Item 7 - Types of Clients:
"NMS" provides portfolio management services to individuals, high net-worth individuals, corporate and
institutional clients, both domestic and international, institutions including endowments and profit sharing plans
and hedge funds.
"NMS" may also assist clients, on a case by case basis with portfolio management services that may not fit into
any one of the above-mentioned services. Each of the accounts establish by "NMS" require a
Minimum Account Balance $100,000.00. However, advisors have the discretion to waive account
minimums with Executive level approval.
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Item 8 - Methods o f Analysis, Investment Strategies and Risk of Loss
For Portfolio Management Services, “NMS" uses fundamental and technical analysis to determine the
investments in each portfolio. In its analysis fundamental, “NMS" seeks to determine the intrinsic value of
equities based on a thorough analysis of the fundamental business factors of the given stocks at time of purchase.
This includes: analysis of financial statements, earnings, dividends, management stricter, competitive
advantages, product offering, competitors and markets. This method of analysis evaluates the overall condition
of the company (or companies in a mutual fund or ETF) to determine whether it is a sound investment. Despite
the fundamental analysis performed by "NMS”, any investment in securities carry a degree of market risk and
investors may lose their principal investment, in addition to management fees.
In a technical analysis, "NMS" seeks to determine the future direction of prices through the study of past market
data, in addition to price and volume. This is done by charting the movement of investments to identify trends and
patters used in the selection of securities to purchase and price points to buy and sell. "NMS" uses many stock
screeners and other software to chart and analyze the movement of various investments. Despite the technical
analysis performed by "NMS”, any investment in securities carry a degree of market risk and investors may
lose their principal investment, in addition to management fees.
Additionally, Portfolio Management Services, investment strategies will vary depending on the Client's financial
goals and risk tolerance. Clients seeking capital preservation with limited risk will be managed with passive
strategies using fixed income products (e.g. bonds) and index funds whereas Clients seeking growth with greater
risk will be managed with active strategies using stocks, mutual funds, ETFs, and stock options.
"NMS" will not engage in day trading, active strategies may entail additional risk due to a greater frequency in
transactions, which may involve additional brokerage fees, transaction costs, and taxes. Additionally, strategies
that use options may entail additional risk as losses may exceed those seen in the underlying stock. Lastly, strategies
that include private placements offerings entail greater risk as these offerings have limited regulatory oversight,
have less liquidity, and depend on the due diligence of the investor or investment adviser.
Item 9 - DisciplinaryInformation
I. Arthur Mansourian was named a respondent in a FINRA complaint alleging that, at the instruction of his
member firm's owner and its CCO, he compiled documents which the CCO produced to FINRA without
revealing that they had been backdated. The complaint also alleges that use of his personal email account
caused the firm to maintain inaccurate books and records. The Extended Hearing Panel Decision rendered
December 15, 2017, wherein Mr. Mansourian was barred from association with any FINRA member and
ordered to, jointly and severally, pay costs in the total amount of $12,184.82. On January 8, 2018, he filed a
notice of appeal based on FINRA’s offering insufficient evidence to prove the allegations. The appeal notes
that the Panel did not allow Mr. Mansourian to have an independent hearing, which resulted in undue
prejudice to him at the hearing. The appeal further states that the Hearing Panel assessed an excessive
sanction on Mr. Mansourian, failing to properly weigh the facts, evidence, and considerations set forth in
the FINRA Sanction Guidelines and that FINRA made their decision based on credibility, and not evidence.
Additionally, the fact that there was no evidence that Mr. Mansourian was not telling the truth, and the fact
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that Mr. Mansourian had no compliance background and was not aware what he was directed to do by a
supervisor was wrong. Mr. Mansourian has since obtained his Series 24 license and has taken continuing
education many times. Mr. Mansourian will fight this accusation fully of the law to maintain his reputation
and previously flawless FINRA record. Sanctions are not in effect pending the review of the appeal.
II. Trevor Saliba was named a respondent in a FINRA complaint alleging that in his capacity as principal, he
caused his member firm to violate interim restrictions placed on it by FINRA shortly after it filed a
Continuing Membership Application (CMA) and failed to provide a complete response to a FINRA request.
The Extended Hearing Panel Decision rendered December 15, 2017, wherein Mr. Saliba was barred from
association with any FINRA member and ordered to, jointly and severally, pay costs in the total amount of
$12,184.82. The Panel found that Enforcement failed to prove that Saliba caused the firm to maintain the
falsified memos as firm records. On January 8, 2018, Mr. Saliba filed a notice of appeal based on FINRA’s
offering insufficient evidence to prove the allegations, coupled with the fact that the Panel denied Mr.
Saliva’s initial motion to sever, which effected undue prejudice to him at the hearing, resulting in a decision
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