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Item 1
Cover Page
Diversified Investment Strategies, LLC
doing business as
Advisor.Investments
SEC File Number: 801 – 67260
ADV Part 2A, Firm Brochure
Dated February 20, 2026
Contact: Shane Haag, Chief Compliance Officer
4870 Bluebonnet Blvd, Suite B
Baton Rouge, LA 70809
www.advisor.investments
www.mywealthchart.com
This brochure provides information about the qualifications and business practices of Diversified
Investment Strategies, LLC, (the “Registrant”), which does business as Advisor.Investments. If you
have any questions about the contents of this brochure, please contact us at (225) 292-0687 or
shane@advisor.investments. The information in this brochure has not been approved or verified by
the United States Securities and Exchange Commission or by any state securities authority.
Additional information about Diversified Investment Strategies, LLC also is available on the SEC’s
website at www.adviserinfo.sec.gov.
References herein to Diversified Investment Strategies, LLC as a “registered investment adviser” or
any reference to being “registered” does not imply a certain level of skill or training.
Item 2
Material Changes
Since the Registrant’s January 9, 2025 Amendment filing, the Registrant below has no material changes
to this brochure. However, the Registrant has mad non-material additions and enhancements at Item 15
below. ANY QUESTIONS: Registrant’s Chief Compliance Officer, Shane Haag, remains available to
address any questions regarding this Part 2A, including the disclosure additions and enhancements below.
Item 3
Table of Contents
Cover Page ..................................................................................................................................... 1
Item 1
Item 2 Material Changes ........................................................................................................................... 2
Table of Contents .......................................................................................................................... 2
Item 3
Advisory Business ......................................................................................................................... 3
Item 4
Fees and Compensation ................................................................................................................. 7
Item 5
Performance-Based Fees and Side-by-Side Management .............................................................. 9
Item 6
Item 7
Types of Clients ........................................................................................................................... 10
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss .................................................... 10
Disciplinary Information.............................................................................................................. 12
Item 9
Item 10 Other Financial Industry Activities and Affiliations .................................................................... 12
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................ 12
Item 12 Brokerage Practices ..................................................................................................................... 13
Item 13 Review of Accounts ..................................................................................................................... 15
Item 14 Client Referrals and Other Compensation ................................................................................... 15
Item 15 Custody ........................................................................................................................................ 16
Item 16
Investment Discretion .................................................................................................................. 16
Item 17 Voting Client Securities ............................................................................................................... 16
Financial Information .................................................................................................................. 16
Item 18
Item 4
Advisory Business
A. Diversified Investment Strategies, LLC (the “Registrant”) is a limited liability company
formed on December 16, 2004 in the state of Louisiana. Diversified Investment Strategies,
LLC does business as Advisor.Investments, and markets itself as such. The Registrant
became registered as an Investment Adviser Firm in November 2006 and as Producer
Agency for insurance sales by the State of Louisiana in April 2015. The Registrant is owned
by James Pope and Shane Haag.
B. As discussed below, the Registrant offers to its clients (individuals, business entities, trusts
and estates, etc.) investment advisory services. The Registrant does not hold itself out as
providing financial planning or estate planning services. To the extent specifically
requested by a client, Registrant shall generally provide limited consulting services to its
investment management clients on investment and non-investment related matters that are
generally ancillary to the investment management process. The type and scope of the
advisory and consulting services offered will vary on a client by client basis.
INVESTMENT ADVISORY SERVICES
The client can determine to engage the Registrant to provide discretionary investment
advisory services on a fee basis. The Registrant’s annual investment advisory fee is based
upon a percentage (%) of the market value of the assets placed under the Registrant’s
management as per the following fee schedule:
Tier Chargeable Assets
First $500,000
Tiers
1
Annual Rate
1.35%
Plus, additional assets up to $1,000,000
2
0.85%
Plus, additional assets up to $2,000,000
3
0.70%
Plus, additional assets up to $4,000,000
4
0.45%
Plus, additional assets up to $8,000,000
5
0.35%
6
Amount over $8 million
negotiable
TAX PREPARATION AND ENROLLED AGENT SERVICES
The Tax Preparation and Enrolled Agent Services may be offered to existing and new clients on a
selective basis.
TAX PREPARATION SERVICES
The Registrant may determine to offer tax preparation services on selective basis with a stand-alone
separate fee set forth in a separate engagement letter. Registrant’s typical tax preparation fee for a simple
tax return is $250 per return. However, Registrant’s fee could be substantially more for more complex
returns. No client is under any obligation to engage the Registrant for tax preparation services.
ENROLLED AGENT SERVICES
Shantelle Palermo, Enrolled Agent, at her discretion on a selective basis, may offer engagement to
represent the client before the Internal Revenue Service (IRS) and/or the State Department of Revenue for
matters relating to any of the following.
