that is they’re going to set up through some legal documents, a limited liability corporation that the title of the rental, the commercial building, whatever their real estate holding is, will be held inside that entity. You really do that for legal protection. But the other reason is for taxes, getting in and out of LLCs, taxes, partnerships is really easy. You can distribute the properties easier without tripping tax. You can play around with some of the economics between partners on who recognizes the losses until certain capital events happen.
And when you compare that with an S-Corp, which is an incorporated entity that will also provide the legal protection, S-Corps are really rigid in entity structure. And the idea with rental real estate is, sometimes you want to get in and out of it. It’s rare that you hold something for 40 or 50 years, as I’m a rental real estate person. But really the problem comes in when you try and exit that strategy with an S Corp, you end up tripping taxes a lot quicker if you want to distribute property out or break up the S Corp than you would with a partnership.
Brian Leitner: Ryan, thank you. Those are all great points. I think there’s a lot of confusion in the areas of write-offs. There are a lot of jokes that are made as it relates to the write-offs and how people can be a little too greedy as it relates to write-offs. I mean, what do you see in this area, Erin?
Erin Alexander: I think greedy is very accurate for a lot of taxpayers. You know, business expenses nowadays, everything seems to be a business expense to someone. An example I like to use are these social media influencers. I don’t know how many of you follow Instagram, but you know, everybody is their own business. So as an influencer, that’s going to be your Schedule C now on your tax return. And since your business or you in your job is influencing people per social media. You think you get to write everything up, you know, Starbucks expense, hashtag expense…
Brian Leitner: All sounds great.
Ryan Drake: Yeah, I mean the gas pump hashtag expense.
Erin Alexander: Right? I would love to be an influencer. It looks like great job. You get a lot of free stuff.
Brian Leitner: After this podcast, you very well may be.
Erin Alexander: I might be. But to be a business expense, typically it needs to be ordinary and necessary. You know, other things that people kind of mess up. We had a client where their tax attorney actually recommended to them as a tax strategy to charge themselves rent expense for using their home office, you know, as a business deduction. That’s incorrect. You cannot do that. Ryan, do you have anything you wanted to add?
Ryan Drake: I think in the line of self-employed individuals, estimated tax payments are always a confusing topic and subjects. So we have people who come in and tell us that they started a business last year. They switched from being a W2, which means that your employer’s in charge of your withholding. You never have to think about what goes to the IRS generally. And now they have this independent contracting business or consulting business and come April the following year, they don’t realize that they went the entire last year without making any kind of tax payments. So your April surprise is not a good one like you’re used to. It’s now, you owe $10 – $15,000 and for some people, that’s a very meaningful number, and it’s hard to come up with when you’re needing capital to start a business. So we like to always be in the creation of the businesses and the planning for the businesses to point that out and say, “Now that you’ve transitioned to this, this is what you should expect going forward. And one of those items is estimated tax payments.” The other thing we see is there’s a form called the 2210 that tracks whether or not you paid the right amount of estimated tax payments and when you were supposed to pay them in. A lot of prepares are lazy for lack of a nicer thing to say, and they don’t take the time to fill this out correctly and it can end up costing taxpayers thousands of dollars.
Erin Alexander: Another issue that we see a lot of tax returns or underpayment penalties because, they didn’t pay enough tax in throughout the year. And you know, kind of a big thing this year. I don’t know if a lot of people, maybe read articles about it. There’s been a lot, The Wall Street Journal, I think, just ran one this week, where they’re talking about how so many Americans are going to be underpaid this year, because the withholding tables that the IRS came out with at the beginning of the year, with the tax law change, IRS kind of redid all the withholding tables and it turns out that they’re not as accurate as they need to be. And so a lot of Americans are finding out they are going to be under withheld. They might actually owe taxes this year, which a lot of Americans are….I mean I have several friends who actually use refunds as a money saving policy.
Brian Leitner: A way in which to force our savings if you will?
