Overview
Assets Under Management: $330 million
Headquarters: MOBILE, AL
High-Net-Worth Clients: 63
Average Client Assets: $4 million
Services Offered
Services: Portfolio Management for Individuals
Fee Structure
Primary Fee Schedule (AULL & MONROE ADV PART 2A BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.00% |
| $1,000,001 | $5,000,000 | 0.80% |
| $5,000,001 | and above | Negotiable |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $42,000 | 0.84% |
| $10 million | Negotiable | Negotiable |
| $50 million | Negotiable | Negotiable |
| $100 million | Negotiable | Negotiable |
Clients
Number of High-Net-Worth Clients: 63
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 81.11
Average High-Net-Worth Client Assets: $4 million
Total Client Accounts: 454
Discretionary Accounts: 454
Regulatory Filings
CRD Number: 104830
Last Filing Date: 2024-08-22 00:00:00
Website: https://aullmonroe.com
Form ADV Documents
Additional Brochure: AULL & MONROE ADV PART 2A BROCHURE (2025-05-02)
View Document Text
Item 1 – Cover Page
Aull & Monroe
Investment Management Corporation
CRD#: 104830
3658 College Ln S
Mobile, Alabama 36608
251-342-3339
www.aullmonroe.com
May 2, 2025
This Brochure provides information about the qualifications and business practices of Aull
& Monroe Investment Management Corporation (“Aull & Monroe”). If you have any
questions about the contents of this Brochure, please contact us at 251-342-3339. The
information in this Brochure has not been approved or verified by the United States
Securities and Exchange Commission (SEC) or by any state securities authority.
Aull & Monroe is a registered investment adviser with the SEC. Our registration as an
Investment Adviser does not imply any level of skill or training. The oral and written
communication we provide to you is information for your use in determining whether to
hire or retain us as your Adviser or to continue to maintain a mutually beneficial
relationship with us. Additional information about Aull & Monroe also is available on the
SEC’s website at www.adviserinfo.sec.gov.
i
Item 2 – Material Changes
Registered Investment Advisers are required to use the Brochure to inform clients of the
nature of advisory services provided, types of clients served, fees charged, potential
conflicts of interest and other information. The Brochure requirements include the annual
provision of a Summary of Material Changes (the “Summary”) reflecting any material
changes to our policies, practices, or conflicts of interest made since our last required
“annual update” filing. In the event of any material changes, such Summary is provided to
all clients within 120 days of our fiscal year-end. Of course, the complete Brochure is
available to clients at any time upon request. Our last annual update was made on March
25, 2025.
ii
Item 3 -Table of Contents
Item 1 – Cover Page .................................................................................................................................................................. i
Item 2 – Material Changes.................................................................................................................................................... ii
Item 3 -Table of Contents .................................................................................................................................................... iii
Item 4 – Advisory Business ................................................................................................................................................. 1
Item 5 – Fees and Compensation ...................................................................................................................................... 3
Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................... 5
Item 7 – Types of Clients ...................................................................................................................................................... 6
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................................ 6
Item 9 – Disciplinary Information .................................................................................................................................. 10
Item 10 – Other Financial Industry Activities and Affiliations ........................................................................... 10
Item 11 – Code of Ethics ..................................................................................................................................................... 10
Item 12 – Brokerage Practices ......................................................................................................................................... 12
Item 13 – Review of Accounts .......................................................................................................................................... 15
Item 14 – Client Referrals and Other Compensation .............................................................................................. 16
Item 15 – Custody .................................................................................................................................................................. 16
Item 16 – Investment Discretion ..................................................................................................................................... 16
Item 17 – Voting Client Securities .................................................................................................................................. 17
Item 18 – Financial Information ...................................................................................................................................... 17
Brochure Supplement(s)
iii
Item 4 – Advisory Business
Investment Advisory Services
Aull & Monroe Investment Management Corporation (“Aull & Monroe” or “we”), an SEC
registered investment adviser was founded in Mobile, Alabama in 1990 by our principal
owners, James P. Aull & W. Earl Monroe. Jamie L. Thuss joined the firm in 1997 and
became a partner alongside Mr. Aull and Dr. Monroe in 2004. Since its inception Aull &
Monroe has served our clients under the Investment Advisers Act of 1940 (the “Act”) and
complies with the Act’s fiduciary standard of care. This standard requires that we act
solely in your best interests when offering personal financial advice, including making
investment decisions on your behalf. As a fee-based investment adviser, Aull & Monroe
provides continuous investment management services to you based on your specific needs.
