Overview
- Average Client Assets
- $2.1 million
- Minimum Account Size
- $100,000
- SEC CRD Number
- 140186
Fee Structure
Primary Fee Schedule (ALPENGLOBAL CAPITAL FORM ADV PARTS 2A AND 2B - FEBRUARY 2026)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $5,000,000 | 2.00% |
| $5,000,001 | and above | 1.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $20,000 | 2.00% |
| $5 million | $100,000 | 2.00% |
| $10 million | $175,000 | 1.75% |
| $50 million | $775,000 | 1.55% |
| $100 million | $1,525,000 | 1.52% |
Clients
- HNW Share of Firm Assets
- 89.85%
- Total Client Accounts
- 287
- Discretionary Accounts
- 287
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients
Regulatory Filings
Primary Brochure: ALPENGLOBAL CAPITAL FORM ADV PARTS 2A AND 2B - FEBRUARY 2026 (2026-03-13)
View Document Text
Item 1 – COVER PAGE
FORM ADV PART 2A BROCHURE*
AND
FORM ADV PART 2B BROCHURE SUPPLEMENT
March 2026
P.O. BOX 153
Tahoe City, California 96145
Tel: 415-424-4005
www.alpenglobalcapital.com
*This brochure provides information about the qualifications and business practices of
AlpenGlobal Capital, LLC (CRD No. 140186). If you have any questions about the contents of this
brochure, please contact the Firm’s Chief Compliance Officer, Karen Craig, at telephone 415-
424-4005 ext. 22. The information in this brochure has not been approved or verified by the U.S.
Securities and Exchange Commission or by any other federal or state authority. Additional
information about AlpenGlobal Capital, LLC is available at www.advisorinfo.sec.gov.
The oral and written statements of an advisor provide information upon which a prospective client
may base a determination as to whether or not to hire the advisor. You are encouraged to review
this Brochure and Brochure Supplements for the Firm’s associates who advise you for more
information on the qualifications of the Firm and its employees.
The use of the term “registered investment adviser” and description of AlpenGlobal Capital, LLC
and/or our associates as “registered” does not imply a certain level of skill or training.
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Item 2 - MATERIAL CHANGES FROM PRIOR FORM ADV 2A
AlpenGlobal Capital, LLC’s Form ADV Part 2A dated March 2026 contains changes from the prior
version dated February 2025, as follows:
- Updated description of the Firm’s assets under management at Part 2A, Item 4.
- Updated description of the Firm’s brokerage and custody arrangements at Part 2A, Item
12.
.
-
Item 3 - TABLE OF CONTENTS
ITEM 1 – COVER PAGE ................................................................................................................................ 1
ITEM 2 - MATERIAL CHANGES FROM PRIOR FORM ADV 2A .................................................................... 2
ITEM 3 - TABLE OF CONTENTS ...................................................................................................................... 2
ITEM 4 - ADVISORY BUSINESS .................................................................................................................... 32
ITEM 5 - FEES AND COMPENSATION .......................................................................................................... 5
ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ............................................... 7
ITEM 7 - TYPES OF CLIENTS ........................................................................................................................... 7
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES, RISK OF LOSS ............................................. 7
ITEM 9 - DISCIPLINARY INFORMATION ........................................................................................................ 9
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .................................................... 9
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL
TRADING ........................................................................................................................................ 10
ITEM 12 - BROKERAGE PRACTICES ........................................................................................................... 10
ITEM 13 - REVIEW OF ACCOUNTS ............................................................................................................. 13
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION ................................................................... 13
ITEM 15 - CUSTODY .................................................................................................................................... 13
ITEM 16 - INVESTMENT DISCRETION .......................................................................................................... 14
ITEM 17 - VOTING CLIENT SECURITIES ....................................................................................................... 14
ITEM 18 - FINANCIAL INFORMATION ........................................................................................................ 14
BROCHURE SUPPLEMENT ........................................................................................................................... 15
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Item 4 - ADVISORY BUSINESS
Registration Status –
Registration by the U.S. Securities and Exchange Commission in
November 2020
Registered with the State of California in August 20061
Registered with the State of Washington in September 2013
Registered with the State of Texas in May 2020
Alex Gutt
Principal Owner –
Assets Under Management Discretionary Assets – $184,036,686
(as of December 31, 2025)
Non-discretionary Assets – $0
ADVISORY SERVICES2
Investment Management Services
AlpenGlobal Capital, LLC (“AlpenGlobal” or sometimes “Advisor” or “the Firm”) provides portfolio
management and financial planning and financial consulting services to its clients. In providing
its services, AlpenGlobal acts as a fiduciary in relation to its clients. The Firm and its staff are subject
to principles of fiduciary duty, which dictate that the Firm conduct its business in a manner that
places the interests of its clients, ahead of those of the Firm and its employees and to disclose to
clients any and all potential conflicts of interest that may impair its ability to do so. This Form ADV
Part 2A describes the Firm’s business and makes numerous important disclosures related to its
investment management and financial planning services.