• Communicating with the IRS and/or State Department of Revenue for a taxpayer regarding the
taxpayer's rights, privileges, or liabilities under laws and regulations administered by the IRS
and/or State Department of Revenue.
• Representing a taxpayer at conferences, hearings, or meetings with the IRS and/or State
Department of Revenue.
• Preparing and filing documents with the IRS and/or State Department of Revenue for a
taxpayer.
• Corresponding and communicating with the IRS and/or State Department of Revenue for a
taxpayer.
The terms and conditions, and corresponding fee, for any such engagement shall be set forth in a separate
engagement letter between Ms. Palermo and the client. No client is under any obligation to engage Ms.
Palermo for any of the above services.
the Registrant, nor any of
its
Non-Investment Consulting/Implementation Services. Neither
representatives, serves as an attorney, and no portion of the Registrant’s services should be construed as legal
or accounting services. To the extent requested by a client, the Registrant may recommend the services of
other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, etc.).
These professionals may also include employees or agents of the Registrant in their separate registered or
licensed capacities as discussed above (Tax Preparation) and below (Insurance). The client is under no
obligation to engage the services of any such recommended professional. The client retains absolute
discretion over all such implementation decisions and is free to accept or reject any recommendation from
the Registrant. Please Note: If the client engages any unaffiliated recommended professional, and a dispute
arises, the client agrees to seek recourse exclusively from and against the engaged professional. At all times,
the engaged unaffiliated licensed professional[s] (i.e. attorney, accountant, etc.), and not Registrant, shall be
responsible for the quality and competency of the services provided. Please Also Note: It remains the client’s
responsibility to promptly notify the Registrant if there is ever any change in their financial situation or
investment objectives for the purpose of reviewing and revising Registrant’s previous recommendations or
services.
Please Note: Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client leaving
an employer typically has four options regarding an existing retirement plan (and may engage in a
combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over
the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an
Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the
client’s age, result in adverse tax consequences). If Registrant recommends that a client roll over their
retirement plan assets into an account to be managed by Registrant, such a recommendation creates a conflict
of interest if Registrant will earn new (or increase its current) compensation as a result of the rollover. If
Registrant provides a recommendation as to whether a client should engage in a rollover or not (whether it is
from an employer’s plan or an existing IRA), Registrant is acting as a fiduciary within the meaning of Title
I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which
are laws governing retirement accounts. No client is under any obligation to roll over retirement plan
assets to an account managed by Registrant, whether it is from an employer’s plan
or an existing IRA. Registrant’s Chief Compliance Officer, Shane Haag, remains available to address
any questions that a client or prospective client may have regarding the potential for conflict of
interest presented by such rollover recommendation.
Custodian Charges-Additional Fees. As discussed below at Item 12 below, when requested to recommend
a broker-dealer/custodian for client accounts, Registrant generally recommends that Schwab serve as the
broker-dealer/custodian for client investment management assets. Broker-dealers such as Schwab charge
brokerage commissions, transaction, and/or other type fees for effecting certain types of securities
transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs
charged for fixed income transactions, etc.). The types of securities for which transaction fees,
commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the
broker-dealer/custodian. While certain custodians, including Schwab, generally (with the potential
exception for large orders) do not currently charge fees on individual equity transactions (including ETFs),
others do. Please Note: there can be no assurance that Schwab will not change their transaction fee pricing
in the future. The above fees/charges are in addition to Registrant’s investment advisory fee at Item 5 below.
Registrant does not receive any portion of these fees/charges. ANY QUESTIONS: Registrant’s Chief
Compliance Officer, Shane Haag, remains available to address any questions that a client or
prospective client may have regarding the above.
Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account
transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated
sweep account. The yield on the sweep account will generally be lower than those available for other money
market accounts. When this occurs, to help mitigate the corresponding yield dispersion, Registrant shall
(usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market
fund available on the custodian’s platform, unless Registrant reasonably anticipates that it will utilize the
cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s
account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash
balances for various reasons, including, but not limited to the amount of dispersion between the sweep
account and a money market fund, an indication from the client of an imminent need for such cash, or the
client has a demonstrated history of writing checks from the account. Please Note: The above does not
apply to the cash component maintained within a Registrant actively managed investment strategy (the cash
balances for which shall generally remain in the custodian designated cash sweep account), an indication
from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager,
and cash balances maintained for fee billing purposes. Please Also Note: The client shall remain exclusively
responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances
maintained in any Registrant unmanaged accounts. ANY QUESTIONS: Registrant’s Chief Compliance
Officer, Shane Haag, remains available to address any questions that a client or prospective client may have
regarding the above.
