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Cover Page – Item 1
Boyle Capital Management, L.L.C.
dba Boyle Capital
1230 Office Plaza Drive
West Des Moines, IA 50266
Telephone: (515) 327-1870
Fax: (515) 619-5719
Email: bboyle@boylecapital.com
Web: www.boylecapital.com
March 10, 2026
FORM ADV PART 2A
BROCHURE
This brochure provides information about the qualifications and business practices of Boyle Capital Management,
L.L.C., dba Boyle Capital. If you have any questions about the contents of this brochure, please contact us at (515)
327-1870. The information in this brochure has not been approved or verified by the United States Securities and
Exchange Commission or by any state securities authority.
Additional information about Boyle Capital is available on the SEC's website at www.adviserinfo.sec.gov.
Boyle Capital is a registered investment adviser. Registration with the United States Securities and Exchange
Commission or any state securities authority does not imply a certain level of skill or training.
Boyle Capital
Form ADV Part 2A
Page 2
Material Changes - Item 2
Form ADV Part 2 requires registered investment advisers to amend their brochures when information becomes
materially inaccurate. If there are any material changes to our disclosure brochure, we are required to notify you
and provide you with a description of the material changes.
On March 10, 2026, we submitted our required annual filing for the firm’s fiscal year ending December 31, 2025.
We have made the following material changes since our previous annual filing submitted to regulators on March
24, 2025.
•
Item 8 was updated with important information regarding political risks and risks associated with the
use of artificial intelligence.
We strongly encourage you to review the entire brochure. If you have questions, or if you would like a current
copy of our brochure at any time free of charge, please contact us at 1230 Office Plaza Drive, West Des Moines,
IA 50266 or (515) 327-1870.
Boyle Capital
Form ADV Part 2A
Page 3
Table of Contents - Item 3
Cover Page – Item 1 ................................................................................................................................................. 1
Material Changes - Item 2 ........................................................................................................................................ 2
Table of Contents - Item 3 ....................................................................................................................................... 3
Advisory Business - Item 4 ....................................................................................................................................... 4
Fees and Compensation - Item 5 ............................................................................................................................. 7
Performance-Based Fees and Side-By-Side Management - Item 6 ....................................................................... 11
Types of Clients - Item 7......................................................................................................................................... 11
Methods of Analysis, Investment Strategies and Risk of Loss - Item 8 .................................................................. 11
Disciplinary Information - Item 9 ........................................................................................................................... 18
Other Financial Industry Activities or Affiliations - Item 10 ................................................................................... 18
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11 .......................... 19
Brokerage Practices - Item 12 ................................................................................................................................ 20
Review of Accounts - Item 13 ................................................................................................................................ 24
Client Referrals and Other Compensation - Item 14 .............................................................................................. 25
Custody - Item 15 ................................................................................................................................................... 25
Investment Discretion - Item 16 ............................................................................................................................ 26
Voting Client Securities - Item 17 ........................................................................................................................... 26
Financial Information - Item 18 ............................................................................................................................. 26
Miscellaneous ........................................................................................................................................................ 27
Boyle Capital
Form ADV Part 2A
Page 4
Advisory Business - Item 4
Boyle Capital Management, L.L.C., doing business as Boyle Capital, is a registered investment adviser based in
West Des Moines, Iowa. It is organized as a limited liability company under the laws of the State of Iowa. The
company is owned by BFB Holdings, LLC, an Arizona holding company. Boyle Capital has been providing
investment advisory services since 2004. Brian F. Boyle is the President and Chief Compliance Officer of Boyle
Capital and is the sole owner and Managing Member of BFB Holdings, LLC.
As used in this brochure, the words “we,” “our,” and “us” refer to Boyle Capital, and the words “you,” “your,”
and “client” refer to you as either a client or prospective client of our firm. The following paragraphs describe
our services and fees. Please refer to the description of each investment advisory service listed below for
information on how we tailor our advisory services to your individual needs.
Boyle Capital Managed Account Program (Wrap Fee Program)
We are a portfolio manager to, and sponsor of, the Boyle Capital Managed Account Program a wrap fee program
(“Program”). If you participate in our wrap fee program, you will pay our firm a single fee, which includes our
money management fees, certain transaction costs, and custodial and administrative costs. We receive a portion
of the wrap fee for our services. The overall cost you will incur if you participate in our wrap fee program may be
higher or lower than you might incur by separately purchasing the types of securities available in the program.
Transactions for your account must be executed through Charles Schwab & Co., Inc. (“Schwab”), an unaffiliated
securities broker-dealer and member of the Financial Industry Regulatory Authority (FINRA) and the Securities
Investor Protection Corporation (SIPC). Depending on the Program's annual percentage fee charged by our firm
(please see Appendix 1 to this Brochure), the amount of portfolio activity in your account, and the value of
custodial and other services provided, the wrap fee may or may not exceed the aggregate cost of such services
if they were to be provided separately and/or if we were to negotiate transaction fees and seek best price and
execution of transactions for your individual account. To compare the cost of the wrap fee program with non-
wrap fee portfolio management services, you should consider the frequency of trading activity associated with
our investment strategies and the brokerage commissions charged by Schwab or other broker-dealers, and the
advisory fees charged by us or investment advisors. In determining whether to establish a Boyle Capital Managed
Account Program account, a client should be aware that the overall cost to the client of the Program may be
higher or lower than the client might incur by purchasing separately the types of securities available in the
Program. For more information concerning the Wrap Fee Program, please see Appendix 1 to this Brochure.