Aull & Monroe specializes in the creation and management of custom portfolios based on
factors pertaining to your personal situation and does not fit you into a “one-size fits all”
portfolio. While neither Aull & Monroe nor its employees hold themselves out as financial
planners, services provided include similar duties involved in financial planning such as
reviewing your personal financial situation, developing a retirement policy, providing risk
and tax management strategies in addition to implementing and ongoing review of your
investment plan.
Since its inception in 1990, Aull & Monroe has grown through capital contributions, the
reinvestment of earnings and new client relationships to reach over $329,144,863 in
discretionary assets under management as of December 31, 2024. Aull & Monroe does not
manage assets on a non-discretionary basis.
Our investment philosophy is generally long-term and oriented toward a balanced portfolio
of high-quality stocks and investment-grade bonds, augmented by a cash reserve. We also
manage all-stock portfolios as well as mutual funds and exchange traded funds. On behalf
of our client partners, Aull & Monroe seeks superior relative returns over time through
diversification, minimization of risk and the benefits of compounding.
Prior to engaging Aull & Monroe’s services, a client is required to enter into a written
agreement with Aull & Monroe setting forth the terms and conditions under which services
are provided (collectively the “Agreement”). As part of this Agreement, Aull & Monroe
obtains a limited power of attorney from the client providing us with discretionary
1
authority. As a discretionary investment adviser, we will have the authority to supervise
and direct the portfolio without prior consultation with you.
Notwithstanding the foregoing, clients may impose certain written restrictions on Aull &
Monroe in the management of their investment portfolios, such as prohibiting the inclusion
of certain types of investments in an investment portfolio or prohibiting the sale of certain
investments held in the account at the commencement of the relationship. Each client
should note, however, that restrictions imposed by a client may adversely affect the
composition and performance of the client’s investment portfolio. Each client should also
note that his or her investment portfolio is treated individually by considering each
purchase or sale for the client’s account. For these and other reasons, performance of
client investment portfolios within the same investment objectives, goals and/or risk
tolerance may differ, and clients should not expect that the composition or performance of
their investment portfolios would necessarily be consistent with similar clients of Aull &
Monroe.
Retirement Plan Advisory Services
The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under
which Plan Fiduciaries may retain investment advisers for various types of services with
respect to Plan assets. For certain services, Aull & Monroe will be considered a fiduciary
under ERISA.
Fiduciary Management Services
Participant Education (Non-Fiduciary Services)
Aull & Monroe serves as a Section 3(38) fiduciary investment advisor in our work with
qualified retirement plans under the Employee Retirement Income Security Act (“ERISA”).
We work closely with the other plan fiduciaries to develop an Investment Policy Statement,
reflecting the investment objectives, policies, constraints and risk tolerance of the plan.
Aull & Monroe uses this document as a guide to exercise discretionary investment
decisions for the plan.
For pension, profit sharing and 401(k) plan clients in self-directed plans for whom we have
been engaged for the discretionary or non-discretionary management services described
above, we may provide periodic educational support designed for the Plan Participants, if
2
provided for in our agreement with the client. The educational support will not provide
Plan Participants with individualized, tailored investment advice.
IRA Rollover Considerations
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide
investment advice to you regarding your retirement plan account or individual retirement
account, we are also fiduciaries 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. We have to act in your best interest and not put our interest
ahead of yours. If we recommend that you roll over or transfer your retirement assets into
an account to be managed by us, such a recommendation creates a conflict of interest if we
will earn a new (or increase our current) advisory fee because of the rollover or transfer.
Investing in an IRA with us will typically be more expensive than an employer-sponsored
retirement plan. You are under no obligation to roll over plan assets to an IRA managed by
us or to engage us to monitor and/or manage the account while maintained at your
employer.