Please Note: Cash Positions. Registrant continues to treat cash as an asset class. As such, unless
determined to the contrary by Registrant, all cash positions (money markets, etc.) shall continue to be
included as part of assets under management for purposes of calculating Registrant’s advisory fee. At any
specific point in time, depending upon perceived or anticipated market conditions/events (there being no
guarantee that such anticipated market conditions/events will occur), Registrant may maintain cash
positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss
market advances. Depending upon current yields, at any point in time, Registrant’s advisory fee could
exceed the interest paid by the client’s money market fund. ANY QUESTIONS: Registrant’s Chief
Compliance Officer, Shane Haag, remains available to address any questions that a client or
prospective may have regarding the above fee billing practice.
emoney. In the event that the Registrant provides the client with access to an unaffiliated vendor’s
website such as emoney, and the site provides access to information and/or concepts, including
financial planning, the client, should not, in any manner whatsoever, infer that such access is a
substitute for services provided by the Registrant. Rather, if the client utilizes any such content, the
client does so separate and independent of the Registrant.
limited
to,
Portfolio Activity. Registrant has a fiduciary duty to provide services consistent with the client’s
best interest. As part of its investment advisory services, Registrant will review client portfolios on
an ongoing basis to determine if any changes are necessary based upon various factors, including,
investment performance, manager changes, debt burden, client
but not
additions/withdrawals, and/or a change in the client’s investment objective. Based upon these
factors, there may be extended periods of time when Registrant determines that changes to a client’s
portfolio are neither necessary nor prudent. The Registrant’s fee shall remain payable during such
periods of account inactivity. Of course, as indicated below, there can be no assurance that
investment decisions made by Registrant will be profitable or equal any specific performance
level(s).
Affiliated Private Investment Fund. The Registrant is the advisor to Aldabra Capital Partners,
LP (the “affiliated private fund”). The Registrant, on a non-discretionary basis, may recommend
that qualified clients consider allocating a portion of their investment assets to the affiliated private
fund. The terms and conditions for participation in the affiliated private fund, including incentive
fees, conflicts of interest, and risk factors, are set forth in the fund’s offering documents.
Registrant’s clients are under absolutely no obligation to consider or make an investment in a
private investment fund.
Risk Factors: Private investment funds generally involve various risk factors, including,
but not limited to, potential for complete loss of principal, liquidity constraints and lack of
transparency, a complete discussion of which is set forth in each fund’s offering
documents, which will be provided to each client for review and consideration. Unlike
liquid investments that a client may maintain, private investment funds do not provide daily
liquidity or pricing. Each prospective client investor will be required to complete a
Subscription Agreement, pursuant to which the client shall establish that he/she is qualified
for investment in the fund, and acknowledges and accepts the various risk factors that are
associated with such an investment.
Conflict of Interest. Because the Registrant earns compensation from the affiliated private
fund (incentive compensation) that could substantially exceed the fee that Registrant would
earn under its standard asset based fee schedule referenced in Item 5 below, the
recommendation that a client become an investor in the affiliated private fund presents a
conflict of interest. No client is under any obligation to become an investor in the affiliated
private fund.
Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and
it should not be assumed that future performance of any specific investment or investment strategy
(including the investments and/or investment strategies recommended or undertaken by Registrant)
will be profitable or equal any specific performance level(s).
Client Obligations. In performing its services, Registrant shall not be required to verify any
information received from the client or from the client’s other professionals, and is expressly
authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to
promptly notify the Registrant if there is ever any change in their financial situation or investment
objectives for the purpose of reviewing, evaluating and revising Registrant’s previous
recommendations or services.
Disclosure Brochure. A copy of the Registrant’s written Brochure as set forth on Part 2A of Form
ADV shall be provided to each client prior to, or contemporaneously with, the execution of the
Investment Advisory Agreement.
to providing
investment advisory services, an
C. The Registrant shall provide investment advisory services specific to the needs of each
client. Prior
investment adviser
representative will ascertain each client’s investment objective(s) allocation(s). Thereafter,
the Registrant shall allocate and/or recommend that the client allocate investment assets
consistent with the designated investment objective(s) allocation(s). The client may, at any
time, impose reasonable restrictions, in writing, on the Registrant’s services.
D. The Registrant does not participate in a wrap fee program.
E. As of December 31, 2025, the Registrant had $192,183,085 in assets under management
in assets under management on a non-
on a discretionary basis and $3,313,133
discretionary basis for a total of $195,496,218 in assets under management.
Item 5
Fees and Compensation
A. The client can determine to engage the Registrant to provide discretionary investment
advisory services on a fee basis.