Erin Alexander: Yes, which, in my opinion, is a terrible idea. You never want to give the IRS more money than it needs. Interest-free loans, they call it. The IRS has realized that it did mess up the tables, so there is going to be a lot of people under withheld, so the IRS has come out kind of with a short-term solution. For tax purposes, you’re supposed to have 90% of your taxes paid in by the tax return due date, by April 15. So now the IRS has come back and said, if you had 85% paid in, you’re not going to be charged those underpayment penalties. Though it’s not as much as I think the IRS should do, it’s helpful.
Brian Leitner: All great points guys, thank you.
Brian Leitner: Thanks again for downloading this episode of Your Life, Simplified, which is produced by Mariner Wealth Advisors. At Mariner Wealth Advisors, we are here to serve as your advocate. We help people chart a course to reach their personal and financial goals so that they can have greater peace of mind that may lead to a more fulfilling life. We do this by always putting our clients first because, as fiduciaries, we’re required to provide guidance that’s in the best interest of clients, not in the best interest of a company or shareholders or anyone else. So, as you listened to this podcast and have questions about your own financial situation or would simply like a second opinion, or even you have an idea for a future podcast, please go ahead and email us at [email protected]. If you found the information on this podcast valuable, please and share it with a friend or family member whom you think might benefit from this information. And please don’t forget to subscribe to this podcast so you don’t miss an episode. Thanks for listening. And now back to the episode.
Brian Leitner: So Ryan, I know another thing that we see quite a bit of is, you have a husband and wife and one of those individuals who works for a company in which he or she has access to a 401(k) or some sort of plan that’s company-sponsored. Whereas maybe the other spouse is working out of the house, a side business, independent contractor that you just mentioned a second ago. And that he or she doesn’t take advantage of the retirement accounts that might be out there, and that could be a mistake.
Ryan Drake: I think, absolutely. What I have seen, a lot of is, individuals just don’t realize what their options are when they leave their employers. And for 30 years, they’ve had this access to either a pension plan or 401(k) that their employer provides and now they kind of just assume that they’re stuck on their own building their investment assets through a Fidelity or Schwab account. And they don’t realize that there are several self-employment 401(k) options. There are self-employment retirement plans that are actually a deduction to them, depending on how they’ve structured their business. And what I like to tell people when they come in is, “Well you could contribute to your SEP plan, your self-employment pension plan, and the reason you really want to do that is, like your traditional 401(k), it actually lowers your tax liability. So the government is still kind of stepping in and subsidizing or assisting you in getting to your retirement goals.”
Brian Leitner: You guys, one of the interesting things I think that’s coming out of this conversation is that there’s a lot that goes on throughout the tax year. And I think that people look at the tax year, you know, January through December. And, oh by the way, there’s this event on April 15 where I need to file my taxes and get that done. And I think that’s a bit of a misnomer. If you think about all the things that happen within someone’s life throughout the year and to not engage with someone as it relates to their tax situation, to be able to take advantage of opportunities or mitigate issues as that tax year goes on. Because once you hit December 31, you no longer have that opportunity to make those decisions. And I know, just prior to us recording this, we were talking about the conversations that people are having, today with their tax advisors and wonder if there’s something we can do from last year? And that window has almost, for all intents and purposes, closed because they should have been having these conversations throughout the year like you guys do with clients.
Ryan Drake: I think that’s a great point. And what I would like to emphasize as you leave this podcast thinking nothing else other than, in 2019, what do I need to do? You need to be focused as a person concerned with your tax situation and profile with income events and with life changing events. So the best time to talk to your advisor is really anytime you’re uncomfortable with an issue, number one. But number two, if you know you’re getting a large bonus, well maybe you should talk about how that withholding should be or what you could do with that. And it’s a great conversation for your wealth advisor or your tax consultant. Or if you’re getting married, that’s a great opportunity to bring in a tax person and talk about, okay, well what are your finances going to be when you’re married? What are your retirement savings going to look like? What are your tax returns going to look like going forward? If you’re having a child, again, now there’s this $2,000 credit instead of one with greater income thresholds before you lose that benefit. So anytime you have these life events, or you have these income events, whether there are loss of a job, a better job, a promotion in your current job, these are great times to really work with your advisor.
