Description of Moneta
Moneta provides financial planning, tax planning, estate planning, risk management, retirement planning, business
succession consulting, concierge services (e.g., bill pay and bookkeeping), and portfolio management services to
high-net-worth families, individuals and institutional clients (defined contribution plans, defined benefit plans,
endowments and other corporate funds). As of the date of this brochure, Moneta is comprised of twenty-six Partner-
led teams, as well as a house Moneta Advisory Services Team supervised by the CEO and Board Chair, (collectively
the “Teams”). Each of the Teams provides varied financial and investment advisory services to their clients. The
services that Moneta provides to our institutional clients include plan consulting and design, participant education
and enrollment, investment policy statement development assistance and investment menu selection. Moneta also
provides both discretionary and non-discretionary advisory services to its retirement plan clients.
Moneta was founded with the singular purpose of assisting clients in planning and managing all aspects of their
financial affairs. Due to the demands of everyday life, most people (and many businesses) benefit from this kind of
professional assistance. Moneta believes that when it comes to individuals, proper financial advice requires specific
goals and objectives, and, in many cases, a comprehensive review of a client’s assets, potential income, applicable
tax rates (including estate taxes), available retirement benefit programs, insurance contracts, wills and trust
agreements and other related matters. The most comprehensive plan, however, is no more than an expensive
academic exercise unless it leads to action. Moneta operates on the premise that our Teams should be actively
involved in implementing recommendations. We take pride in providing superior quality and unwavering personal
service while attempting to maximize our clients’ abilities to achieve their financial goals and objectives.
The evolution of Moneta is a historical microcosm of the independent investment adviser industry as a whole. Moneta
began as a handful of “sellers” of commissioned insurance products, operating under various iterations of First
Financial Group. Early in the industry, the financial sector remained rife with conflicts of interest, offering financial
professionals little economic incentive other than generating new transactions. Moneta’s vision was to escape the
constraints created by those conflicts, reinventing Moneta’s service model and in doing so became a pioneering
member of the independent investment adviser community focusing on individuals and families. Moneta was one of
the first “full service” comprehensive financial planning and investment advisory firms in the St. Louis area. It is from
these roots that the notion of the “Family CFO” sprang. In general, Moneta strives to provide the same breadth of
services that a Chief Financial Officer (“CFO”) provides to any ongoing business concern; we have simply boiled
down the CFO job to the individual client level.
Today, Moneta has grown to become a leading provider of investment advisory services with approximately 501
employees and approximately $37.4 billion in regulatory assets under management as of December 31, 2023.
Moneta also advises on assets that are not includable for SEC reporting purposes in its assets under management
total, but which are subject to Moneta’s billing practices and for which Moneta provides investment advisory
services. In this regard, as of December 31, 2023, Moneta advised on a total of approximately $42.1 billion in
assets (“AUA”).
Moneta is governed by its Board of Managers, which is headed by Chief Executive Officer and Board Chair Eric
Kittner and supported by the following Executive Officers named in Moneta’s ADV Part 1: President and Chief
Operating Officer, Keith Bowles; Chief Compliance Officer, Adam Kruger; Chief Platform Officer, Amanda Barrale;
Chief Investment Officer, Andrew Kelsen; Chief Global Market Strategist, Aoifinn Devitt; and Chief Talent Officer,
Bethany Wilkinson. This group, alongside other members of Moneta’s Enterprise Service Team, provides the
leadership and structure that allows Moneta to focus exclusively on the many needs of its clients. Mr. Kittner, as
Moneta’s CEO, is also ultimately responsible for supervising the Teams.
Moneta is a wholly owned subsidiary of Moneta Group, LLC (“Moneta Group”). Moneta Group is wholly owned
by the Moneta Partners and Professional Staff. As a result of our independence, and “open architecture”, we are
agnostic to the type of investments selected for client portfolios. Our multi-criteria investment selection process
(described in more detail in Item 8) forms the primary basis upon which our clients’ investment portfolios are
constructed.