Item 5 – Fees and Compensation
The specific manner in which fees are charged by Aull & Monroe is established in a client’s
written Agreement with Aull & Monroe. Aull & Monroe typically charges its clients a fee for
the investment advisory services offered based on a percentage of assets under
management. In certain limited situations, Aull & Monroe may charge a fixed fee or bill for
hourly charges based on a mutually agreed amount between the client and Aull & Monroe.
Management Fees will be payable beginning on the date the Agreement is executed or
based on a date thereafter (e.g., when the account(s) are funded or invested) (the “Billing
Inception Date”). Fees will be charged quarterly, in arrears, as of each third-month
anniversary of the Billing Inception Date (each, a “Billing Period”) based upon the value of
the assets as of the last day of the Billing Period. Management fees will not be prorated for
each capital contribution and withdrawal made to/from an account during the applicable
Billing Period.
3
Aull & Monroe’s annual asset-based fee schedule for a managed account, is as follows:
First $1,000,000
Next $4,000,000
Balance over $5,000,000
1.00%
0.80%
Negotiable, not to exceed 1.00%
Aull & Monroe, on its own discretion, may negotiate and charge a fee less than that
specified above based on certain situations (e.g., account composition such as more fixed
income which generally requires less time and research to manage, anticipated future
contributions, related accounts, etc.). Therefore, some clients may pay more or less than
other clients for the same management services.
Either Aull & Monroe or the client may choose to terminate the Agreement at any time
upon written notice as outlined in the Agreement. In the event of termination, we will
assess any fees owed us for the portion of the Billing Period the account(s) were managed.
Aull & Monroe’s fees are exclusive of brokerage commissions, transaction fees, and other
related costs and expenses which shall be incurred by the client. Clients may incur certain
charges imposed by custodians, brokers, and other third parties such as custodial fees,
odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees
and taxes on brokerage accounts and securities transactions.
Mutual funds, exchange traded funds and other investment pools also charge internal
management fees, which are disclosed in a fund’s prospectus or offering documents. Such
charges, fees and commissions are exclusive of and in addition to Aull & Monroe’s fee, and
Aull & Monroe shall not receive any portion of these commissions, fees, and costs. Aull &
Monroe as a matter of practice only invests in mutual funds with no load.
We do not use margin as an investment strategy. However, you may elect to borrow funds
against your investment portfolio. For accounts with a margin balance, you are assessed the
management fee based on the gross value of the assets in your account. In other words, your
account value on which the fee is calculated is not reduced by the margin balance. This could
create a conflict of interest where we may have an incentive to encourage the use of margin
to maintain a higher market value and therefore receive a higher fee.
4
Item 12
further describes the factors that Aull & Monroe considers in selecting or
e.g.
transactions and determining the reasonableness
recommending broker-dealers for client
of their compensation (
, commissions).
.
Clients may elect to be directly billed for management fees due Aull & Monroe, or with
written instruction and authorization, a client may elect to have the account custodian pay
fees due to Aull & Monroe directly from the managed account. The debited fee will also be
reflected on the monthly statement the client receives from the custodian. The account
custodian is not responsible for verifying the accuracy of the billing statement prior to
debiting the account
Retirement Plan Advisory Services Fees
Retirement Plan Advisory Services Fees are an annual percentage fee of assets under
management based on the following blended fee schedule:
First $1,000,000
Next $4,000,000
Balance over $5,000,000
1.00%
0.80%
Negotiable, not to exceed 1.00%
Plan Sponsors can decide whether the fees will be paid directly by the Plan Sponsor or
deducted from Plan assets. The specific fee arrangement, manner of collection, and timing
of fee payments will be set forth in the Plan’s written agreement with us. Our fees are
separate from and additional to any third-party administrative, custodial, recordkeeping,
or transaction fees incurred by the Plan and any Plan Participant accounts. We do not share
in any part of these fees. Fees are negotiable in our sole discretion.
Item 6 – Performance-Based Fees and Side-By-Side Management
Aull & Monroe does not charge any performance-based fees (fees based on a share of
capital gains on or capital appreciation of the assets of a client).