Erin Alexander: To add onto that, another big reason to, reach out to your tax advisor is anytime there’s a big tax overhaul, which happened in 2017.
Brian Leitner: So to take that a step forward, once you’ve completed the tax insurance. If someone is working with his or her advisor, or maybe even doing taxes on their own. I mean generally speaking, whoever it is who prepared that return, signs off on that return and sends it in. But what kind of dialogue or opportunity is there after all these documents have been produced? Again, I think a lot of times they’re big scary documents and everyone just wants to electronically file these or put them in the mail and be done with it. But isn’t there an opportunity after all of this data has been collected and put through this formula, if you will? Is there an opportunity at that point?
Ryan Drake: I think so. And even if you can’t go back in the past and change what happened, you can always be more active on what’s going to happen. And I think it was on a previous podcast from this series where someone was talking about, it’s always a great idea to know what’s coming up and always to be proactive so that you can limit surprises. And if you have an idea of whether your financial plan is working for you, taxes play a big part of that. And the surprise mitigation is a wonderful tool the tax consultants can bring to the table with that. And kind of what I mean by that last confusing sentence is, if you unpack it, and you take a step back and say, my financial plan for 2019 is to do these three things. Are those three things tax-focused? And not everything in life needs to be, but if my goal is to save $20,000, what’s the most tax-efficient way to save $20,000 and not only today, but in the future?
Depending on what stage of life you’re in, you might need that $20,000 in 30 years. You might need it at five. In addition to that, if I am going to save for my kid’s college tuition, or I know I have my child’s college bills coming up soon, and I’m planning on helping with those, is it time to start a 529? Have I already done that? Am I at my limit for those items? So as you get all of these documents prepared, and you sit down and talk about your tax return with your preparer or hopefully your consultant and advisor, you can ask the questions of, “What could I have done differently for next time?” As well as, “Here’s what my next year looks like and what my goals are, how can I fit some tax efficiencies into those?”
Brian Leitner: Great points. The two that I took away immediately was being proactive. I think a lot of us are reactive as it relates to our taxes. As I mentioned, you know, we get the return done and we want to get it out and we want to file it immediately. But what clues can we find in there and how do we have that conversation throughout the year to really affect change and implement strategies where appropriate. The other is, of course we all pay money and taxes, all of us, so some of us pay more than others. To have a plan as it relates to taxes and be proactive just make sense. It’s like anything else.
Ryan Drake: Agreed.
Brian Leitner: So Ryan, for those who are listening and are not currently working with a tax advisor, can you talk a little bit about what to look for in a tax advisor? Maybe the difference between what you see on TV, like a tax preparer versus a true tax consultant, what that might look like?
Ryan Drake: I think that’s a great question and something that’s near and dear to everyone’s heart. You want to make sure that if you’re going to pay someone to help you with something, you want someone who is qualified, and you want to know that they’re doing what you need them to do. And with taxes, that’s just so complicated. In college I had a funny professor and one of the most memorable things he said is, “You know, taxes aren’t that complicated if you have a critical mind and you can read instructions.” And what he meant by that is, it’s easy to get a form right. You can look at a document that’s got tax numbers, read the instructions to that document and the 1040 that you reported on, or whatever form you reported on, and you can get technically right answers. What a tax preparer will do is likely that. You will take your documents, and you’ll sit in front of him or her, and that person will give you 30 minutes of his or her time and will put numbers in boxes and will likely be correct at the end of the day. If you take a step back and you find a tax consultant or advisor, someone who really lives and breathes taxes and loves helping people, what they’re going to do is they’re going to get you a right answer that’s also the most right answer. And in today’s world, that sounds rather funny to say, but it’s absolutely true. Just because you’ve got the same fact pattern with client X and Y, they can have wildly different tax answers. If you sit down with someone who looks at it and takes a more holistic approach, looking at the entire forest instead of just the leaves on the trees when you’re avalanched in the documents. And how are you finding that person is a great question. How you find anything really word of mouth, referrals. Just having a CP in your name that just means you pass the test and it’s a good first start. But I know a lot of people like my father who taught me taxes when I was 14, and he gets it as well as some of the people I’ve helped develop through their careers. But, really, word of mouth is the best way to do it.