AlpenGlobal constructs and actively manages client portfolios investing primarily in individual
global equity positions based on fundamental research, communication with management
teams and in-depth financial analysis of companies to identify secular global trends, potential
company and industry catalysts, as well as discovering undervalued companies. The Firm takes
a long-term perspective on client portfolios and the investment recommendations, while actively
managing the portfolio on a day-to-day basis.
The Firm’s portfolio manager consults with each client to design an individualized investment plan
based on a number of factors including the client’s financial condition, investment goals and
objectives, risk tolerances, asset class preferences, time horizons, liquidity needs and other factors.
Our portfolio manager helps each of the Firm’s clients identify a strategic asset allocation that is
consistent with the client’s investment objectives and other client criteria.
AlpenGlobal requires a minimum of $100,000 placed under management per client relationship.
Clients may make additions to and withdrawals from their investment account at any time, subject
to the Firm’s right to terminate an account if the amount of assets drops below our account size
minimum. Clients may withdraw account assets with notice to the Firm, subject to the usual and
customary securities settlement procedures. However, we design client portfolios as long-term
investments and caution our clients that asset withdrawals may impair the achievement of the
client’s investment objectives.
1 “Registration” means only that the Firm meets the minimum requirements for registration as an investment
advisor and does not imply that the Securities and Exchange Commission guarantees the quality of the
Firm services or recommends them.
2 The Firm does not sponsor, nor does it provide portfolio management services to wrap fee programs offered
by broker-dealers or others.
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Additions to an account may be in cash or securities provided that our portfolio manager may
decline to accept particular securities into a client’s account or may recommend that the security
be liquidated if it is inconsistent with the Firm’s investment strategy or the client’s investment
objectives. Clients are advised that when transferred securities are liquidated, they may be-
subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales
charge) and/or tax ramifications.
Financial Planning Services
AlpenGlobal provides financial planning analyses included with its investment management
services for those clients that would benefit from such planning. Financial planning services may
include a financial review and analysis of some or all of the following areas:
• Determining Financial Goals And
• Mortgage and Refinance
Objectives
Evaluation
• Estate Plan Review or
Development
• Charitable (or social capital)
Panning
• Opinion on Current Investment
Strategy/Advisors
• Other financial or investment
• Asset Allocation Review
• Retirement Plan Analysis
• Employee Stock Option Analysis
• Current Portfolio Review
• Education Funding Analysis
• Cost Audit of Current Investments
• Cash Flow Management Review
• Review of Insurance Needs
analysis
Fiduciary Status
When AlpenGlobal Capital provides investment advice to you regarding your investment
accounts, including your retirement plan account or individual retirement account, we are
fiduciaries within the meaning of certain state and federal laws such as the Employee Retirement
Income Security Act and/or the Internal Revenue Code and the regulations of the U.S. Securities
and Exchange Commission, as applicable. These regulations require us to act in your best interest
and not put our interests ahead of yours.
General Notices
In performing its services, AlpenGlobal is not required to verify any information received from the
client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is authorized
to rely on such information as provided. Clients must promptly notify us of any change in their
financial situation or investment objectives that would necessitate a review or revision by our
advisors of the client’s portfolio and/or financial plan.
The Firm may recommend its own investment management or financial planning services or those
of other professionals to implement investment recommendations. Clients are advised that a
conflict of interest exists if the Firm recommends its own services and that recommendations that
favor securities investments over other investments such as limited partnerships, real estate or
insurance products may affect total assets under management upon which we base our
investment management fee.
Advisor Does Not Provide Comprehensive Tax or Accounting Advice
In providing investment management services, Advisor’s decisions and recommendations may
include the consideration of the possible alternative tax consequences incidental to such
decisions and recommendations.
However the Firm does not undertake to provide
comprehensive tax or accounting advice or counseling. Although we may prepare reports to
assist our clients with the preparation of tax returns, such reports do not represent the advice or
approval of tax professionals. We advise clients to consult a tax professional in order to determine
the tax and accounting consequences of investments in their accounts.
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TERMINATION OF AGREEMENT
Clients may terminate the investment management agreement upon 30 days written notice to
AlpenGlobal. The Firm does not assess any fees related to termination but will be entitled to all
management fees earned up to the date of termination. Any unearned fees owed to the client
will be refunded by AlpenGlobal on a pro rata basis determined on the amount of time expired
in the calendar quarter. AlpenGlobal may terminate the investment management agreement
upon 30 days’ written notice to the client. Any unearned investment management fees owed to
the client will be refunded on a pro rata basis determined on the amount of time expired in the
calendar quarter.