5
Item 7 – Types of Clients
Aull & Monroe provides portfolio management services to individuals, high net worth
individuals, corporate pension and profit-sharing plans, charitable organizations,
corporations and other organized businesses, including sole proprietorships. Individual
clients include trusts, estates, 401(K) participant accounts and IRAs of individuals and their
family members. Aull & Monroe also provides educational services to some 401(K) plan
participants.
Aull & Monroe requires clients to have a minimum investment of $100,000 in assets under
management. This may include investments in multiple accounts for individuals or
entities. Exception to the minimum is provided for pension and profit-sharing plans with
anticipated future contributions. In addition, Aull & Monroe, at its sole discretion, may
make exceptions to the minimum when deemed appropriate.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Aull & Monroe uses an investment strategy for the long-term investor which can consist of
high-quality stocks, exchange traded funds, mutual funds, master limited partnerships
(“MLPs”) and/or investment grade bonds augmented by a cash reserve. Each portfolio is
individually managed and tailored to reflect the client’s investment objectives, financial
needs and tolerance for risk. As a result, asset allocations vary from client to client. On
behalf of its client partners, Aull & Monroe seeks superior relative returns over time
through diversification, minimization of risk and the benefits of compounding. In short, the
aim is to maximize long-term returns while minimizing risk.
Aull & Monroe uses the attributes of Modern Portfolio Theory to incorporate selected
securities into individual client portfolios. This is a quantitative risk management strategy
in general use by professional asset managers throughout the world. Common stock
investments are usually limited to large-and-medium capitalization companies with an
established history of increasing earnings and dividends.
Fixed income investments may be used as an instrument to fulfill liquidity or income needs
6
in a portfolio, or to add a component of capital preservation. We will generally evaluate and
select individual bonds or bond funds based on several factors including, without
limitation, rating, yield and duration.
Mutual funds and ETFs are generally evaluated and selected based on a variety of factors,
including, without limitation, past performance, fee structure, portfolio manager, fund
sponsor, overall ratings for safety and returns, and other factors.
As most portfolios are assembled for clients investing for the long-term. Aull & Monroe’s
investment strategy is based on the benefits of compounding over time. Occasional
declines in the overall market are not viewed as a cause for concern but rather an
opportunity to buy.
Aull & Monroe’s strategy also calls for a very low rate of portfolio turnover. The turnover
rate of accounts managed by Aull & Monroe is generally lower than that of the average
asset manager. While Aull & Monroe buys and sells securities based on the perception of
value, economic conditions, trends and client needs, they do not attempt to “time the
markets” in relation to significant movements of assets into and out of common stocks.
Principal Risks of Investing
Issuer risk.
All investments are inherently risky, and setting a goal to earn superior returns, by its very
nature, entails varying degrees of risk taking. Investing in securities involves risk of loss
that clients should be prepared to bear. Aull & Monroe uses several well-recognized
methods to attempt to minimize risk. Portfolios may be diversified by including different
classes of assets such as stocks, bonds and money market funds as well as through
diversification among different industry groups within each asset class. However,
diversification does not guarantee protection from loss. Performance could be hurt by:
Securities held in managed portfolios may decline in value because of
changes in the financial condition of, or other events affecting, the issuers of these
Equity risk.
securities.
Equity securities generally have greater price volatility than fixed
income securities.
o Investing in growth stocks
- may involve greater price fluctuations and
7
greater potential for loss than other types of investments.
o Investing in income-oriented stocks
- may result in reduced income due to
changes in dividend policies of, and capital resources available to, the
company.
Fixed income/bond risk
. Rising interest rates will typically cause the prices of bonds
and other debt securities to fall. Falling interest rates may also cause an issuer to
redeem, call or refinance a security before its stated maturity. Longer maturity debt
securities may be subject to greater price fluctuations than shorter maturity debt
securities.
o Credit risk.
Credit risk is the possibility that the credit strength of an issuer
will weaken and/or an issuer of a debt security will fail to make timely
payments of principal or interest and the security will go into default.
o U.S. government backed securities.
These securities are only backed by the
U.S. Treasury or the full faith and credit of the U.S. government and
guaranteed only as to the timely payment of interest and principal when held
to maturity. The current market values will fluctuate with changes in
interest rates. Securities issued by government sponsored entities and
federal agencies are neither issued nor guaranteed by the U.S. government.
Market risk.
