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Item 1: Cover Page
450 Kings Hwy N.E.
Dover, DE 19901
Form ADV Part 2A – Firm Brochure
302-734-7526
Dated February 26, 2026
This Brochure provides information about the qualifications and business practices of Boothe Investment Group
Inc., “B.I.G. Investment Services”. If you have any questions about the contents of this Brochure, please contact
us at 302-734-7526. The information in this Brochure has not been approved or verified by the United States
Securities and Exchange Commission or by any state securities authority.
Boothe Investment Group Inc. is registered as an investment adviser with the SEC. Registration of an investment
adviser does not imply any level of skill or training.
information about B.I.G.
Investment Services
is available on
the SEC’s website at
Additional
www.adviserinfo.sec.gov which can be found using the firm’s identification number 291437.
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Since the last filing of the Form ADV Part 2A, dated February 18, 2025, there have been no material changes.
Item 2: Material Changes
Please note, this item only discusses changes we consider material, and not all changes made.
Item 3: Table of Contents
Contents
Item 1: Cover Page ............................................................................................................................................ 1
Item 2: Material Changes .................................................................................................................................. 2
Item 3: Table of Contents .................................................................................................................................. 2
Item 4: Advisory Business .................................................................................................................................. 3
Item 5: Fees and Compensation ........................................................................................................................ 6
Item 6: Performance-Based Fees and Side-By-Side Management ................................................................... 7
Item 7: Types of Clients ..................................................................................................................................... 7
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .............................................................. 7
Item 9: Disciplinary Information...................................................................................................................... 10
Item 10: Other Financial Industry Activities and Affiliations .......................................................................... 10
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................... 11
Item 12: Brokerage Practices .......................................................................................................................... 13
Item 13: Review of Accounts ........................................................................................................................... 13
Item 14: Client Referrals and Other Compensation ........................................................................................ 14
Item 15: Custody ............................................................................................................................................. 14
Item 16: Investment Discretion ....................................................................................................................... 14
Item 17: Voting Client Securities ..................................................................................................................... 14
Item 18: Financial Information ........................................................................................................................ 15
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Description of Advisory Firm
Item 4: Advisory Business
Boothe Investment Group Inc. is registered as an investment adviser with the Securities and Exchange
Commission. We were founded in 2005. David F. Boothe is the principal owner of B.I.G. Investment Services.
As of December 31, 2025, we manage $366,226,952 on a discretionary basis and $3,087,266 on a non-
discretionary basis.
Types of Advisory Services
Investment Management Services
We are in the business of managing individually tailored investment portfolios. Our firm provides continuous
advice to a client regarding the investment of client funds based on the individual needs of the client.
Through personal discussions in which goals and objectives based on a client's particular circumstances are
established, we develop a client's personal investment policy or an investment plan with an asset allocation
target and create and manage a portfolio based on that policy and allocation target. During our data-
gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity
needs. We may also review and discuss a client’s prior investment history, as well as family composition and
background.
Account supervision is guided by the stated objectives of the client (e.g., maximum capital appreciation,
growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable
restrictions on investing in certain securities, types of securities, or industry sectors. Fees pertaining to this
service are outlined in Item 5 of this brochure.
Financial Planning
Financial planning is a comprehensive evaluation of a client’s current and future financial state by using
currently known variables to predict future cash flows, asset values and withdrawal plans. The key defining
aspect of financial planning is that through the financial planning process, all questions, information and
analysis will be considered as they impact and are impacted by the entire financial and life situation of the
client. Clients purchasing this service will receive a written or an electronic report, providing the client with
a detailed financial plan designed to achieve his or her stated financial goals and objectives.
The client always has the right to decide whether or not to act upon our recommendations. If the client
elects to act on any of the recommendations, the client always has the right to affect the transactions
through anyone of their choosing.
In general, the financial plan will address any or all of the following areas of concern. The client and advisor
will work together to select the specific areas to cover. These areas may include, but are not limited to, the
following:
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• Business Planning: We provide consulting services for clients who currently operate their own
business, are considering starting a business, or are planning for an exit from their current business.