If a copy of this Form ADV Part 2A disclosure statement was delivered to the client less than 48
hours prior to a client entering into a written advisory contract with Advisor, then the client has the
right to terminate the contract without penalty within five (5) business days after entering into the
contract. For purposes of this provision, a contract is considered entered into when all parties to
the contract have signed the contract. If a client terminates the contract on this basis, all fees
pre-paid by the client will be refunded. Any investment action directed by a client or taken on a
client’s behalf with the client’s consent during such 5-day period may involve assessments made
by third party custodians or executing broker-dealers. Any transaction costs imposed by an
executing broker or custodian for establishing the custodial account or for trades occurring during
those five days may not be refunded by applicable broker-dealer.
Item 5 - FEES AND COMPENSATION
INVESTMENT MANAGEMENT FEES
For its portfolio management services, AlpenGlobal charges an investment management fee
based on a percentage of assets under management. All management fees are payable
quarterly in advance, based on the market value of the portfolio on the last day of the preceding
calendar quarter. For new accounts, AlpenGlobal charges a fee based on the value of assets
placed in the account, prorated to the portion of the calendar quarter during which the assets
were under management by the Firm. AlpenGlobal’s standard fee schedule is as follows:
Portfolio Value of Assets Under Management
On the First
Above
$ 5,000,000
$ 5,000,000
Annual Fee as a % of Assets
2.00%
1.50%
AlpenGlobal requires a minimum of $100,000 placed under management per client relationship.
Multiple accounts of a client may be aggregated to meet this minimum. Under certain
circumstances, and at the Firm’s sole discretion, we may waive the minimum account size and/or
minimum fee requirements or may negotiate an alternative fee based upon the nature of the
account.
The management fee is determined in accordance with the above standard fee structure, with
exceptions negotiated on a case-by-case basis at our discretion. Any deviations from the
standard fee structure are based upon a number of factors including the amount of work
involved, the amount of assets placed under management and the attention needed to manage
the account.
To the extent that a client authorizes the use of margin, and margin is thereafter employed by our
portfolio managers in the management of the client’s portfolio, the market value of the client’s
account and corresponding fee payable by the client to AlpenGlobal may be increased. As a
result, in addition to understanding and assuming the additional principal risks associated with the
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use of margin, clients authorizing margin are advised of the potential conflict of interest whereby
the client’s decision to employ margin may correspondingly increase the management fee
payable to the Firm. Accordingly, the decision as to whether to employ margin is left to the sole
discretion of client.
Clients authorize AlpenGlobal to deduct its quarterly investment advisory fee directly from their
custodial account. This authorization is granted under the terms of the client’s signed investment
management agreement. We send clients a copy of the investment advisory fee invoice at the
same time we request payment from the client’s custodian. It is the client’s responsibility to verify
the accuracy of the fee calculation, as the custodian will not determine whether the fee is
properly calculated.
GENERAL FEE DISCLOSURE
AlpenGlobal’s fee is comprehensive of many services that the clients of other investment advisors
may pay additional fees for, either directly to the advisor and/or indirectly as transaction costs or
as fund management or other security-related fees. As a result, the AlpenGlobal’s fees may
appear higher than advisory fees charged by other investment managers. However, the Firm’s
fee structure is based upon the experience, expertise, and investment style of its principal and
includes the active management of clients’ global portfolios. AlpenGlobal Capital believes that
this extensive due diligence is critical to reducing risk and improving performance in client
portfolios. Moreover, AlpenGlobal’s fee reflects the fact that, unlike most other investment
managers, AlpenGlobal pays for most client brokerage transaction, commission, and other
associated trading costs. Other investment managers may provide some individual services for
lower compensation, while others may charge more for the same or fewer services.
AlpenGlobal receives no commissions on investment products purchased or sold for client
accounts.
We do not provide clients advice as to the tax deductibility of our advisory fees. Clients are
directed to consult a tax professional to determine the potential tax deductibility of the payment
of advisory fees.
CUSTODIAN AND BROKERAGE FEES
Clients may incur certain charges imposed by their custodians and other third parties such as
custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and
electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions.
Additionally, clients may incur charges by the executing broker-dealer in the form of brokerage
commissions and transaction fees on the investment transactions entered into for their account(s).
All of these charges, fees and commissions are apart from AlpenGlobal’s investment
management fee.
FUND DISCLOSURES
Mutual funds, closed-end funds, exchange traded funds and alternative investment funds are
investment vehicles and the investment strategies, objectives and types of securities held by such
funds vary widely. In addition to the advisory fee charged by AlpenGlobal, clients indirectly pay
for the expenses and advisory fees charged by the funds in which their assets are invested. All
such funds incur operating expenses in connection with the management of the fund. Investment
funds pass some or all of these expenses through to their shareholders (the individual investors in
the funds) in the form of management fees. The management fees charged vary from fund to
fund. In addition, funds charge shareholders (individual investors in the funds) other types of fees
such as early redemption or transaction fees. These charges also vary widely among funds. As a
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result, clients will still pay management fees and other, “indirect” fees and expenses as charged
by each mutual fund (or other fund) in which they are invested.
Clients are provided a copy of a fund prospectus for each fund in which they invest by their
custodian or by the fund sponsor rather than by AlpenGlobal. As required by law, a prospectus
represents the fund’s complete disclosure of its management and fee structure. In addition, a
fund’s prospectus can be obtained directly from the fund.