Prices of, and income generated by, securities may decline over short or
extended periods due to general market conditions.
Management risk.
Aull & Monroe’s opinion about the intrinsic worth of a company
or security may be incorrect, purchases and sales may not be made timely in a
client’s account and the market may continue to undervalue a security.
Risks of Investments in Mutual Funds, ETFs and Other Investment Pools.
As described
above, we will generally invest your portfolio in mutual funds, ETFs and other
investment pools (“pooled investment funds”). Investments in pooled investment
funds are generally less risky than investing in individual securities because of their
diversified portfolios; however, these investments are still subject to risks
associated with the markets in which they invest. In addition, pooled investment
funds’ success will be related to the skills of their particular managers and their
performance in managing their funds. Pooled investment funds are also subject to
8
risks due to regulatory restrictions applicable to registered investment companies
under the Investment Company Act of 1940
Liquidity risk.
Aull & Monroe may not be able to sell a security in a timely manner or
at desired prices.
Non-U.S. issuer risk and foreign exposure risk.
Foreign securities (including ADRs) and
securities with significant foreign exposure may decline in value because of political,
economic or market instability. Sometimes there is an absence of accurate
information about foreign companies as well as exposure to unfavorable government
actions, including expropriation and nationalization. Lack of uniform accounting,
auditing and financial reporting standards, with less government regulation and
oversight than U.S. companies may also increase risk.
MLP risk
. Aull & Monroe may recommend that portions of client portfolios be
allocated to master limited partnerships, otherwise known as “MLPs.” An MLP is a
publicly traded entity that is designed to provide tax benefits for the investor. In order
to preserve these benefits, the MLP must derive most, if not all, of its income from real
estate, natural resources and commodities. While MLPs may add diversification and
tax favored treatment to a client’s portfolio, they also carry significant risks beyond
more traditional investments such as stocks, bonds and mutual funds. One such risk
is management risk-the success of the MLP is dependent upon the manager’s
experience and judgment in selecting investments for the MLP. Another risk is the
governance structure, which means the rules under which the entity is run. The
investors are the limited partners of the MLP, with an affiliate of the manager typically
the general partner. This means the manager has all of the control in running the
entity, as opposed to an equity investment where shareholders vote on such matters
as board composition. There is also a significant amount of risk with the underlying
real estate, resources or commodities investments. Clients should ask us any
questions regarding the role of MLPs in their portfolio.
Margin Risk.
9
We do not use margin as an investment strategy. However, you may elect
to borrow funds against your investment portfolio. When securities are purchased,
they may be paid for in full or you may borrow part of the purchase price from the
account custodian. If you borrow part of the purchase price, you are engaging in
margin transactions and there is risk involved with this. The securities held in a
margin account are collateral for the custodian that loaned you money. If those
securities decline in value, then the value of the collateral supporting your loan also
declines. As a result, the brokerage firm is required to take action in order to maintain
the necessary level of equity in your account. The brokerage firm may issue a margin
call and/or sell other assets in your account to accomplish this. It is important that
you fully understand the risks involved in trading securities on margin, including but
−
not limited to:
−
−
−
−
−
It is possible to lose more funds than is deposited into a margin account;
The account custodian can force the sale of assets in the account;
The account custodian can sell assets in the account without contacting you first;
You are not entitled to choose which assets in a margin account may be sold to
meet a margin call;
The account custodian can increase its “house” maintenance margin requirements
at any time without advance written notice; and
You are not entitled to an extension of time on a margin call
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any
legal or disciplinary events that would be material to your evaluation of Aull & Monroe or
the integrity of Aull & Monroe’s management. Aull & Monroe has no information applicable
to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Aull & Monroe has no other financial industry activities or affiliations to report.
Item 11 – Code of Ethics
Code of Ethics and Personal Trading
We have adopted a Code of Ethics (“the Code”), the full text of which is available to you upon
10
request. Our Code has several goals. First, the Code is designed to assist us in complying
with applicable laws and regulations governing our duties to our clients. Pursuant to these
fiduciary duties, the Code requires persons associated with us (owners, managers, and
employees) to act with honesty, good faith and fair dealing in working with clients. In
addition, the Code prohibits such associated persons from trading or otherwise acting on
insider information.