Under this type of engagement, we work with you to assess your current situation, identify your
objectives, and develop a plan aimed at achieving your goals.
• Cash Flow and Debt Management: We will conduct a review of your income and expenses to
determine your current surplus or deficit along with advice on prioritizing how any surplus should be
used or how to reduce expenses if they exceed your income. Advice may also be provided on which
debts to pay off first based on factors such as the interest rate of the debt and any income tax
ramifications. We may also recommend what we believe to be an appropriate cash reserve that
should be considered for emergencies and other financial goals, along with a review of accounts
(such as money market funds) for such reserves, plus strategies to save desired amounts.
• College Savings: Includes projecting the amount that will be needed to achieve college or other post-
secondary education funding goals, along with advice on ways for you to save the desired amount.
Recommendations as to savings strategies are included, and, if needed, we will review your financial
picture as it relates to eligibility for financial aid or the best way to contribute to grandchildren (if
appropriate).
• Employee Benefits Optimization: We will provide review and analysis as to whether you, as an
employee, are taking the maximum advantage possible of your employee benefits. If you are a
business owner, we will consider and/or recommend the various benefit programs that can be
structured to meet both business and personal retirement goals.
• Estate Planning: This usually includes an analysis of your exposure to estate taxes and your current
estate plan, which may include whether you have a will, powers of attorney, trusts and other related
documents. Our advice also typically includes ways for you to minimize or avoid future estate taxes
by implementing appropriate estate planning strategies such as the use of applicable trusts.
We always recommend that you consult with a qualified attorney when you initiate, update, or
complete estate planning activities. We may provide you with contact information for attorneys who
specialize in estate planning when you wish to hire an attorney for such purposes. From time-to-
time, we will participate in meetings or phone calls between you and your attorney with your
approval or request.
• Financial Goals: We will help clients identify financial goals and develop a plan to reach them. We
will identify what you plan to accomplish, what resources you will need to make it happen, how much
time you will need to reach the goal, and how much you should budget for your goal.
•
Insurance: Review of existing policies to ensure proper coverage for life, health, disability, long-term
care, liability, home and automobile.
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•
Investment Analysis: This may involve developing an asset allocation strategy to meet clients’
financial goals and risk tolerance, providing information on investment vehicles and strategies,
reviewing employee stock options, as well as assisting you in establishing your own investment
account at a selected broker/dealer or custodian. The strategies and types of investments we may
recommend are further discussed in Item 8 of this brochure.
• Retirement Planning: Our retirement planning services typically include projections of your
likelihood of achieving your financial goals, typically focusing on financial independence as the
primary objective. For situations where projections show less than the desired results, we may make
recommendations, including those that may impact the original projections by adjusting certain
variables (e.g., working longer, saving more, spending less, taking more risk with investments).
If you are near retirement or already retired, advice may be given on appropriate distribution
strategies to minimize the likelihood of running out of money or having to adversely alter spending
during your retirement years.
• Risk Management: A risk management review includes an analysis of your exposure to major risks
that could have a significantly adverse effect on your financial picture, such as premature death,
disability, property and casualty losses, or the need for long-term care planning. Advice may be
provided on ways to minimize such risks and about weighing the costs of purchasing insurance versus
the benefits of doing so and, likewise, the potential cost of not purchasing insurance (“self-insuring”).
• Tax Planning Strategies: Advice may include ways to minimize current and future income taxes as a
part of your overall financial planning picture. For example, we may make recommendations on
which type of account(s) or specific investments should be owned based in part on their “tax
efficiency,” with consideration that there is always a possibility of future changes to federal, state or
local tax laws and rates that may affect your situation.
We recommend that you consult with a qualified tax professional before initiating any tax planning
strategy, and we may provide you with contact information for accountants or attorneys who
specialize in this area if you wish to hire someone for such purposes. We will participate in meetings
or phone calls between you and your tax professional with your approval.