INVESTMENT ADVISORY SERVICES
The client can determine to engage the Registrant to provide discretionary investment
advisory services on a fee basis. The Registrant’s annual investment advisory fee is based
upon a percentage (%) of the market value of the assets placed under the Registrant’s
management as per the following fee schedule:
Tiers
Tier Chargeable Assets
Annual Rate
First $500,000
1
1.35%
Plus, additional assets up to $1,000,000
2
0.85%
Plus, additional assets up to $2,000,000
3
0.70%
Plus, additional assets up to $4,000,000
4
0.45%
Plus, additional assets up to $8,000,000
5
0.35%
6
Amount over $8 million
negotiable
As indicated at Item 7 below, the Registrant, in its discretion, may charge a lesser or higher
investment advisory fee, charge a flat fee, waive its fee entirely, or charge fee on a different
interval, based upon certain criteria (i.e. anticipated future earning capacity, anticipated
future additional assets, dollar amount of assets to be managed, related accounts, account
composition, complexity of the engagement, anticipated services to be rendered,
grandfathered fee schedules, employees and family members, courtesy accounts,
competition, negotiations with client, etc.).
TAX PREPARATION SERVICES
The Registrant may determine to provide tax preparation services on a stand-alone separate
fee basis for select clients as set forth in a separate engagement letter. Registrant’s typical
tax preparation fee for a simple tax return is $250 per return. However, Registrant’s fee
could be substantially more for more complex returns. No client is under any obligation to
engage the Registrant for tax preparation services.
Please see additional disclosure at Item 7 below regarding advisory fees.
B. Clients may elect to have the Registrant’s advisory fees deducted from their custodial
account. Both Registrant's Investment Advisory Agreement and the custodial/ clearing
agreement may authorize the custodian to debit the account for the amount of the
Registrant's investment advisory fee and to directly remit that management fee to the
Registrant in compliance with regulatory procedures. In the limited event that the
Registrant bills the client directly, payment is due upon receipt of the Registrant’s invoice.
The Registrant shall deduct fees and/or bill clients monthly in advance, based upon the
market value of the assets on the last business day of the previous month. Clients who
purchase insurance products from representatives of the Registrant will be provided with
the terms of such products pursuant to state insurance laws. Additional disclosure
documents may be provided directly by an unaffiliated insurance company.
C. As discussed above and below, unless the client directs otherwise or an individual client’s
circumstances require, the Registrant shall generally recommend that Charles Schwab and
Co., Inc. (“Schwab”) serve as the broker-dealer/custodian for client investment
management assets. As indicated above, broker-dealers such as Schwab charge transaction
fees for effecting certain types of securities transactions. In addition to Registrant’s
investment management fee and transaction fees, clients will also incur, relative to all
mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g.,
management fees and other fund expenses).
D. Registrant's annual investment advisory fee shall be prorated and paid monthly, in advance,
based upon the market value of the assets on the last business day of the previous month.
The Registrant does not generally require an annual minimum fee or asset level for
investment advisory services. The Registrant, in its sole discretion, may charge a lesser
investment management fee based upon certain criteria (i.e. anticipated future earning
capacity, anticipated future additional assets, dollar amount of assets to be managed, related
accounts, account composition, negotiations with client, etc.).
The Investment Advisory Agreement between the Registrant and the client will continue in
effect until terminated by either party by written notice in accordance with the terms of the
Investment Advisory Agreement. Upon termination, the Registrant shall refund the pro-
rated portion of the advanced advisory fee paid based upon the number of days remaining
in the billing month.
E. Insurance Commission Transactions. In the event that the client desires, the client can
engage the Registrant and its representatives to purchase insurance products on a
commission basis. The commissions and fees charged by the Registrant may be higher or
lower than those charged by other insurance producers.
1. Conflict of Interest: The recommendation that a client purchase an insurance
commission product presents a conflict of interest, as the receipt of commissions
may provide an incentive to recommend insurance products based on commissions
to be received, rather than on a particular client’s need. No client is under any
obligation to purchase any commission products from Registrant’s representatives.
The Registrant’s Chief Compliance Officer, Shane Haag, remains available to
address any questions that a client or prospective client may have regarding the
above conflict of interest.
2. Please Note: Clients may purchase insurance products recommended by
Registrant through other, non-affiliated insurance agents and agencies.
3. The Registrant does not receive more than 50% of its revenue from advisory clients
as a result of commissions or other compensation for the sale of insurance products
the Registrant recommends to its clients.
4. The Registrant and its representatives may receive continuing commissions for the
sale of an insurance product.
Item 6
Performance-Based Fees and Side-by-Side Management
Registrant may charge performance-based fees to clients. Clients are advised that
performance-based fees involve a sharing of any portfolio gains between the client and the
Registrant. Such performance-based fees create a conflict of interest because the Registrant
is incentivized to take additional risks in the management of a client portfolio that may be
in conflict with the client’s current investment objectives and tolerance for risk. No
performance-based bees will be assessed until the portfolio, on a cumulative basis from
account inception, is in a net gain position.
