M Holdings Securities, Inc.: Manager Rating and Record

Insurance-dedicated funds managed by M Financial

Funds and platform series in our database that file a Form D under an insurance-dedicated name and are managed by this adviser. Gross assets are as reported in the latest Form ADV that lists each fund.

Why M Holdings Securities, Inc. has two stars

M Financial runs USD 3.2 billion of regulatory assets and has been registered with the SEC since 2000. Its Form ADV lists three matters. Two concern M Holdings Securities itself, the most recent brought by the SEC in 2025; the other concerns another company in its group or an individual and counts for less. Its one rated insurance-dedicated fund has two stars. In that fund little or none of the assets were valued last year by a firm outside the group, and on its own that rules out five stars.

The rating looks only at the areas below, which matter to a family holding this manager's funds through a private placement policy. Past returns play no part: these funds do not report them in their SEC filings, and they say little about what a policy will earn.

Conduct and regulatory record

What regulators and courts have recorded against the manager, and for platform series against the platform, as the advisers report it to the SEC. Several proceedings on one set of facts count as one matter. Recent and serious matters count most, matters of other companies in the group count for less, matters of individuals are weighed by the person's role and their bearing on the business, and the size of the firm is taken into account.

Reported controls

What the adviser reports to the SEC for the fund: whether the accounts are audited every year by an accountant registered with the PCAOB and subject to its regular inspection, whether audited statements go to investors and what the audit opinion says, whether the administrator and custodian are outside the adviser's group, and what share of the assets was valued last year by a person not related to the adviser.

Depth and experience of the manager

The assets the manager runs, its investment staff and how long it has been registered with the SEC.

PPLI.comManager Rating

Investor experience. What policyholders, insurers and advisers tell us is shown separately and never changes the stars. A factual point they raise is checked against the filings, and if it holds, the data is corrected. We never publish names. Tell us about yours

The rating expresses the opinion of PPLI.com on the date shown. It is not a statement of fact about the fund or its manager, not a credit rating, not a forecast of returns and not investment advice. Read about the rating.

Registration and size

Identity

Legal nameM Holdings Securities, Inc.

SEC registrationRegistered investment adviser, 801-57304 IAPD

CRD number43285

Latest Form ADV27 October 2026 ADV

Registered with the SEC since14 March 2000

Assets and staff, as filed

Regulatory assets under managementUSD 3,206,000,000

Of which discretionaryUSD 1,972,000,000

Employees1,442

Of which investment advisory staff171

Regulatory assets are calculated under the SEC's Form ADV instructions and include all funds and accounts the adviser manages, not only those open to insurers. Figures come from the SEC's adviser files of November 2026.

Regulatory and legal record

What the adviser itself discloses in Item 11 of its Form ADV, summarised from the disclosure pages, with a link to the filing. Item 11 is filed for the adviser as a whole, so under each matter the fund it concerns is read from the disclosure itself.

202525 November 2025

Regulatory action by US Securities and Exchange Commission: civil penalty

Fund concerned: none named in the filing. The matter concerns the adviser itself, not a specific fund, and none of the insurance-dedicated funds in this file is named.

The Securities and Exchange Commission ("SEC") found that m Holdings Securities, Inc. ("M Holdings") failed to (1) adopt written policies and procedures reasonably designed to protect customer records and information, in violation of Rule 30(a) of Regulation sp (17 c.f.r. § 248.30(a)); and (2) develop and implement a written identity theft prevention program that is designed to detect, prevent, and mitigate identity theft in connection with the opening of a covered account or any existing covered account, in violation of Rule 201 of Regulation sid (17 c.f.r. § 248.201).

US Securities and Exchange Commission · Order 25 November 2025 · USD 325,000 · Concerns the adviser itself · Form ADV, Item 11 disclosure

201811 June 2018

Regulatory action by US Securities and Exchange Commission: cease and desist

Fund concerned: a public mutual fund. None of the insurance-dedicated funds in this file is named.

On March 11, 2019, the Securities and Exchange Commission (SEC) published ia release no. 5193, an order instituting administrative and cease and desist proceedings, pursuant to Sections 203(e) and 203(k) of the Investment Advisers Act of 1940 (Advisers Act), against m Holdings Securities, Inc. (respondent). Respondent self-reported the violations to the SEC. The proceedings arise out of breaches of fiduciary duty and inadequate disclosures by respondent in connection with its mutual Fund share class selection practices and the 12b- 1 fees it AND/OR its associated persons received. At times during the relevant period, respondent purchased for, recommended to, or held for advisory clients ...

US Securities and Exchange Commission · Order 11 March 2019 · No monetary sanction reported · Concerns the adviser itself · Form ADV, Item 11 disclosure

The filing also reports 1 matter that concerns an individual; such matters are weighed in the rating by the person's role and are not published here. These are the matters M Holdings Securities, Inc. reports in Item 11 of its Form ADV, filed 27 October 2026. A reported matter is a fact disclosed by the adviser, not a finding by PPLI.com. None of them concerns the insurance-dedicated funds listed above.

How would you rate M Holdings Securities, Inc.?

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M Holdings Securities, Inc.