Erin Alexander: And I’d say, what’s so great about Mariner Wealth Advisors is that, we kind of have this all in-house where we work so closely with the wealth advisors, and the wealth advisors know the clients. What their financial goals are, what they did throughout the year. For two teams to talk to each other is really beneficial. So I’d say, you know, a great place, I mean if you have to find a CPA is to talk to your wealth advisor. A lot of them have relationships with CPAs. So I think they’re a really good place to start for recommendations.
Brian Leitner: Guys, that’s terrific. As we wrap up the show, we wrap it up the same way each time. And that’s by asking what your worst financial mistake has ever been. So Ryan, we’ll start with you.
Ryan Drake: I have children. I love them. No no no. In all seriousness, they are a sunk cost and a money pit, but they are lovely little critters. The worst mistake I’ve really ever made financially is, I bought a home before I should have. At 25 tender years of age, I had just gotten my first big boy job. My wife had just graduated, and we knew without a doubt she was going to be an educator. Then ‘08 hit with the financial recession, and we bought our house anyway, and she didn’t have a job and they basically let a bunch of teachers go in our area, and she still doesn’t have an educator job. So for many years we were, we were under for that, but we fought her way out of it. But, hold off on buying things that you shouldn’t.
Brian Leitner: And just to be clear, your kids, are they listeners of the podcast?
Ryan Drake: Uh, no, no, they’re, they’re eight, six and two.
Brian Leitner: Erin?
Erin Alexander: I was talking to Ryan about this earlier. Trying to figure out, what my biggest financial mistake was, and I was claiming I never had one. Then it occurred to me that, a few years ago, I basically was living off no budget. Having no idea really where my money went until I finally straightened up and got myself a wealth advisor. And now, I’m on top of it. I know my retirement accounts are all set up. I have my investments. So a little nest egg I’ve started. So my biggest failure turned probably into my greatest achievement.
Brian Leitner: Well that’s great guys, thank you very much for sharing that. We’d rather ask you that question versus you know, the best financial decision you’ve ever made. So guys, again, I know it’s a busy season, it’s a busy time for you, but thank you very much for taking the time to join us. And I also want to thank our listeners for taking the time to listen to this podcast. For those of you who are listening and have a questions about this topic or would like to provide us topic ideas, please go ahead and feel free to email us pod[email protected]. And if you’ve liked this podcast, please go ahead, maybe tell one or two people about the podcast and where they can download this wherever they listen to podcasts themselves. Thank you very much.
This transcript is limited to the dissemination of general information pertaining to Mariner Wealth Advisors’ investment advisory services and general economic market conditions. The views expressed are for commentary purposes only and do not take into account any individual personal, financial, or tax considerations. As such, the information contained herein is not intended to be personal legal, investment or tax advice or a solicitation to buy or sell any security or engage in a particular investment strategy. Nothing herein should be relied upon as such, and there is no guarantee that any claims made will come to pass. Any opinions and forecasts contained herein are based on information and sources of information deemed to be reliable, but Mariner Wealth Advisors does not warrant the accuracy of the information that this opinion and forecast is based upon. You should note that the materials are provided “as is” without any express or implied warranties. Opinions expressed are subject to change without notice and are not intended as investment advice or to predict future performance. Past performance does not guarantee future results. Consult your financial professional before making any investment decision.
Mariner Wealth Advisors (“MWA”), is an SEC registered investment adviser with its principal place of business in the State of Kansas. Registration of an investment adviser does not imply a certain level of skill or training.MWA is in compliance with the current notice filing requirements imposed upon registered investment advisers by those states in which MWA maintains clients. MWA may only transact business in those states in which it is notice filed or qualifies for an exemption or exclusion from notice filing requirements. Any subsequent, direct communication by MWA with a prospective client shall be conducted by a representative that is either registered or qualifies for an exemption or exclusion from registration in the state where the prospective client resides. For additional information about MWA, including fees and services, please contact MWA or refer to the Investment Adviser Public Disclosure website. Please read the disclosure statement carefully before you invest or send money.