Performance-based fees are in addition to the asset-based fees detailed in Item 5 of this
Brochure. Clients are also advised that as a result of the standard asset-based fee and the
performance-based fee, the Registrant has an economic incentive to recommend a
performance-based fee structure.
Performance-based fees may only be offered to clients who meet one of the following
criteria:
A natural person who or a company that immediately after entering into the
contract has at least $1,100,000 under the management of the investment
adviser;
A natural person who or a company that the investment adviser entering into
the contract (and any person acting on his behalf) reasonably believes,
immediately before entering into the contract, either:
o
o Has a net worth (together, in the case of a natural person, with assets held
jointly with a spouse, excluding principal residence) of more than
$2,200,000, at the time the contract is entered into; or
Is a qualified purchaser as defined in section 2(a)(51)(AA) of the
Investment Company Act of 1940 (15 U.S.C. 80a-2(51)(A)) at the time the
contract is entered into; or
A natural person who immediately before entering into the contract is:
o An executive officer, director, trustee, general partner, or person serving
in similar capacity of the investment adviser; or
o An employee of the investment adviser (other than an employee
performing solely clerical, secretarial, or administrative functions with
regard to the investment adviser) who, in connection with his or her regular
functions or duties, participates in the investment activities of such
investment adviser, provided that such employee has been performing
such functions and duties for or on behalf of the investment adviser, or
substantially similar functions or duties for or on behalf of another
company for at least 12 months.
Item 7
Types of Clients
The Registrant’s clients shall generally include individuals, business entities, trusts, and estates.
Registrant, in its discretion, may charge a lesser or higher investment advisory fee, charge a flat
fee, waive its fee entirely, or charge fee on a different interval, based upon certain criteria (i.e.
anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to
be managed, related accounts, account composition, complexity of the engagement, anticipated
services to be rendered, grandfathered fee schedules, employees and family members, courtesy
accounts, competition, negotiations with client, etc.). Please Note: As result of the above, similarly
situated clients could pay different fees. In addition, similar advisory services may be available
from other investment advisers for similar or lower fees.
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss
A. The Registrant may utilize the following methods of security analysis:
Charting - (analysis performed using patterns to identify current trends and trend
reversals to forecast the direction of prices)
Fundamental - (analysis performed on historical and present data, with the goal of
making financial forecasts)
Technical – (analysis performed on historical and present data, focusing on price
and trade volume, to forecast the direction of prices)
Cyclical – (analysis performed on historical relationships between price and
market trends, to forecast the direction of prices)
The Registrant may utilize the following investment strategies when implementing
investment advice given to clients:
Long Term Purchases (securities held at least a year)
Short Term Purchases (securities sold within a year)
Trading (securities sold within thirty (30) days)
Options (contract for the purchase or sale of a security at a predetermined price
during a specific period of time)
Please Note: Investment Risk. Different types of investments involve varying degrees of
risk, and it should not be assumed that future performance of any specific investment or
investment strategy (including the investments and/or investment strategies recommended
or undertaken by the Registrant) will be profitable or equal any specific performance
level(s).
B. The Registrant’s methods of analysis and investment strategies do not present any
significant or unusual risks.
However, every method of analysis has its own inherent risks. To perform an accurate
market analysis the Registrant must have access to current/new market information. The
Registrant has no control over the dissemination rate of market information; therefore,
unbeknownst to the Registrant, certain analyses may be compiled with outdated market
information, severely limiting the value of the Registrant’s analysis. Furthermore, an
accurate market analysis can only produce a forecast of the direction of market values.
There can be no assurances that a forecasted change in market value will materialize into
actionable and/or profitable investment opportunities.
The Registrant’s primary investment strategies - Long Term Purchases, Short Term
Purchases, and Trading - are fundamental investment strategies. However, every
investment strategy has its own inherent risks and limitations. For example, longer term
investment strategies require a longer investment time period to allow for the strategy to
potentially develop. Shorter term investment strategies require a shorter investment time
period to potentially develop but, as a result of more frequent trading, may incur higher
transactional costs when compared to a longer term investment strategy. Trading, an
investment strategy that requires the purchase and sale of securities within a thirty (30) day
investment time period, involves a very short investment time period but will incur higher
transaction costs when compared to a short term investment strategy and substantially
higher transaction costs than a longer term investment strategy.
In addition to the fundamental investment strategies discussed above, the Registrant may
also implement and/or recommend options transactions. Option transactions have a high
level of inherent risk. (See discussion below).
The use of options transactions as an investment strategy may involve a high level of
inherent risk. Option transactions establish a contract between two parties concerning the
buying or selling of an asset at a predetermined price during a specific period of time.