Client Tailored Services and Client Imposed Restrictions
We offer the same suite of services to all our clients. However, specific client financial plans and their
implementation are dependent upon a client Investment Policy Statement, which outlines each client’s
current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific plan
to aid in the selection of a portfolio that matches restrictions, needs, and targets.
Wrap Fee Programs
We do sponsor and participate in a wrap fee program. Please see our Appendix 1 regarding our wrap
program information.
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Item 5: Fees and Compensation
Please note, unless a client has received the firm’s disclosure brochure at least 48 hours prior to signing the
investment advisory contract, the investment advisory contract may be terminated by the client within five
(5) business days of signing the contract without incurring any advisory fees and without penalty. How we
are paid depends on the type of advisory service we are performing. Please review the fee and compensation
information below.
Investment Management Services
Our standard advisory fee is based on the market value of the assets under management and is calculated
as follows:
Account Value
Annual Advisory Fee
1.25%
$0 - $999,999
0.95%
$1,000,000 - $3,000,000
0.75%
$3,000,001 and Above
The annual fees are negotiable and are pro-rated and paid in advance on a quarterly basis. The advisory fee
is a blended fee and is calculated by assessing the percentage rates using the predefined levels of assets as
shown in the above chart. No increase in the annual fee shall be effective without agreement from the client
by signing a new agreement or amendment to their current advisory agreement.
Advisory fees are directly debited from client accounts. Accounts initiated or terminated during a calendar
quarter will be charged a pro-rated fee calculated according to the amount of time remaining in the billing
period. An account may be terminated with written notice at least 15 calendar days in advance. Upon
termination of the account, any unearned fee will be refunded to the client on a prorated basis.
Other Types of Fees and Expenses
Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses
that may be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, 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. Mutual fund and exchange traded funds also charge internal management fees, which are
disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to our
fee, and we shall not receive any portion of these commissions, fees, and costs.
Item 12 further describes the factors that we consider in selecting or recommending broker-dealers for
client’s transactions and determining the reasonableness of their compensation (e.g., commissions).
We do not accept compensation for the sale of securities or other investment products including asset-
based sales charges or service fees from the sale of mutual funds.
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We do not offer performance-based fees.
Item 6: Performance-Based Fees and Side-By-
Side Management
We provide financial planning and portfolio management services to individuals, high net-worth individuals,
pension and profiting sharing plans and corporations or other businesses.
Item 7: Types of Clients
We do have a minimum account size requirement of $250,000, however we may waive this at our
discretion.
Our primary methods of investment analysis are fundamental, technical, and cyclical analysis.
Item 8: Methods of Analysis, Investment
Strategies and Risk of Loss
Fundamental analysis involves analyzing individual companies and their industry groups, such as a
company’s financial statements, details regarding the company’s product line, the experience, and expertise
of the company’s management, and the outlook for the company’s industry. The resulting data is used to
measure the true value of the company’s stock compared to the current market value. The risk of
fundamental analysis is that information obtained may be incorrect and the analysis may not provide an
accurate estimate of earnings, which may be the basis for a stock’s value. If securities prices adjust rapidly
to new information, utilizing fundamental analysis may not result in favorable performance.
Technical analysis involves using chart patterns, momentum, volume, and relative strength in an effort to
pick sectors that may outperform market indices. However, there is no assurance of accurate forecasts or
that trends will develop in the markets we follow. In the past, there have been periods without discernible
trends and similar periods will presumably occur in the future. Even where major trends develop, outside
factors like government intervention could potentially shorten them.
Furthermore, one limitation of technical analysis is that it requires price movement data, which can translate
into price trends sufficient to dictate a market entry or exit decision. In a trendless or erratic market, a
technical method may fail to identify trends requiring action. In addition, technical methods may overreact
to minor price movements, establishing positions contrary to overall price trends, which may result in losses.