Neither AlpenGlobal, nor its principal or employees, accept compensation for the sale of
securities or other investment products, including asset-based sales charges or fees from the sale
of mutual funds. A client could invest in most securities directly, without the services of
AlpenGlobal. In that case, the client would not receive the advisory and administrative services
provided by AlpenGlobal which are designed, among other things, to assist the client in
determining which investments are most appropriate given the client’s financial circumstances
and investment and retirement goals.
BOND DISCLOSURE
Clients whose assets are invested in bonds purchased directly from an underwriter may pay a sales
credit or sales concession to the underwriter on the trade (in lieu of a sales commission) ranging
from 0% - 2% of the par value of the bond.
Item 6 - PERFORMANCE-BASED FEES and SIDE-BY-SIDE MANAGEMENT
AlpenGlobal does not charge an additional performance fee based upon a percentage of the
capital gains realized in client accounts. AlpenGlobal does not manage any client accounts
where a performance fee is charged.
Item 7 - TYPES OF CLIENTS
Our clients include individuals, high net worth individuals, companies, trusts, estates, charitable
organizations and other entities. As a result of our minimum account size and management fee
requirements disclosed above, our services may not be appropriate for everyone. Particularly for
smaller accounts, other investment advisors may provide somewhat similar services for lower
compensation, although still others may charge more for similar services.
Item 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES, RISK OF LOSS
METHODS OF ANALYSIS
AlpenGlobal constructs and actively manages client portfolios using research and analysis to
identify secular global trends, potential company and industry catalysts and undervalued
companies. Depending upon the type of investment, AlpenGlobal utilizes a combination of
charting, fundamental and technical analyses. Fundamental analysis involves analyzing real
data, including overall economic and company-specific information available to determine the
value of a particular investment. Technical analysis involves analyzing statistics provided by
market activity such as past prices and volume to identify patterns that can be used to predict
future activity. In performing these analyses, the Firm consults research materials, company
annual reports and other regulatory filings, and financial newspapers and periodicals.
INVESTMENT STRATEGY
The firm aims to recommend and invest in equities with a holding period of 18-months to 3 years.
These investments are blended with mutual funds and/or Exchange Traded Funds that
complement the investment expertise of the portfolio manager to further diversify holdings while
managing risk. AlpenGlobal may, at times, recommend other investment strategies, such as
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options and short selling, amongst others, to opportunistically capture performance and/or to
protect investments and manage risk in client portfolios. The Firm takes a long-term perspective
on client portfolios and the investment recommendations, while actively managing the portfolio
on a day-to-day basis.
Alternative Investments
In addition to these types of investments the Firm also provides investment advice regarding
alternative investments to qualified clients for whom such investments are deemed suitable. These
alternative investments may include, but are not limited to, venture capital, limited partnerships,
private equity, managed future funds and hedge funds.
Initial Public Offerings (“IPOs”)
While not a substantial part of its investment style, AlpenGlobal does from time to time invest in
initial public offerings (“IPO”) on behalf of client accounts for which such investments are suitable.
Some client accounts do not participate in IPOs at all or do not participate in certain volatile IPOs,
either due to client instructions, risk tolerance, financial condition or investment objectives. When
client accounts are determined to be eligible to participate in a purchase of an IPO, and there is
an insufficient amount of shares of the IPO for all accounts eligible to participate in the trade,
AlpenGlobal uses a random generator to select participating accounts so that all eligible
accounts are selected from fairly.
INVESTMENT RISKS
All securities investments carry risk, including the risk that an investor may lose a part or all of his or
her initial investment. Risk refers to the uncertainty that the actual return the investor realizes could
differ from the expected return. Risks may be systematic, referring to factors that affect the returns
on all comparable investments and that affect the market as a whole. Systematic risks include
market risk, interest rate risk, reinvestment rate risk, purchasing power risk and exchange rate risk.
Unsystematic risks depend on factors that are unique to the specific investment security. These
risks include business risk and financial risk. Here are some of the general risks associated with parts
of our investment strategy:
Short-term purchases – on occasion, generally only for tax management purposes, we may
determine to buy or sell securities in a client’s account and hold them for less than a year. Some
of the risks associated with short-term trading that could affect investment performance are
increased commissions and transaction costs to the account and increased tax obligations on
the gains in a security’s value.
Bond Pricing – The price of bonds depends in part on the current rate of interest. Rising interest
rates decrease the current price of bonds because current purchasers require a competitive yield.
As such, decreasing interest rates increase the current value of bonds with associated decrease
in bond yield. We may decide to exchange to a lower or higher duration bond or to another asset
class due to interest rate risk that could affect investment performance.
Price Fluctuation - Security prices do fluctuate (except for cash or cash equivalents) and clients
must accept that risk associated with the fluctuations or change to a more appropriate
investment portfolio in alignment with their risk tolerance.