During the term of the option contract, the buyer of the option gains the right to demand
fulfillment by the seller. Fulfillment may take the form of either selling or purchasing a
security depending upon the nature of the option contract. Generally, the purchase or the
recommendation to purchase or sell an option contract by the Registrant shall be with the
intent of producing income or offsetting/”hedging” a potential market risk in a client’s
portfolio. Please Note: Although the intent of the options-related transactions that may be
implemented by the Registrant is to produce income or hedge against principal risk, certain
of the options-related strategies (i.e. straddles, short positions, etc.), may, in and of
themselves, produce principal volatility and/or risk. Thus, a client must be willing to accept
these enhanced volatility and principal risks associated with such strategies. In light of
these enhanced risks, client may direct the Registrant, in writing, not to employ any or all
such strategies for his/her/their/its accounts.
C. Currently, the Registrant primarily allocates client investment assets among various
individual equity (stocks), debt (bonds) and fixed income securities, closed-end mutual
funds, exchange traded funds and preferred stock on a discretionary basis, consistent with
the client’s designated objectives allocation. The Registrant may also engage in option
strategies: (1) writing covered calls (“out of the money” and “in the money”)- to provide
portfolio income and sell/buy at certain prices; (2) buying puts - to help protect the portfolio
value against market decline; and/or (3) option collar – combining a call with a put to hedge
selected price movements.
Item 9
Disciplinary Information
The Registrant has not been the subject of any disciplinary actions.
Item 10
Other Financial Industry Activities and Affiliations
A. Neither the Registrant, nor its representatives, are registered or have an application pending
to register, as a broker-dealer or a registered representative of a broker-dealer.
B. Neither the Registrant, nor its representatives, are registered or have an application pending
to register, as a futures commission merchant, commodity pool operator, a commodity
trading advisor, or a representative of the foregoing.
C. Licensed Insurance Producer Agency and Licensed Insurance Agents. The Registrant
is registered as Producer Agency for Accident and Health and Life Insurance by the
Louisiana Department of Insurance. Clients can engage the Registrant and certain of its
representative to purchase insurance products and policies on a commission basis.
Conflict of Interest: The recommendation that a client purchase an insurance commission
product or policy presents a material conflict of interest, as the receipt of commissions
may provide an incentive to recommend insurance products based on commissions
received, rather than on a particular client’s need. No client is under any obligation to
purchase any commission product from the Registrant or any of its representatives. Clients
are reminded that they may purchase insurance products recommended by the Registrant
through other non-affiliated insurance agents and agencies. The Registrant’s Chief
Compliance Officer, Shane Haag, remains available to address any questions that a
client or prospective may have regarding the above conflicts of interest.
D. The Registrant does not receive, directly or indirectly, compensation from investment
advisors that it recommends or selects for its clients.
Item 11
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
A. The Registrant maintains an investment policy relative to personal securities transactions.
This investment policy is part of Registrant’s overall Code of Ethics, which serves to
establish a standard of business conduct for all of Registrant’s Representatives that is based
upon fundamental principles of openness, integrity, honesty and trust, a copy of which is
available upon request.
In accordance with Section 204A of the Investment Advisers Act of 1940, the Registrant
also maintains and enforces written policies reasonably designed to prevent the misuse of
material non-public information by the Registrant or any person associated with the
Registrant.
B. As disclosed above, the Registrant has a financial interest in the affiliated private fund. The
terms and conditions for participation in the affiliated private fund, including incentive
fees, conflicts of interest, and risk factors, are set forth in the fund’s offering documents.
C. The Registrant and/or representatives of the Registrant may buy or sell securities that are
also recommended to clients. This practice may create a situation where the Registrant
and/or representatives of the Registrant are in a position to materially benefit from the sale
or purchase of those securities. Therefore, this situation creates a potential conflict of
interest. Practices such as “scalping” (i.e., a practice whereby the owner of shares of a
security recommends that security for investment and then immediately sells it at a profit
upon the rise in the market price which follows the recommendation) could take place if
the Registrant did not have adequate policies in place to detect such activities. In addition,
this requirement can help detect insider trading, “front-running” (i.e., personal trades
executed prior to those of the Registrant’s clients) and other potentially abusive practices.
The Registrant has a personal securities transaction policy in place to monitor the personal
securities transactions and securities holdings of each of the Registrant’s “Access Persons”.
The Registrant’s securities transaction policy requires that an Access Person of the
Registrant must provide the Chief Compliance Officer or his/her designee with a written
report of their current securities holdings within ten (10) days after becoming an Access
Person. Additionally, each Access Person must provide the Chief Compliance Officer or
his/her designee with a written report of the Access Person’s current securities holdings at
least once each twelve (12) month period thereafter on a date the Registrant selects;
provided, however that at any time that the Registrant has only one Access Person, he or
she shall not be required to submit any securities report described above.