Finally, a technical trading method may under perform other trading methods when fundamental factors
dominate price moves within a given market.
Cyclical analysis is a type of technical analysis that involves evaluating recurring price patterns and trends
based upon business cycles. Economic/business cycles may not be predictable and may have many
fluctuations between long term expansions and contractions. The lengths of economic cycles may be difficult
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to predict with accuracy and therefore the risk of cyclical analysis is the difficulty in predicting economic
trends and consequently the changing value of securities that would be affected by these changing trends.
Tactical Index Investment
We primarily practice a tactical investment strategy. This involves building portfolios that are comprised of
various distinct asset classes. The asset classes are weighted in a manner to achieve a desired relationship
between correlation, risk, and return. Funds that passively capture the returns of the desired asset classes
are placed in the portfolio as well as individual equities. The funds that are used to build passive portfolios
are typically index mutual funds or exchange traded funds. Once we have determined the proper balance
between your risk tolerance and your need for growth and/or income, we allocate your money to help meet
those parameters. We then deploy a tactical approach within those parameters to try and enhance returns
and minimize risk depending on current market conditions.
Index fund investment is characterized by low portfolio expenses (i.e., the funds inside the portfolio have
low internal costs), minimal trading costs (due to infrequent trading activity), and relative tax efficiency
(because the funds inside the portfolio are tax efficient and turnover inside the portfolio is minimal).
Material Risks Involved
All investing strategies we offer involve risk and may result in a loss of your original investment which you
should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities and any other
investment or security. Material risks associated with our investment strategies are listed below.
Market Risk: Market risk involves the possibility that an investment’s current market value will fall because
of a general market decline, reducing the value of the investment regardless of the success of the issuer’s
operations or its financial condition.
Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work as intended.
Small and Medium Cap Company Risk: Securities of companies with small and medium market
capitalizations are often more volatile and less liquid than investments in larger companies. Small and
medium cap companies may face a greater risk of business failure, which could increase the volatility of the
client’s portfolio.
Concentration Risk: Certain investment strategies focus on particular asset-classes, industries, sectors or
types of investment. From time to time these strategies may be subject to greater risks of adverse
developments in such areas of focus than a strategy that is more broadly diversified across a wider variety
of investments.
Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may fall
below par value or the principal investment. The opposite is also generally true: bond prices generally rise
when interest rates fall. In general, fixed income securities with longer maturities are more sensitive to these
price changes. Most other investments are also sensitive to the level and direction of interest rates.
Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or the
securities’ claim on the issuer’s assets and finances.
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Inflation: Inflation may erode the buying-power of your investment portfolio, even if the dollar value of your
investments remains the same.
Risks Associated with Securities
Apart from the general risks outlined above which apply to all types of investments, specific securities may
have other risks.
Commercial Paper is, in most cases, an unsecured promissory note that is issued with a maturity of 270 days
or less. Being unsecured the risk to the investor is that the issuer may default.
Common stocks may go up and down in price quite dramatically, and in the event of an issuer’s bankruptcy
or restructuring could lose all value. A slower-growth or recessionary economic environment could have an
adverse effect on the price of all stocks.
Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest and
repay the amount borrowed either periodically during the life of the security and/or at maturity.
Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay
current interest, but rather are priced at a discount from their face values and their values accrete over time
to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest
rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates
rise and increase when interest rates fall. The longer the time to a bond’s maturity, the greater its interest
rate risk.
Bank Obligations including bonds and certificates of deposit may be vulnerable to setbacks or panics in the
banking industry. Banks and other financial institutions are greatly affected by interest rates and may be
adversely affected by downturns in the U.S. and foreign economies or changes in banking regulations.
Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes, including
the construction of public facilities. Municipal bonds pay a lower rate of return than most other types of
bonds. However, because of a municipal bond’s tax-favored status, investors should compare the relative
after-tax return to the after-tax return of other bonds, depending on the investor’s tax bracket. Investing in
municipal bonds carries the same general risks as investing in bonds in general. Those risks include interest
rate risk, reinvestment risk, inflation risk, market risk, call or redemption risk, credit risk, and liquidity and
valuation risk.