Reinvestment of Dividends - An investor can choose to reinvest interest, dividends and capital
gains to accumulate wealth. This is an appropriate strategy for a portfolio designed for capital
growth. However, the reinvested earnings could result in a lower or a higher rate than was initially
earned.
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Mutual Funds with Foreign Asset Holdings – Any investments in mutual funds that make foreign
investments are subject to the uncertainty with changes in the foreign currency value. The client
will bear more risk and may earn a substantially higher return or a substantially lower return.
Short Sale Trading – Short Sale Trading, or “shorting” involves a great amount of risk and is not
advocated by AlpenGlobal, nor is it a part of our investment strategy. In rare cases, short selling
may be used as directed by client to achieve specific goals.
Margin Trading –In some cases, and generally only for short term financing considerations, clients
may elect to assume a margin balance on their investment account. The client’s custodian may
require a percentage of assets under management to be pledged as collateral for the margin
amount. Clients risk that in a falling market, the pledged collateral will be insufficient to cover a
margin call by their custodian. Consequently, all margin decisions are left to the client.
Option Trading – Certain AlpenGlobal clients engage in option trading. Option securities are
complex derivatives of equity securities that incorporate certain leverage characteristics and as
such carry an increased risk of investment loss.
Alternative Asset Classes – Many alternative investments are illiquid, which means that the
investments can be difficult to trade. Consequently, such holdings may limit a client's ability to
dispose of such investments in a timely manner and at an advantageous price.
IPOs – Are generally investments in companies with limited operational histories and non-existent
or weak earnings and are highly subject to market sentiment. Shares purchased through an IPO
can often trade down immediately from their offer price or can be subject to wild fluctuations in
performance at certain time periods after their entry to the public markets and, as such, carry
increased risks of investment loss.
Private Equities – AlpenGlobal may purchase or recommend the inclusion of shares in non-publicly
traded equities in the accounts of accredited clients. These companies will generally have little
available information on their financial status, capital structure or revenues, resulting in increased
risk of loss, including total loss. In addition, these securities may be highly illiquid or may experience
losses of liquidity – resulting in an inability to sell said equities or sales prices that are substantially
below the purchase or market price. AlpenGlobal, unless otherwise expressly agreed, will value
these positions at their purchase price for any accounting purposes, which may not reflect losses
that would be realized if the position was sold. Of particular risk is that AlpenGlobal will base its
account values for billing purposes on these positions’ purchase price (unless another
methodology is agreed upon with the client), leading to a potential motivation to overvalue said
equities. Finally, AlpenGlobal may have clients who are executives of said firms or have other
financial relationships that may create conflicts of interest. Where such conflicts exist, AlpenGlobal
will disclose these conflicts to the clients who hold such securities or whom we intend to purchase
such securities under our discretion prior to any transactions.
Item 9 - DISCIPLINARY INFORMATION
AlpenGlobal has no disciplinary history and consequently, is not subject to any disciplinary
disclosures.
Item 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
AlpenGlobal is an independent investment advisor, unaffiliated with any other financial institution
or securities dealer or issuer.
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Although we may refer our clients to other professionals such as attorneys or accountants for
estate planning, tax or other matters, neither the Firm nor its principals or employees are affiliated
with any law or accountancy firm.
Item 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL
TRADING
AlpenGlobal, its employees and their immediate families (sometimes collectively "employees") are
permitted to buy and sell securities for their personal investment accounts. AlpenGlobal has
adopted employee personal trading policies and procedures and a code of ethics to govern Firm
and employee trading practices. AlpenGlobal’s members, officers and employees are required
to report all personal securities transactions to the Firm on a regular basis. Employees are required
to sign a certification agreeing to abide by the Firm’s personal trading practices and code of
ethics. The Firm will provide a copy of its Code of Ethics to any client or prospective client upon
request.
It is the policy of AlpenGlobal not to give preference to orders for personnel associated with the
Firm regarding employee trades in the same securities as client trades. Employees may personally
invest in the same securities that are purchased for client accounts and may own securities that
are subsequently purchased for client accounts. From time to time, trading by employees in
particular securities may be restricted in recognition of impending investment decisions on behalf
of clients. If a security is purchased or sold for client accounts and employees on the same day,
either employees will pay or receive the same price as the client account, or the client account
will receive the more favorable price. If purchased or sold on different days, it is possible that
employees’ transactions might be executed at more favorable prices than were obtained for
clients.
Employees may buy or sell different investments, based on personal investment considerations,
which AlpenGlobal may not deem appropriate to buy or sell for clients. It is also possible that
Employees may take investment positions for their own accounts that are contrary to those taken
on behalf of clients. Employees may also buy or sell a specific security for their personal account
based on personal investment considerations aside from company or industry fundamentals,
which are not deemed appropriate to buy or sell for clients. This can occur when securities which
are not suitable for clients at the time of purchase (e.g., speculative stocks, micro-cap stocks,
penny stocks), are purchased by employees. If these securities subsequently appreciate, these
personal transactions could be viewed as creating a conflict of interest.