Next, the Code sets forth guidelines for professional standards for our associated persons.
Under the Code’s Professional Standards, we expect our associated persons to put the
interests of our clients first, ahead of personal interests. In this regard, our associated
persons are not to take inappropriate advantage of their positions in relation to our clients.
Third, the Code sets forth policies and procedures to monitor and review the personal
trading activities of associated persons. From time to time, our associated persons may
invest in the same securities recommended to clients. Under the Code, we have adopted
procedures designed to reduce or eliminate conflicts of interest that this could potentially
cause. The Code’s personal trading policies include procedures for limitations on personal
securities transactions of associated persons, reporting and review of such trading and pre-
clearance of certain types of personal trading activities. These policies are designed to
discourage and prohibit personal trading that would disadvantage clients. The Code also
provides for disciplinary action as appropriate for violations.
Participation or Interest in Client Transactions
Because associated persons may invest in the same securities as those purchased in client
accounts, associated persons are required to wait until all client trades in a security have
been effected prior to effecting personal trades in the same security on the same day (subject
to certain exemptions). The goal of this policy is to avoid any conflicts of interest that arise
in these situations. However, in the event of other identified potential trading conflicts of
interest, our goal is to place client interests first.
Consistent with the foregoing, we maintain policies regarding participation in initial public
offerings (“IPOs”) and private placements to comply with applicable laws and avoid conflicts
with client transactions. Associated persons may not purchase IPOs and if they wish to
invest in a private placement, he or she must submit a pre-clearance request and obtain the
approval of the Chief Compliance Officer.
Finally, if associated persons trade with client accounts (i.e., in a bundled or aggregated
trade), and the trade is not filled in its entirety, the associated person’s shares will be
removed from the block, and the balance of shares will be allocated among client accounts
in accordance with our written policy.
11
Item 12 – Brokerage Practices
Best Execution and Benefits of Brokerage Selection
When given discretion to select the brokerage firm that will execute orders in client
accounts, we seek “best execution” for client trades, which is a combination of a number of
factors, including, without limitation, quality of execution, services provided and
commission rates. Therefore, we may use or recommend the use of brokers who do not
charge the lowest available commission in the recognition of research and securities
transaction services, or quality of execution. Research services received with transactions
may include proprietary or third-party research (or any combination), and may be used in
servicing any or all of our clients. Therefore, research services received may not be used
for the account for which the particular transaction was effected.
We recommend that clients establish brokerage accounts with Charles Schwab & Co., Inc.
(“Schwab”), a FINRA registered broker-dealer, member SIPC, as the qualified custodian to
maintain custody of clients’ assets. We will also effect trades for client accounts at Schwab,
or may in some instances, consistent with our duty of best execution and specific
agreement with each client, elect to execute trades elsewhere. Although we may
recommend that clients establish accounts at Schwab, it is ultimately your decision to
custody assets with Schwab. We are independently owned and operated and are not
affiliated with Schwab.
12
For our clients’ accounts that Schwab maintains, Schwab generally does not charge you
separately for custody services but is compensated by charging you commissions or other
fees on trades that it executes or that settle into your Schwab account. Certain trades may
not incur Schwab commissions or transaction fees. Schwab is also compensated by earning
interest on the uninvested cash in your account in Schwab’s Cash Features Program. In
addition to commissions, Schwab charges you a flat dollar amount as a “prime broker” or
“trade away” fee for each trade that we have executed by a different broker-dealer but
where the securities bought or the funds from the securities sold are deposited (settled)
into your Schwab account. These fees are in addition to the commissions or other
compensation you pay the executing broker/dealer. Because of this, in order to minimize
your trading costs, we have Schwab execute most trades for your account. We have
determined that having Schwab execute most trades is consistent with our duty to seek
“best execution” of your trades. Best execution means the most favorable terms for a
transaction based on all relevant factors.
Schwab Advisor Services provides us with access to its institutional trading, custody,
reporting and related services, which are typically not available to Schwab retail investors.