D. The Registrant and/or representatives of the Registrant may buy or sell securities, at or
around the same time as those securities are recommended to clients. This practice creates
a situation where the Registrant and/or representatives of the Registrant are in a position to
materially benefit from the sale or purchase of those securities. Therefore, this situation
creates a potential conflict of interest. As indicated above in Item 11.C, the Registrant has
a personal securities transaction policy in place to monitor the personal securities
transaction and securities holdings of each of Registrant’s Access Persons.
Item 12
Brokerage Practices
In the event that the client requests that Registrant recommend a broker-dealer/custodian for
execution and/or custodial services, Registrant generally recommends that investment Registrant
accounts be maintained at Charles Schwab & Co., Inc. (“Schwab”). Prior to engaging Registrant to
provide investment management services, the client will be required to enter into a formal
Investment Advisory Agreement with Registrant setting forth the terms and conditions under which
Registrant shall advise on the client's assets, and a separate custodial/clearing agreement with each
designated broker-dealer/custodian.
Factors that Registrant considers in recommending Schwab (or any other broker-dealer/custodian
to clients) include historical relationship with Registrant, financial strength, reputation, execution
capabilities, pricing, research, and service. Although the commissions and/or transaction fees paid
by Registrant’s clients shall comply with Registrant’s duty to obtain best execution, a client may
pay a transaction fee that is higher than another qualified broker-dealer might charge to effect the
same transaction where Registrant determines, in good faith, that the transaction fee is reasonable.
In seeking best execution, the determinative factor is not the lowest possible cost, but whether the
transaction represents the best qualitative execution, taking into consideration the full range of a
broker-dealer’s services, including the value of research provided, execution capability,
commission rates, and responsiveness. Accordingly, although Registrant will seek competitive
rates, it may not necessarily obtain the lowest possible commission rates for client account
transactions. The brokerage commissions or transaction fees charged by the designated broker-
dealer/custodian are exclusive of, and in addition to, Registrant’s investment advisory fee.
Non-Soft Dollar Research and Benefits: Although not a material consideration when determining
whether to recommend that a client utilize the services of a particular broker-dealer/custodian,
Registrant can receive from Schwab (or another broker-dealer/custodian, investment manager,
platform or fund sponsor, or vendor) without cost (and/or at a discount) support services and/or
products, certain of which assist Registrant to better monitor and service client accounts maintained
at such institutions. Included within the support services that can be obtained by Registrant may
be investment-related research, pricing information and market data, software and other technology
that provide access to client account data, compliance and/or practice management-related
publications, discounted or gratis consulting services, discounted and/or gratis attendance at
conferences, meetings, and other educational and/or social events, marketing support-including
client events, computer hardware and/or software and/or other products used by Registrant in
furtherance of its investment advisory business operations..
As indicated above, certain of the support services and/or products that may be received may assist
Registrant in managing and administering client accounts. Others do not directly provide such
assistance, but rather assist Registrant to manage and further develop its business enterprise.
Registrant’s clients do not pay more for investment transactions effected and/or assets maintained
at Schwab as a result of this arrangement. There is no corresponding commitment made by
Registrant to Schwab or any other any entity to invest any specific amount or percentage of client
assets in any specific mutual funds, securities or other investment products as result of the above
arrangement.
ANY QUESTIONS: Registrant’s Chief Compliance Officer, Shane Haag, remains
available to address any questions that a client or prospective client may have
regarding the above arrangement and the corresponding conflict of interest presented
by such arrangement.
Directed Brokerage. Registrant recommends that its clients utilize the brokerage and custodial
services provided by Schwab. Registrant generally does not accept directed brokerage arrangements
(when a client requires that account transactions be effected through a specific broker-dealer). In
such client directed arrangements, the client will negotiate terms and arrangements for their account
with that broker-dealer, and Registrant will not seek better execution services or prices from other
broker-dealers or be able to "batch" the client’s transactions for execution through other broker-
dealers with orders for other accounts managed by Registrant As a result, a client may pay higher
commissions or other transaction costs or greater spreads, or receive less favorable net prices, on
transactions for the account than would otherwise be the case. Please Note: In the event that the
client directs Registrant to effect securities transactions for the client’s accounts through a specific
broker-dealer, the client correspondingly acknowledges that such direction may cause the accounts
to incur higher commissions or transaction costs than the accounts would otherwise incur had the
client determined to effect account transactions through alternative
clearing arrangements that may be available through Registrant. Higher transaction costs adversely
impact account performance. Please Also Note: Transactions for directed accounts will generally
be executed following the execution of portfolio transactions for non-directed accounts.