Conversely, employees may liquidate a security position which is held both for their own account
and for the accounts of AlpenGlobal clients, sometimes in advance of clients. This occurs when
personal considerations (i.e. liquidity needs, tax-planning, industry/sector weightings) deem a
stock sale necessary for individual financial planning reasons. If the security subsequently falls in
price, these personal transactions could be viewed as creating a conflict of interest.
In rare circumstances, AlpenGlobal may recommend to clients the same securities that
employees previously acquired for themselves in non-public transactions. In addition, employees
may purchase options on the same securities held on behalf of clients.
AlpenGlobal employees may not “trade on” any knowledge they may have regarding the
potential market impact of transactions entered on behalf of clients.
Item 12 - BROKERAGE PRACTICES
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RECOMMENDATION OF CUSTODIAN AND EXECUTING BROKER
AlpenGlobal recommends that clients establish brokerage accounts with RBC Capital Markets,
LLC (“RBC”), a FINRA registered broker-dealer and member SIPC, to maintain their investment
accounts and custody ofclient assets and funds. RBC is independently owned and operated and
not affiliated with AlpenGlobal and do not supervise or otherwise monitor AlpenGlobal’s
investment management services to its clients.
RBC provides AlpenGlobal with access to institutional trading and custody services, which
typically are not available to retail investors. These services generally are available to
independent investment advisors on an unsolicited basis, at no charge to them so long as a
threshold level of the advisor's clients' assets is maintained in accounts at RBC but are not otherwise
contingent upon AlpenGlobal committing to RBC any specific amount of business (in the form of
either assets in custody or trading). RBC’s services include brokerage, custody, and other
investments that are otherwise generally available only to institutional investors or would require a
significantly higher minimum initial investment.
RBC may make available to AlpenGlobal other products and services that benefit AlpenGlobal
but may not benefit any individual AlpenGlobal client. Some of these other products and services
assist AlpenGlobal in managing and administering clients' accounts. These include software and
other technology that provide access to client account data (such as trade confirmations and
account statements); facilitate trade execution (and allocation of aggregated trade orders for
multiple client accounts); provide pricing information and other market data; facilitate payment
of AlpenGlobal’s fees from its clients' accounts; and assist with back-office functions,
recordkeeping and client reporting. Many of these services generally may be used to service all
or a substantial number of AlpenGlobal’s accounts, including accounts not maintained at RBC.
RBC also makes available other services intended to help AlpenGlobal manage and further
develop its business. These products or services may include consulting, publications and
conferences on practice management, information technology, business succession, regulatory
compliance and marketing.
AlpenGlobal’s recommendation that clients maintain their assets in accounts at RBC may be
based in part on the benefit to AlpenGlobal of the availability of some of the foregoing services
and not solely on the nature, cost or quality of custody and brokerage services provided by RBC,
which may create a potential conflict of interest.
BEST EXECUTION
AlpenGlobal is not obligated to obtain the best net price or lowest brokerage commission on any
particular transaction. Rather applicable law requires investment managers to act primarily for
the benefit of their clients to obtain the most favorable execution for each transaction executed
on behalf of client accounts.
In selecting broker-dealers, AlpenGlobal’s primary objective is to obtain the best execution.
Expected price, giving effect to brokerage commissions, if any, and other transaction costs are
factors, but the selection also takes account of other factors, including the execution, clearance
and settlement capabilities of the broker-dealer, the broker-dealer’s willingness to commit capital,
the broker-dealer’s reliability and financial stability, the size of the particular transaction and its
complexity in terms of execution and settlement, the market for the security, the value of any
other brokerage services provided by the broker-dealer, and the cost incurred by placing prime
brokerage trades in client accounts.
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Based upon an evaluation of some or all of these factors, AlpenGlobal may execute client trades
through broker-dealers that charge fees that are higher than the lowest available fees.
AlpenGlobal may select broker-dealers whose fees may be greater than those charged for similar
investments if AlpenGlobal determines that brokerage services provided by that broker-dealer
warrant the payment of higher fees.
AlpenGlobal reviews transaction results periodically to determine the quality of execution
provided by the various broker-dealers through whom AlpenGlobal executes transactions on
behalf of clients.
SOFT DOLLAR ARRANGEMENTS AND POTENTIAL CONFLICTS
AlpenGlobal does not currently participate in any arrangements whereby it directs client
brokerage to a broker dealer in exchange for “soft dollar” brokerage services. “Soft dollars” refers
to the use of brokerage commissions on client trades to pay for the soft dollar brokerage services
received. Soft dollar services might include among others, economic data and market
information, portfolio strategy advice, proxy voting services, industry and company comments,
technical data, recommendations, conferences, general reports, periodical subscription fees,
consultations, performance measurement data, on-line pricing, news wire charges, quotation
services, computer hardware and software.