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Fiduciary Status
Moneta is a federally registered investment adviser. As such, Moneta provides investment advisory/management
services in a fiduciary capacity in accordance with, and subject to being deemed a fiduciary pursuant to, the Advisers
Act, the Employee Retirement Income Security Act of 1974 (“ERISA”), and such other governing laws as may be
applicable within any particular client relationship.
Family CFO and Family Office Services
Moneta provides services to high-net-worth families and individuals. These services can be best defined as giving
continuous financial and investment advice, and related services, to individuals, spouses and families based on their
particular needs. Specific client investment strategies are crafted to focus on the client’s specific goals and objectives.
In this regard, Family CFO and Family Office services can include, but are not limited to, the following:
Comprehensive Financial Management
In general, services will begin with a comprehensive financial management plan tailored to each prospective
Moneta client. The planning process is organic and involves a close review of existing financial positions of each
prospective client and an investment plan for each client. However, each client’s situation is unique and, as a result,
financial plans vary in length and scope and in certain instances are foregone in their entirety. Once the financial
plan is mutually agreed upon by the applicable client and the client’s Team, the Team begins to implement the plan.
On an ongoing basis an advisor will review and update portions of the financial plan, meet with the client and bring
attention to any issues deemed worthy of closer review.
In order to fully prepare a financial plan, the Team engages in a series of meetings with the prospective client. In
these meetings, the Team reviews the client’s goals and investment objectives, and formulates a plan that addresses
some or all of the following key issues: 1) Financial Management; 2) Financial Independence; 3) Money
Management; 4) Income Tax Planning; 5) Investment Planning; 6) Risk Management; 7) Estate Planning; and 8)
Business Succession Planning. Our Teams focus on the specific personal goals articulated by the client, including,
for example, how to achieve and maintain financial independence, funding for children’s college education and/or
providing adequate funds for dependents in the event of death or disability. Each prospective client is expected to
provide complete information in all relevant areas. Careful consideration is given to subjective factors such as a
client’s prior investment experience, ability and desire to manage their assets, risk tolerance and familiarity with
various investment vehicles. The goal is to determine the optimum course of action necessary to realize the client’s
short term and long-term objectives. The Teams will then develop and propose an investment plan that includes an
asset allocation model specifically designed to meet the client’s goals. Moneta’s portfolio allocations typically
include a mix of the following: taxable, municipal and government bonds; cash and cash equivalents (e.g., money
markets and certificates of deposit); large cap, mid cap, small cap and international equities; and a variety of
alternative investments.
Investment-Only & Financial-Only Planning
Moneta recommends its full financial planning services only to those clients whose needs and financial circumstances
warrant such services. In other instances, for those clients who either do not need or desire comprehensive financial
planning services, Moneta offers investment-only services. As part of this service, an advisor will analyze the client’s
current investment portfolio and will, as necessary, make recommendations relative to the portfolio and its holdings.
Those recommendations are based on the client’s stated investment goals, objectives and risk tolerance.
Similarly, some clients benefit from only receiving financial planning services. As part of this service, a Team analyzes
the client’s financial situation and prepares a financial plan for the client but does not provide specific investment
recommendations or ongoing investment advisory/management services to the client.
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Investment Supervision and Monitoring
Investment services are based on the recommendations of each individual Team. Teams then continuously monitor
those investments that are subject to our management to ensure conformity with the client’s goals and objectives.
These investment-related services are provided on a non-discretionary, discretionary or combined basis.
Non-Discretionary Investment Management
Moneta Teams can manage client assets on a non-discretionary basis and, as such, each client must
approve each recommendation before a specific trade can be placed. Following the initial implementation,
the Team reviews and monitors the portfolio for adherence to the agreed-upon asset allocation model.
Recommendations will vary between, and within, Teams based on the client’s particular needs and goals.
From time to time, the Team will recommend changes to the underlying investments to rebalance the
portfolio, recommend removing investments that no longer meet the client’s goals and objectives, or to
address other changes to the client’s financial situation, and/or to add or remove investments based on
Moneta’s Investment Department’s recommendations.
With respect to Family CFO clients, as of December 31, 2023, Moneta reported non-discretionary
regulatory assets under management of approximately $8.9 billion. For this same period, Moneta’s non-
discretionary
AUA with respect to Family CFO clients was approximately $12.8 billion.