Order Aggregation. Transactions for each client account generally will be effected independently,
unless Registrant decides to purchase or sell the same securities for several clients at approximately
the same time. Registrant aggregates such orders to obtain best execution, to negotiate more
favorable commission rates or to allocate equitably among Registrant’s clients differences in prices
and commissions or other transaction costs that might have been obtained had such orders been
placed independently. Under this procedure, transactions will be averaged as to price and will be
allocated among clients in proportion to the purchase and sale orders placed for each client account
on any given day. Registrant shall not receive any additional compensation or remuneration as a
result of such aggregation.
Item 13
Review of Accounts
A. For those clients to whom Registrant provides investment supervisory services, account
reviews are conducted on an ongoing basis by the Registrant's Principals and
representatives. All investment supervisory clients are advised that it remains their
responsibility to advise the Registrant of any changes in their investment objectives,
allocation, and/or financial situation. All clients (in person, via telephone and/or internet
meeting) are encouraged to review investment advisory issues (to the extent applicable),
investment objectives, allocation, and account performance with the Registrant on an at
least annual basis.
B. The Registrant may conduct account reviews on an other than periodic basis upon the
occurrence of a triggering event, such as a change in client investment objectives and/or
financial situation, market corrections and client request.
C. Clients are provided, at least quarterly, with written transaction confirmation notices and
regular written summary account statements directly from the broker-dealer/custodian
and/or program sponsor for the client accounts. The Registrant may also provide a written
periodic report summarizing account activity and performance.
Item 14
Client Referrals and Other Compensation
A. As indicated at Item 12 above, Registrant can receive from Schwab (and/or others) without
cost (and/or at a discount), support services and/or products. Registrant’s clients do not pay
more for investment transactions effected and/or assets maintained at Schwab as result of
this arrangement. There is no corresponding commitment made by Registrant to Schwab,
or any other entity, to invest any specific amount or percentage of client assets in any
specific mutual funds, securities or other investment products as a result of the above
arrangement. ANY QUESTIONS: Registrant’s Chief Compliance Officer, Shane
Haag, remains available to address any questions that a client or prospective
client may have regarding the above arrangement and the corresponding
conflict of interest presented by such arrangement.
B. The Registrant does not compensate any entity or person ( other than its representatives)
for client referrals.
Item 15
Custody
Registrant shall have the ability to deduct its advisory fee from the client’s Schwab account on a
monthly basis. Clients are provided with written transaction confirmation notices, and a written
summary account statement directly from Schwab, at least quarterly. Please Note: To the extent
that Registrant provides clients with periodic account statements or reports, the client is urged to
compare any statement or report provided by Registrant with the account statements received from
the account custodian. Please Also Note: The account custodian does not verify the accuracy of
Registrant’s advisory fee calculation.
Certain clients have established asset transfer authorizations that permit the qualified custodian to
rely upon instructions from Registrant to transfer client funds or securities to third parties. These
arrangements are disclosed at Item 9 of Part 1 of Form ADV. However, in accordance with the
guidance provided in the SEC’s February 21, 2017 Investment Adviser Association No-Action
Letter, the affected accounts are not subject to an annual surprise CPA examination.
Item 16
Investment Discretion
The client can determine to engage the Registrant to provide investment advisory services
on a discretionary basis. Prior to the Registrant assuming discretionary authority over a
client’s account, the client shall be required to execute an Investment Advisory Agreement,
naming the Registrant as the client’s attorney and agent in fact, granting the Registrant full
authority to buy, sell, or otherwise effect investment transactions involving the assets in
the client’s name found in the discretionary account.
Clients who engage the Registrant on a discretionary basis may, at any time, impose
restrictions, in writing, on the Registrant’s discretionary authority (i.e., limit the
types/amounts of particular securities purchased for their account, exclude the ability to
purchase securities with an inverse relationship to the market, limit or proscribe the
Registrant’s use of margin, etc.).
Item 17
Voting Client Securities
A. The Registrant does not vote client proxies. Clients maintain exclusive responsibility for:
(1) directing the manner in which proxies solicited by issuers of securities owned by the
client shall be voted, and (2) making all elections relative to any mergers, acquisitions,
tender offers, bankruptcy proceedings or other type events pertaining to the client’s
investment assets. The Registrant may provide an opinion about proxies to clients holding
effected securities but the decision and right to vote the proxy is retained by the customer
B. Clients will receive their proxies or other solicitations directly from their custodian. Clients
may contact the Registrant to discuss any questions they may have with a particular
solicitation.
Item 18
Financial Information
A. The Registrant does not solicit fees of more than $1,200, per client, six months or more in
advance.
B. The Registrant is unaware of any financial condition that is reasonably likely to impair its
ability to meet its contractual commitments relating to its discretionary authority over
certain client accounts.
C. The Registrant has not been the subject of a bankruptcy petition.
ANY QUESTIONS: The Registrant’s Chief Compliance Officer, Shane Haag,
remains available to address any questions that a client or prospective client may have
regarding the above disclosures and arrangements.