Schwab also makes available various support services. Some of those services help us
manage or administer our clients’ accounts while others help us manage and grow our
business. These services generally are available to independent investment advisors on an
unsolicited basis, at no charge to them. These services are not soft dollar arrangements but
are part of the institutional platform offered by Schwab. Schwab’s brokerage services
include the execution of securities transactions, custody, research, and access to mutual
funds and other investments that are otherwise generally available only to institutional
investors or would require a significantly higher minimum initial investment.
Schwab Advisor Services also makes available to Aull & Monroe other products and
services that benefit Aull & Monroe but may not directly benefit its clients’ accounts. Many
of these products and services may be used to service all or some substantial number of
Aull & Monroe accounts, including accounts not maintained at Schwab.
Schwab’s products and services that assist us in managing and administering clients’
accounts include software and other technology that (i) provide access to client account
data (such as trade confirmations and account statements); (ii) facilitate trade execution
and allocate aggregated trade orders for multiple client accounts; (iii) provide pricing and
other market data; (iv) facilitate payment of Aull & Monroe’s fees from its clients’ accounts;
and (v) assist with back-office functions, recordkeeping and client reporting.
Schwab Advisor Services also offers other services intended to help us manage and further
develop our business enterprise. These services may include: (i) technology, compliance,
legal and business consulting; (ii) publications and conferences on practice management
and business succession; and (iii) access to employee benefits providers, human capital
consultants and insurance providers. Schwab may make available, arrange and/or pay
third-party vendors for the types of services rendered to us. Schwab Advisor Services may
discount or waive fees it would otherwise charge for some of these services or pay all or a
part of the fees of a third-party providing these services to us. Schwab Advisor Services
13
may also provide other benefits such as educational events or occasional business
entertainment of our personnel. In evaluating whether to recommend that clients custody
their assets at Schwab, we may take into account the availability of some of the foregoing
products and services and other arrangements as part of the total mix of factors it
considers and not solely on the nature, cost or quality of custody and brokerage services
provided by Schwab, which may create a potential conflict of interest.
Directed Brokerage
In very limited instances, we may allow you to direct us to use a particular broker for
custodial or transaction services on behalf of your portfolio. In directed brokerage
arrangements, you are responsible for negotiating the commission rates and other fees to
be paid to the broker. Accordingly, if you direct brokerage, you should consider whether
such designation may result in certain costs or disadvantages, either because you may pay
higher commissions or obtain less favorable execution, or the designation limits your
available investment options.
The arrangement that we have with Schwab is designed to maximize efficiency and to be
cost effective. By directing brokerage arrangements, you acknowledge that these
economies of scale and levels of efficiency are generally compromised when alternative
brokers are used. While every effort is made to treat clients fairly over time, if you choose
to use the brokerage and/or custodial services of these alternative service providers, it can
result in a certain degree of delay in executing trades for your account(s) and otherwise
adversely affect management of your account(s).
By directing us to use a specific broker or dealer, clients who are subject to ERISA confirm
and agree that they have the authority to make the direction, that there are no provisions in
any client or plan document which are inconsistent with the direction, that the brokerage
and other goods and services provided by the broker or dealer through the brokerage
transactions are provided solely to and for the benefit of the client’s plan, plan participants
and their beneficiaries, that the amount paid for the brokerage and other services have
been determined by the client and the plan to be reasonable, that any expenses paid by the
broker on behalf of the plan are expenses that the plan would otherwise be obligated to
pay, and that the specific broker or dealer is not a party in interest of the client or the plan
as defined under applicable ERISA regulations.
14
Aggregated Trade Policy
We typically direct trading in your accounts as and when trades are appropriate based on
your Investment Plan, without regard to activity in other client accounts. However, from
time to time, we may aggregate trades together for multiple client accounts, most often
when these accounts are being directed to sell the same securities. If such an aggregated
trade is not completely filled, Aull & Monroe will allocate shares received (in an aggregated
purchase) or sold (in an aggregated sale) across participating accounts on a pro rata or
other fair basis; provided, however, that any participating accounts that are owned by us or
our officers, directors, or employees will be excluded first.
Item 13 – Review of Accounts
Accounts under the continuous management of Aull & Monroe are reviewed formally at
least monthly by a designated portfolio manager/officer of Aull & Monroe. Accounts are
reviewed as to individual holdings in the account, appropriate asset allocation and sector
diversification based on the individual clients stated objectives and any changes in market
conditions. Performance of individual accounts is also compared to the modeled index
which most closely matches an account’s stated objective and adjusted as necessary.