Discretionary Investment Management
Moneta Teams can provide discretionary investment management services, where the client delegates full
investment authority to Moneta to determine which securities are to be bought or sold in the client’s portfolio.
Teams managing discretionary accounts have the authority to invest client assets in stocks, bonds, mutual
funds and other investments as deemed appropriate for the individual client. Discretionary clients have the
right to impose reasonable restrictions on Moneta’s authority to purchase certain investments for the
portfolio. Changes to the portfolio investments are made based on, among other factors, changes in
general market conditions, factors affecting the specific investments, or to rebalance the portfolio or
incorporate changes in the client’s circumstances. However, because each client’s portfolio will generally
contain a different mix of investments, and Teams have the ability to trade their clients’ holdings independent
of one another, client orders for the same security will not always be submitted at one time, which can result
in variances to prices received by clients buying or selling the same security. Moneta provides each
discretionary client with periodic reports detailing all investments within the portfolio for the prior reporting
period. With respect to Family CFO clients, as of December 31, 2023, Moneta reported discretionary
regulatory assets under management of approximately $24.7 billion, which is also representative of
Moneta’s AUA for the same period with respect to these clients.
Professional and Developing Athlete
Some Moneta Teams provide financial planning and career strategy advice that is tailored to the unique and
complex financial situations of professional and developing athletes. This service includes educational coaching and
planning around common challenges for athletes, which can include coordination of any legal entities to receive
income, tax consultation when earning compensation across multiple states or countries, analysis of cash flows for
name-image-likeness licensing and/or product royalties, and expense coordination of agents and licensing. This
service is often paired with either the Comprehensive Financial Management or Investment Supervision services.
Institutional Intelligent Portfolios
Some Moneta client accounts are managed utilizing the Schwab Institutional Intelligent Portfolio platform. For
additional information and disclosures on this, please see Item 21.
Retirement/Pension Plan Services
Moneta provides fiduciary management and investment advisory services, and non-fiduciary education and
consulting services to a variety of retirement plans, pensions and profit-sharing clients, including, but not limited to,
the following: 401(k), 403(b), 457(b) and 409(a) plans; defined benefit plans; balance forward plans; and profit-
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sharing plans. Moneta is engaged by plan fiduciaries to define the investment options available to the plan as a
whole, the menu of options available to the individual plan participants, or to select plan investments.
More specifically, Moneta provides the following services:
Non-Discretionary Retirement Consulting
Moneta offers non-discretionary investment advisory services to qualified retirement plans under Section
3(21) of ERISA, or to non-qualified retirement plans under a non-discretionary engagement. As a Section
3(21) investment advisor or non-discretionary advisor, Moneta’s typical service offering includes consulting
with and advising the plan fiduciaries on the development of an Investment Policy Statement designed to
reflect the investment objectives, policies, constraints and risk tolerance of the plan. Moneta is responsible
for making investment recommendations to the plans regarding the fund options made available to plan
participants. The plan fiduciaries are ultimately required to exercise their discretion to act upon the
investment options recommended by Moneta. With respect to non-discretionary retirement plan clients, as
of December 31, 2023, Moneta reported no regulatory assets under management relative to 3(21) plan
clients, and $142 million for non-ERISA plan clients. For this same period, Moneta’s AUA for non-
discretionary Retirement/Pension Plan Services client assets was $1.05 billion.
Discretionary Retirement Management
Moneta offers full discretionary investment management services to qualified retirement plan clients under
Section 3(38) of ERISA. As a Section 3(38) ERISA investment manager, Moneta deploys a distinct and
customizable Investment Policy Statement which is subsequently approved by the plan fiduciaries. As the
discretionary investment manager, Moneta is solely responsible for determining the appropriate investment
options available to plan participants and/or the plan, as applicable. Moneta works with the plan’s third-
party administrator and qualified custodian to ensure the selected investment options are available within
the plan. Moneta is responsible for the ongoing monitoring of investment options and implementing changes
as necessary. Plan fiduciaries are given notice of changes to existing allocations and/or menu choices;
Moneta implements those changes as promptly as practicable in coordination with the plan’s third-party
administrator and plan custodian. Consent of the plan for investment option changes is not required. With
respect to discretionary retirement plan clients, as of December 31, 2023, Moneta reported discretionary
regulatory assets under management of approximately $3.4 billion, which is also representative of
Moneta’s AUA for the same period with respect to these clients.