Options and other derivatives carry many unique risks, including time-sensitivity, and can result in the
complete loss of principal. While covered call writing does provide a partial hedge to the stock against which
the call is written, the hedge is limited to the amount of cash flow received when writing the option. When
selling covered calls, there is a risk the underlying position may be called away at a price lower than the
current market price.
Exchange Traded Funds prices may vary significantly from the Net Asset Value due to market conditions.
Certain Exchange Traded Funds may not track underlying benchmarks as expected.
Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the client indirectly
bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the client
will incur higher expenses, many of which may be duplicative. In addition, the client’s overall portfolio may
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be affected by losses of an underlying fund and the level of risk arising from the investment practices of an
underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares
may trade at a market price that is above or below their net asset value; (ii) the ETF may employ an
investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the
listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the
activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock
trading generally. The Adviser has no control over the risks taken by the underlying funds in which clients
invest.
Criminal or Civil Actions
Item 9: Disciplinary Information
B.I.G. Investment Services and its management have not been involved in any criminal or civil action.
Administrative Enforcement Proceedings
B.I.G. Investment Services and its management have not been involved in administrative enforcement
proceedings.
Self-Regulatory Organization Enforcement Proceedings
B.I.G. Investment Services and its management have not been involved in legal or disciplinary events that
are material to a client’s or prospective client’s evaluation of B.I.G. Investment Services or the integrity of
its management.
No B.I.G. Investment Services employee is registered, or have an application pending to register, as a broker-
dealer or a registered representative of a broker-dealer.
Item 10: Other Financial Industry Activities
and Affiliations
No B.I.G. Investment Services employee is registered, or have an application pending to register, as a futures
commission merchant, commodity pool operator or a commodity trading advisor.
B.I.G. Investment Services only receives compensation directly from clients. We do not receive
compensation from any outside source. We do not have any conflicts of interest with any outside party.
David Boothe is licensed to sell life and health insurance; however, he does not engage in product sales with
our clients.
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Item 11: Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading
As a fiduciary, our firm and its associates have a duty of utmost good faith to act solely in the best interests
of each client. Our clients entrust us with their funds and personal information, which in turn places a high
standard on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and
represents the expected basis of all our dealings.
Code of Ethics Description
This code does not attempt to identify all possible conflicts of interest, and literal compliance with each of
its specific provisions will not shield associated persons from liability for personal trading or other conduct
that violates a fiduciary duty to advisory clients. A summary of the Code of Ethics' Principles is outlined
below.
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Integrity - Associated persons shall offer and provide professional services with integrity.
•
Objectivity - Associated persons shall be objective in providing professional services to clients.
•
Competence - Associated persons shall provide services to clients competently and maintain the
necessary knowledge and skill to continue to do so in those areas in which they are engaged.
•
Fairness - Associated persons shall perform professional services in a manner that is fair and
reasonable to clients, principals, partners, and employers, and shall disclose conflict(s) of interest in
providing such services.
•
Confidentiality - Associated persons shall not disclose confidential client information without the
specific consent of the client unless in response to proper legal process, or as required by law.
•
Professionalism - Associated persons’ conduct in all matters shall reflect credit of the profession.
•
Diligence - Associated persons shall act diligently in providing professional services.
We periodically review and amend our Code of Ethics to ensure that it remains current, and we require all
firm access persons to attest to their understanding of and adherence to the Code of Ethics at least annually.
Our firm will provide of copy of its Code of Ethics to any client or prospective client upon request.
Investment Recommendations Involving a Material Financial Interest and
Conflicts of Interest
Neither our firm, its associates or any related person is authorized to recommend to a client, or effect a
transaction for a client, involving any security in which our firm or a related person has a material financial
interest, such as in the capacity as an underwriter, adviser to the issuer, etc.
