Account Minimums and Types of Clients — Form ADV Part 2A (9/25/2020)
[Brochure]
Types of Clients
We provide the advisory services described in this brochure to individuals, pension or profit sharing plans, trusts, estates or
charitable organizations, corporations or other business entities, governmental entities and educational institutions, as well as
banks or thrift institutions.
Portfolio Manager Selection and Evaluation
Each Program described in this Disclosure Document has specific criteria used in evaluating and/or selecting Portfolio
Managers or underlying investments for inclusion in the Program. Please see the "Services, Fees and Compensation" section
for each specific Program to review the criteria used in that Program.
Services Tailored to Individual Client Needs
All of our investment recommendations for Program Accounts are based on an analysis of your individual financial needs.
They are drawn from research and analysis we believe to be reliable and appropriate to your financial circumstances. Each of
the advisory services we offer is tailored to a specific type of investor and designed to meet their individual investment
objectives, financial needs and tolerance of risk. A detailed description of these Programs is provided in the "Services, Fees
and Compensation" section.
Client Restrictions and Instructions
We will comply with any reasonable instructions and/or restrictions you give us when making recommendations for your
Account. Reasonable instructions generally include the designation of particular securities or types of securities that should
not be purchased for the Account.
If your restrictions are unreasonable or if we, or your Financial Advisor, believe that the restrictions are inappropriate, we will
notify you that unless the restrictions are modified, we may remove your Account from the Program. You will not be able to
provide instructions that prohibit or restrict the investment adviser of an open-end or closed-end mutual fund or an ETF, with
respect to the purchase or sale of specific securities or types of securities within the fund or ETF.
Our policy is generally to liquidate your preexisting securities portfolio immediately and bring the Account into conformity with
your target allocations. If you wish to hold certain positions for tax or investment purposes, you should consider holding these
positions in a separate Account.
Methods of Analysis, Investment Strategies and Risk of Loss
The Methods of Analysis used and Investment Strategies available in each Program are described above in the "Services,
Fees and Compensation" section.
Risk of Loss
All investments shall be at your risk exclusively, and you must understand that we do not guarantee any return on the
investments recommended or advised upon and may not be responsible for losses resulting from such trading or for any
transactions that we have not recommended to you.
AUM Breakdown
Accounts
AUM ($M)
By Client Type
(a) Individuals (other than high net worth individuals)
105
34.2
(b) Individuals (high net worth individuals)
173
108.4
(c) Banking or thrift institutions
0
0.0
(d) Investment companies
0
0.0
(e) Business development companies
0
0.0
(f) Pooled investment vehicles
0
0.0
(g) Pension and profit sharing plans
370
92.5
(h) Charitable organizations
8
18.6
(i) State or municipal government entities
2
128.8
(j) Other investment advisers
0
0.0
(k) Insurance companies
3
27.7
(l) Sovereign wealth funds and foreign official institutions
0
0.0
(m) Corporations or other businesses not listed above