AGGREGATION OF TRADES AND POTENTIAL CONFLICTS
AlpenGlobal may aggregate orders of more than one client if it is determined that aggregation
is in the best interests of the clients. Trade aggregation is usually sought to obtain lower
commissions and costs or a better transaction price. AlpenGlobal does not aggregate securities
transactions for client accounts unless we believe that aggregation is consistent with its duty to
seek best execution and is consistent with the investment objectives and guidelines for the client
accounts participating in the trade.
When orders are aggregated, the price paid by each account is the average price of the order.
Transaction costs are allocated to each client according to the client’s agreement with their
custodian. It is Firm policy that trades are not allocated in any manner that favors one group of
similarly situated clients over another. Client transactions may be aggregated according to
custodial relationship in consideration of execution charges that may be imposed if trades are
directed to a non-custodial broker-dealer for execution. Aggregated trades placed with different
executing brokers may be priced differently.
While AlpenGlobal believes combining transaction orders in this way should, over time, be
advantageous to all participants, in particular cases the average price could be less
advantageous to a particular client than if such client had been the only client effecting the
transaction or had completed its transaction before the other participants.
AlpenGlobal and/or its associated persons may participate in such aggregated orders to the
extent such employee trades are pre-authorized and consistent with the Firm’s code or ethics.
There may be circumstances in which transactions on behalf of AlpenGlobal or its associated
persons may not, under certain laws and regulations, be combined with those of some of
AlpenGlobal ’s other clients. In such cases, neither AlpenGlobal nor any associated person will
effect transactions in a security on the same day as clients until after the clients’ transactions have
been executed.
ALLOCATION OF OPPORTUNITIES AND POTENTIAL CONFLICTS
Because the Firm manages more than one client account, there may be a conflict of interest
related to the allocation of investment opportunities among all accounts managed by the Firm.
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The Firm attempts to resolve all such conflicts in a manner that is generally fair to all of clients over
time. AlpenGlobal may give advice and take action with respect to any of its clients that may
differ from advice given or the timing or nature of action taken with respect to any other client
based upon individual client circumstances. It is Firm policy, to the greatest extent practicable,
to allocate investment opportunities over a period of time on a fair and equitable basis relative to
all clients. The Firm is not obligated to acquire for any client account any security that the Firm or
its owners, officers, employees or affiliated persons may acquire for their own accounts or for the
account of any other client, if in the discretion of the portfolio managers, based upon the client’s
financial condition and investment objectives and guidelines, it is not practical or desirable to
acquire a position in such security for that account.
Item 13 - REVIEW OF ACCOUNTS
AlpenGlobal monitors client portfolios and investment advisory accounts as part of an ongoing
process. All client accounts are reviewed not less than quarterly by Alex Gutt, Managing Director
and Portfolio Manager of AlpenGlobal, for consistency with the Firm’s investment strategy and
performance and with client investment objectives. Additionally, client accounts are reviewed in
response to changes in the financial markets, changes in the Firm’s investment strategy, and/or
changes in individual client circumstances.
The client’s custodian provides written monthly reports to each client. These reports may include
an asset allocation of the account; a summary of assets held in the account (including cost and
market value), a chronological summary of transactions during the quarter; cumulative summary
of annual realized capital gains and losses and a calculation of the account’s performance for
the quarter and cumulatively since inception. In addition, each client receives transaction
confirmations and a monthly account statement directly from the custodian of their account.
Item 14 - CLIENT REFERRALS AND OTHER COMPENSATION
AlpenGlobal does not pay referral fees to any third-party firms or individuals for recommending
the Firm to prospective clients, nor is the Firm or its employees paid referral fees by any third party
for referring clients to their businesses. We do not direct brokerage transactions in exchange for
receiving client referrals. AlpenGlobal employees are not paid “sales awards” or other prizes for
referring clients to the Firm.
Item 15 - CUSTODY
AlpenGlobal does not maintain physical custody of client funds or securities. Clients are required
to set up their investment accounts with a “qualified custodian,” namely a broker dealer, bank or
trust company. AlpenGlobal is unable to take even temporary possession of client assets for the
purpose of transferring them to the client’s account. The client is responsible for making deposits
to and withdrawals from their account directly with their custodian as necessary.
Although AlpenGlobal does not maintain physical custody of client investment accounts, it is
deemed to have custody of client assets on the basis of the Firm’s authority to: 1. direct client-
approved transfers of assets between a client’s own accounts and if authorized, to client-
designated third-party accounts; and 2. to receive payment of its investment management fees
via direct payment by the client’s custodian from the client’s investment account.
Disclosures Related to Custodians
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RBC acts as the physical custodian for AlpenGlobal clients. RBC is independently owned and
operated and not affiliated with AlpenGlobal and does not supervise or otherwise monitor our
investment management services to our clients.