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Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts
of Interest
Our firm and its “related persons” may buy or sell securities similar to, or different from, those we
recommend to clients for their accounts. Our policy is designed to assure that the personal securities
transactions, activities and interests of the employees of our firm will not interfere with (i) making decisions
in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing
employees to invest for their own accounts. Nonetheless, because the Code of Ethics in some circumstances
would permit employees to invest in the same securities as clients, there is a possibility that employees
might benefit from market activity by a client in a security held by an employee. In an effort to reduce or
eliminate certain conflicts of interest involving the firm or personal trading, our policy may require that we
restrict or prohibit associates’ transactions in specific reportable securities transactions. Any exceptions or
trading pre-clearance must be approved by the firm principal in advance of the transaction in an account,
and we maintain the required personal securities transaction records per regulation.
Trading Securities at/Around the Same Time as Client’s Securities
From time to time, our firm or its “related persons” may buy or sell securities for themselves at or around
the same time as clients. We will not trade non-mutual fund securities prior to the same security for clients
on the same day.
Investment Advice Relating to Retirement Accounts
When we provide investment advice to you regarding your retirement plan account or individual retirement
account, we are 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. The way
we make money creates some conflicts with your interests, so we operate under a special rule that requires
us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions,
we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice).
• Never put our financial interests ahead of yours when making recommendations (give loyal advice).
• Avoid misleading statements about conflicts of interest, fees, and investments.
• Follow policies and procedures designed to ensure that we give advice that is in your best interest.
• Charge no more than is reasonable for our services.
• Give you basic information about conflicts of interest.
In addition, and as required by this rule, we provide information regarding the services that we provide to
you, and any material conflicts of interest, in this brochure and in your client agreement.
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Factors Used to Select Custodians and/or Broker-Dealers
Item 12: Brokerage Practices
Boothe Investment Group Inc. does not have any affiliation with Broker-Dealers. Specific custodian
recommendations are made to client based on their need for such services. We recommend custodians
based on the reputation and services provided by the firm.
1. Research and Other Soft-Dollar Benefits
We currently do not receive soft dollar benefits.
2. Brokerage for Client Referrals
We receive no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third
party.
3. Clients Directing Which Broker/Dealer/Custodian to Use
We do recommend a specific custodian for clients to use. Clients may request their assets be held at a
custodian of their choice however, B.I.G. Investment Services ultimately reserves the right to make a final
decision regarding the use of any requested custodian. By utilizing a client requested custodian, B.I.G.
Investment Services may be unable to achieve the most favorable execution of client transactions and this
may cost clients’ money over using our preferred custodian.
Aggregating (Block) Trading for Multiple Client Accounts
Generally, we combine multiple orders for shares of the same securities purchased for advisory accounts we
manage (this practice is commonly referred to as “block trading”). We will then distribute a portion of the
shares to participating accounts in a fair and equitable manner. The distribution of the shares purchased is
typically proportionate to the size of the account, but it is not based on account performance or the amount
or structure of management fees. Subject to our discretion, regarding circumstances and market conditions,
when we combine orders, each participating account pays an average price per share for all transactions
and pays a proportionate share of all transaction costs. Accounts owned by our firm or persons associated
with our firm may participate in block trading with your accounts; however, they will not be given
preferential treatment.
Item 13: Review of Accounts
Client accounts with the Investment Management Service will be reviewed regularly on a quarterly basis by
David F. Boothe, President and Financial Advisor. The account is reviewed with regards to the client’s
investment policies and risk tolerance levels. Events that may trigger a special review would be unusual
performance, addition or deletions of client-imposed restrictions, excessive draw-down, volatility in
performance, or buy and sell decisions from the firm or per client's needs.
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Clients will receive trade confirmations from the broker(s) for each transaction in their accounts as well as
monthly or quarterly statements and annual tax reporting statements from their custodian showing all
activity in the accounts, such as receipt of dividends and interest.