While individual accounts are reviewed on a monthly basis, Aull & Monroe reviews
recommended securities on an ongoing basis. Depending on the continuous research and
analyses of the securities, changes are considered for the individual portfolios holding such
securities or for using any cash reserve for investment in new securities.
15
Clients of Aull & Monroe will receive trade confirmations as well as at least quarterly
statements directly from the qualified custodian (i.e. bank trust department or broker-
dealer) of the account held in their name. Per the client’s request, these “mailings” may be
delivered to them electronically via the custodian. In addition to the custodial reports, Aull
& Monroe delivers a more detailed written report to the client on a quarterly basis
providing an inventory of the account holdings, analysis of the account since its inception
and how it has performed against a modeled index (i.e. S&P 500 or Balanced Index)
comparable to the accounts stated objective. Clients are asked to notify Aull & Monroe
immediately regarding any changes to their financial situation or investment objectives
and encouraged to meet for a formal review of their portfolio at least annually.
Item 14 – Client Referrals and Other Compensation
As noted above, we receive an economic benefit from the Custodians in the form of support
products and services they make available to us and other independent investment
Item 12 -
advisors whose clients maintain accounts with them. These products and services, how
Brokerage Practices.
they benefit our firm, and the related conflicts of interest are described in
The availability of the Custodians’ products and services to us is
based solely on our participation in the Programs and not in the provision of any particular
investment advice. Neither the Custodians nor any other party is paid to refer clients to us.
Item 15 – Custody
Schwab is the custodian of nearly all our client accounts. However, from time to time,
clients may select an alternate broker to hold accounts in custody. In any case, it is the
custodian’s responsibility to provide you with confirmations of trading activity, tax forms
and at least quarterly account statements. You are advised to review this information
carefully, and to notify us of any questions or concerns. You are also asked to promptly
notify us if the custodian fails to provide statements on each account held.
From time to time, we will provide additional reports. We urge you to compare the account
balances reflected on these reports to the balances shown on the brokerage statements to
ensure accuracy. At times there may be small differences due to the timing of dividend
reporting and pending trades.
Item 16 – Investment Discretion
Item 4 - Advisory Business
, we manage portfolios on a
As described above under
discretionary basis. This means that we will not obtain specific consent from you for each
transaction we place on your behalf. For discretionary accounts, you will execute a Limited
Power of Attorney (“LPOA”), giving us the authority to carry out various activities in the
account, generally including the following: trade execution; the ability to request checks on
your behalf (depending on the custodian), and the withdrawal of advisory fees directly
16
from your account(s). We then direct investment of your portfolio using our discretionary
authority. You may limit the terms of the LPOA to the extent consistent with your
investment advisory agreement with us and the requirements of your custodian. The
discretionary relationship is further described in the investment advisory agreement
between us.
Item 17 – Voting Client Securities
It is the policy of Aull & Monroe to vote client proxies on their behalf. Where Aull & Monroe
votes proxies for clients, the firm uses its fiduciary obligations of prudence and loyalty to
vote in the best interests of its clients. Aull & Monroe considers, on a case-by-case basis,
those factors that may affect the long-term value of the underlying investment on behalf of
the beneficial owners, in this case, all clients including participants of ERISA qualified
retirement plans.
Aull & Monroe has a contractual arrangement with a third-party vendor to vote proxies
using a secure proxy management platform. This service allows Aull & Monroe an effective
method of voting and records retention for all proxies, making documentation easily
accessible should clients wish to view a specific proxy vote.
You may obtain a free copy of Aull & Monroe’s complete proxy voting policies and
procedures upon request. Clients may also obtain information from Aull & Monroe about
how Aull & Monroe voted any proxies on behalf of their account(s).
Item 18 – Financial Information
Registered investment advisers are required in this Item to provide you with certain
financial information or disclosures about Aull & Monroe’s financial condition. Aull &
Monroe has no financial commitment that impairs its ability to meet contractual and
fiduciary commitments to clients, and has not been the subject of a bankruptcy proceeding.
17