Kostrzewski, Mark Benedict

The firm provides advisory referral services to individual clients, including both non‑high‑net‑worth and high‑net‑worth individuals, by referring them to a non‑affiliated, SEC‑registered investment adviser for portfolio management. It does not itself manage client investment accounts, does not charge clients an asset‑based advisory fee, and does not participate in wrap fee programs.

When evaluating a prospective referral, the firm considers a client’s investment objectives, account size, time horizon and risk tolerance to determine whether the third‑party manager’s approach is appropriate and documents the required solicitor disclosures. Ongoing engagement typically consists of consulting and periodic reviews while the third‑party adviser retains day‑to‑day investment discretion and provides client reporting; the firm is compensated by the third‑party manager through solicitation/referral arrangements rather than directly charging clients a percentage‑of‑AUM fee.

A notable feature of the firm is its principal’s concurrent role as president of a full‑service insurance brokerage, and the adviser discloses and seeks to manage the resulting conflicts of interest related to insurance sales and referral compensation. The brochure also discloses a past regulatory notification from the state insurance regulator concerning certain annuity contracts that resulted in a modest administrative penalty.