Collective Investment/Retirement Advocate Funds Sub-Advisor
Moneta acts as the sub-advisor for five (5) Retirement Advocate Funds (“RAFs”). The Matrix Trust Company is the
Trustee and custodian of the RAFs and provides the general administration. Matrix Trust Company engages the
advisory services of Moneta to provide asset allocation targets, fund recommendations, and occasionally, direction
to rebalance outside of the quarterly regimen. Currently, the availability of the RAFs is limited to Moneta’s institutional
401(k) and retirement planning clients. Moneta uses a proprietary investment allocation methodology to manage
the RAFs’ assets. The RAFs have five model strategies: Conservative, Moderately Conservative, Moderate,
Moderately Aggressive and Aggressive. Each model strategy employs a unique portfolio allocation that is assessed
against an appropriate performance benchmark chosen by the Investments Department. Plan participants select the
model strategy best suited to their individual investment goals and objectives. Moneta does not receive fees for its
sub-advisory services to the RAFs but does receive customary advisory fees from plans (or participants, as
applicable) for its advisory/management services to the plan, but these fees are independent of any plan’s use of
the RAFs.
Non-Fiduciary Consulting Services
Moneta provides plan participant enrollment, educational, and other consulting services. Enrollment education
discusses the benefits of enrolling in the plan as a retirement savings vehicle and best practice strategies relating to
saving. The educational presentations are designed to assist participants in evaluating their specific goals and
objectives and how to select the investments best suited to help them attain those goals. This education also provides
a review of various asset allocation models and how asset allocation affects investment results.
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Moneta’s consulting services on plan benefits include: project planning, facilitating benefit committee meetings,
consulting on fiduciary duties, consulting on vendor management and fee benchmarking and consulting on industry
trends.
Institutional Investment Management Consulting
Moneta provides both investment management and investment consulting services to large institutional clients,
endowments, foundations and charitable organizations.
Other Services
In addition to the above-referenced advisory services, our Teams will from time to time provide the following non-
advisory services to clients on a case-by-case basis as agreed upon by Moneta and the client:
Insurance Review and Sales
When engaged to do so, Moneta will review and, as appropriate, recommend changes or additions to a client’s
health, life, disability, long-term care or other insurance coverage needs. Clients are free to follow or decline such
recommendations.
Death Claims Services
Moneta can assist clients in processing death claims. Moneta provides services such as asset valuation and re-titling
of assets distributed to the estate beneficiaries. Please see Item 5 herein regarding applicable fees.
Bill Pay, Bookkeeping & Other Concierge Services
For clients who desire bill payment, bookkeeping, or other concierge services, a Team can provide such services
itself or through Moneta’s centralized resources. Fees for these services are established on a client-by-client basis
and can be structured as hourly or flat fees.
Securities Class Action Claims
For clients that have a brokerage account that contains securities, there may be an opportunity to be party to legal
action against the company that issues any security if they allegedly harmed their investors. Such legal filings
(broadly, “Securities Class Actions”) can result in financial relief paid to the owners of the security who are party to
the Securities Class Actions, if a court concludes that the issuing company did harm the investors. Moneta contracts
with a third-party service provider to process Securities Class Actions claims on behalf of its clients that opt in for
such service. Unless the Client completes the Moneta Class Action Claim Filing Election Form and opts in for this
service, the Client will retain sole and absolute authority and responsibility for pursuit of any Securities Class Actions
for any securities the Client owns. Moneta makes no guarantee of the success of any such Securities Class Actions
against any issuer, nor a guarantee of any financial relief or compensation to any Client. The service typically does
bear a contingent cost to the client, where a fee of roughly 18.5% is charged by the third party service provider only
if proceeds from any issuer are successfully acquired for Client by that service provider.
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