For AlpenGlobal client accounts maintained in its custody, RBC generally does not charge
separately for custody but is compensated by account holders through commissions or other
transaction-related fees for securities trades that are executed through RBC or that settle into
client accounts that are held with RBC. In most cases, trade executions for client accounts
custodied at RBC will be made by RBC to avoid “trade away” charges otherwise imposed for
trades executed at other broker-dealers. In cases where a desired security is not available for
purchase or sale through the custodial broker, and in light of the Firm’s best execution evaluation,
certain executions may be made at a different broker-dealer.
Item 16 - INVESTMENT DISCRETION
Clients appoint AlpenGlobal as their investment advisor and grant full trading and investment
authority over their assets at the time they establish their investment accounts. Subject to the
Firm’s investment strategy and the client’s investment objectives, our portfolio managers are given
full discretion to determine:
•
Types of investments;
• Which securities to buy;
• Which securities to sell;
•
•
•
The timing of any buys or sells;
The amount of securities to buy or sell; and
The broker-dealer to be used in the transaction.
This discretion may be limited by client investment guidelines and by any investment restrictions
set by the client. Where possible, the Firm will attempt to negotiate the commission rates at which
transactions for client accounts are effected, seeking to attain the most favorable price and
market execution for each transaction.
Item 17 - VOTING CLIENT SECURITIES
It is AlpenGlobal policy not to vote proxy solicitations received on behalf of clients from the issuers
of securities held in client’s account. All such solicitations will be forwarded to client for voting.
Any client wishing to review our proxy voting policies in full may request a copy from the Firm at
his or her convenience.
Item 18 - FINANCIAL INFORMATION
AlpenGlobal does not require or solicit prepayment of its investment management fees from
clients six or more months in advance. There are no adverse conditions related to the Firm’s
finances that are likely to impair its ability to meet its contractual commitments to its clients. The
Firm has not been the subject of a bankruptcy filing in the last ten years, or ever.
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FORM ADV PART 2B*
Brochure Supplement
Professional Background of
Alex J. Gutt
P.O. BOX 153
Tahoe City, California 96145
Tel: 415-424-4005
www.alpenglobalcapital.com
*This brochure provides information about the qualifications and business practices of
AlpenGlobal Capital, LLC’s (CRD No. 140186) principal, Alex J. Gutt. This is a supplement to the
AlpenGlobal Capital brochure which you should have received previously. Please contact the
Chief Compliance Officer, Karen Craig, if you have not received the brochure or if you have any
questions about the contents of this supplement. Additional information about AlpenGlobal
Capital LLC is available on the SEC’s website at www.adviserinfo.sec.gov.
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Each member of AlpenGlobal Capital’s professional staff is evaluated on the basis of his or her
education and work experience. Prior related business experience, a specialized business or
technical skill or applicable undergraduate/post-graduate work are required. In addition, any
associated persons involved in determining investment strategy or giving investment advice to
clients must meet the examination or experience requirements of the states in which they provide
investment advisory services.
_______________________________________________________
ALEX J. GUTT
Born:
1972
Item 2 - Educational Background and Business Experience
Education:
Santa Clara University, Santa Clara, California - Bachelor of Science, Finance (International
Business emphasis) and Minor in French - 1994
Business Background:
3/2006 – Present
AlpenGlobal Capital, LLC – San Francisco, CA
Managing Director, Portfolio Manager
2000 – 2005
Avalon Global Asset Management – San Francisco, CA
Founding Member, Senior Analyst
1997 – 1999
Montgomery Asset Management – San Francisco, CA
Senior Analyst
1996 – 1997
Barclays Global Investors – San Francisco, CA
Global Portfolio Accounting Analyst
1994 – 1996
Rhone-Poulenc Rorer SA (Aventis) – Paris, France
International Marketing Associate Marketing Analyst
Professional and Community Activities:
In addition to his professional career, Mr. Gutt spends a considerable amount of time volunteering
for various organizations. One might find him guiding at-risk urban youths in the Yosemite
backcountry with Big City Mountaineers, coaching soccer for Jamestown Community Center,
searching for lost skiers in the Sierra Nevada mountains as a member of the Tahoe Nordic Search
& Rescue Team or participating in a beach clean-up with the Surfrider Foundation. During his free
time, he pursues his outdoor passions: casting flies on mountain streams, hiking, biking & skiing in
the Sierras and sailing on San Francisco Bay. He is also an avid soccer player.
Item 3 – Disciplinary Information
Mr. Gutt has no legal or disciplinary events or disclosures.
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Item 4 – Other Business Activities
Mr. Gutt is involved in no other business activities.
Item 5 – Additional Compensation
Other than as disclosed in Item 12 of the Firm’s Form ADV Part 2A related to brokerage services
provided by client custodians, neither the Firm nor Mr. Gutt receives any economic benefit from
any non-client for the provision of investment advisory services. Employees are not paid “sales
awards” or other prizes for referring clients to the Firm.
Item 6 – Supervision
All Firm activities are supervised by Mr. Gutt and the Firm’s Chief Compliance Officer, Karen Craig,
whose supervision is ongoing and includes account reviews, trade supervision, annual
compliance reviews including the forensic testing of Firm systems.
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