B.I.G. Investment Services will provide written reports to investment management clients on an annual
basis. We urge clients to compare these reports against the account statements they receive from their
custodian.
Item 14: Client Referrals and Other
Compensation
We do not receive any economic benefit, directly or indirectly from any third party for advice rendered to
our clients. Nor do we directly or indirectly compensate any person who is not advisory personnel for client
referrals.
Item 15: Custody
B.I.G. Investment Services does not generally accept custody of client funds however is deemed to have
custody due to advisory fee deduction. Clients should receive at least quarterly statements from the broker
dealer, bank or other qualified custodian that holds and maintains client's investment assets. We urge you
to carefully review such statements and compare such official custodial records to the account statements
or reports that we may provide to you. Our statements or reports may vary from custodial statements based
on accounting procedures, reporting dates, or valuation methodologies of certain securities.
Item 16: Investment Discretion
For those client accounts where we provide investment management services, we maintain discretion over
client accounts with respect to securities to be bought and sold and the amount of securities to be bought
and sold. Investment discretion is explained to clients in detail when an advisory relationship has
commenced. At the start of the advisory relationship, the client will execute a Limited Power of Attorney,
which will grant our firm discretion over the account. Additionally, the discretionary relationship will be
outlined in the advisory contract and signed by the client. Clients may impose reasonable restrictions on
investing in certain securities, types of securities, or industry sectors.
Item 17: Voting Client Securities
We do not vote Client proxies. Therefore, Clients maintain exclusive responsibility for: (1) voting proxies,
and (2) acting on corporate actions pertaining to the Client’s investment assets. The Client shall instruct the
Client’s qualified custodian to forward to the Client copies of all proxies and shareholder communications
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relating to the Client’s investment assets. If the client would like our opinion on a particular proxy vote, they
may contact us at the number listed on the cover of this brochure.
In most cases, you will receive proxy materials directly from the account custodian. However, in the event
we were to receive any written or electronic proxy materials, we would forward them directly to you by
mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward
you any electronic solicitation to vote proxies.
Security Claims Class Action Litigation
BIG Investment Services has engaged a third-party service provider, Chicago Clearing Corporation (CCC), to
monitor and file securities claims class action litigation paperwork with claims administrators on behalf of
the Firm’s clients. When a claim is settled and payments are awarded to BIG Investment Services clients, it
may be necessary to share client information, such as name and account number, with CCC in connection
with this service.
BIG Investment Services does not receive any fees or remuneration in connection with this service nor does
it receive any fees from the third-party provider(s). CCC earns a flat fee that equates to a percentage of all
claims it collects on behalf of BIG Investment Services clients. This fee is collected and retained by CCC out
of the claims paid by the claim administrator. Clients may opt out of this service at any time. If a client opts
out, BIG Investment Services does not have an obligation to advise or take any action on behalf of a client
with regard to class action litigation involving investments held in or formerly held in a clients account.
Class Action Claims
In June 2022, we began providing class action litigation monitoring and securities claim filing services
through an independent third party, Chicago Clearing Corporation ("CCC"). You are included in this service
unless you choose to opt out. You may change your opt-out election at any time by notifying us in writing.
If you participate in this service, CCC will retain 15% of each claim recovery you receive. We have the right
to change the provider of this service. If we do, we will notify you and send you another opt-out election
form. Because we are providing this service through CCC, we no longer monitor class action suits or process
claim forms on your behalf (whether or not you participate in the service CCC provides). We are not
responsible or liable for: (a) any assistance we provide to CCC concerning monitoring or processing class
action claims or (b) any CCC act in monitoring or processing such claims.
Item 18: Financial Information
Registered investment advisers are required in this Item to provide you with certain financial information or
disclosures about our financial condition. We have no financial commitment that impairs our ability to meet
contractual and fiduciary commitments to clients, and we have not been the subject of a bankruptcy
proceeding.
We do not have custody of client funds or securities or require or solicit prepayment of more than $1,200 in
fees per client six months in advance.
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