Non-Wrap Portfolio Management Services
In limited circumstances and at our discretion, we may provide direct asset management services on a non-wrap
basis. There is no difference in the way we manage non-wrap accounts and wrap accounts. If you participate in
our discretionary portfolio management services, we require you to grant us discretionary authority to manage
your account. Subject to a grant of discretionary authorization, we have the authority and responsibility to
formulate investment strategies on your behalf. Discretionary authorization will allow us to determine the
specific securities and the amount of securities to be purchased or sold for your account without obtaining your
approval prior to each transaction. Discretionary authority is typically granted by the investment advisory
agreement you sign with our firm, a power of attorney, or trading authorization forms.
In limited circumstances and at our discretion, we may also offer non-discretionary portfolio management
services. If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to
executing any transactions on behalf of your account. You have an unrestricted right to decline to implement any
advice provided by our firm on a non-discretionary basis.
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Form ADV Part 2A
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In either case, our investment advice is tailored to meet our clients’ needs and investment objectives. If you
decide to hire our firm to manage your portfolio, we will meet with you to gather your financial information,
determine your goals, and help you decide how much risk you should take in your investments. The information
we gather will help us implement a strategy that will be specific to your goals, whether we are actively investing
for you or simply providing you with advice.
Once the portfolio is constructed, we periodically rebalance the portfolio as changes in market conditions and
your circumstances may require. A minimum account size of $30,000 is required to participate in the Program.
The minimum account size may be waived or lowered at our discretion.
You may specify investment objectives, guidelines, and/or impose certain conditions or investment parameters
for your account(s). For example, you may specify that the investment in any particular stock or industry should
not exceed specified percentages of the value of the portfolio and/or restrictions or prohibitions of transactions
in the securities of a specific industry or security. Simply provide us with your restrictions or guidelines in writing.
In determining whether to establish a wrap or non-wrap account, a client should be aware that the overall cost
to the client may be higher or lower in the wrap program than in the non-wrap program. Accounts participating
in Non-Wrap Portfolio Management Services will incur transaction charges and/or brokerage fees when
purchasing or selling securities, as well as applicable brokerage and custodial fees. The broker-dealer or custodian
through which your account transactions are executed typically imposes these charges and fees.
Boyle Capital Manager of Managers Program
As part of our investment advisory services, we offer Manager selection services (referred to as the “Manager
of Managers” Program whereby we may recommend that you use the services of or specific programs/model
portfolios offered through an unaffiliated third-party adviser or sub-adviser (collectively “Managers”) to manage
a portion of or your entire investment portfolio. Factors that we take into consideration when making our
recommendation(s) include, but are not limited to, the Manager’s performance, methods of analysis, fees, your
financial needs, investment goals, risk tolerance, and investment objectives. After gathering information about
your financial situation and objectives, we will recommend that you engage one or more specific Manager(s) or
investment program(s).
If you decide to act on our recommendation(s), the selected Manager(s) will actively manage your portfolio and
will assume discretionary investment authority over your account. We will recommend allocations of assets to
Managers, monitor Managers’ performance on an ongoing basis, and make recommendations to you to
rebalance and reallocate the assets in accordance with your financial situation and investment objectives.
However, we will not have investment authority to direct the investment, reinvestment, allocation, or
reallocation of account assets, to execute transactions on behalf of the account, or to terminate Managers
without obtaining your specific consent prior to each such investment, reinvestment, or transaction, and
termination. In some cases, in accordance with the agreement you sign with us, we will be granted discretionary
authority to reallocate your assets to other strategies or models offered through your selected Manager(s)where
we deem such action to be appropriate. Neither our firm nor persons associated with our firm serve as an officer,
director, or employee of any recommended Manager.
Generally, you will be required to sign an agreement directly with the selected Manager(s) in addition to the
agreement you sign with us. We will provide you with a copy of each recommended Manager’s disclosure
brochures prior to the engagement of any such Manager. You should carefully review each Manager’s disclosure
brochure and applicable advisory agreement for detailed information about the Manager’s services and fees and
for specific information on how you may terminate your advisory relationship with the Manager, and how you
may receive a refund of any prepaid, unearned fees, if applicable. You can contact the Manager directly for
questions regarding your advisory agreement with them. You may terminate your agreement with us within the
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Form ADV Part 2A
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first five days of execution without penalty. Thereafter, either party may terminate the agreement upon 30 days'
written notice to the other party. Any prepaid, unearned fees will be promptly refunded.
Financial Planning Services
We offer financial planning services, which typically involve providing a variety of advisory services to clients
regarding the management of their financial resources based on an analysis of their individual needs. These
services can range from broad-based financial planning to consultative or single-subject planning. If you retain
our firm for financial planning services, we will meet with you to gather information about your financial
circumstances and objectives. We may also use financial planning software to determine your current financial
position and to define and quantify your long-term goals and objectives. Once we specify those long-term
objectives (both financial and non-financial), we will develop shorter-term, targeted objectives. Once we review
and analyze the information you provide to our firm and the data derived from our financial planning software,
we will deliver a written plan to you, designed to help you achieve your stated financial goals and objectives.
Financial plans are based on your financial situation at the time we present the plan to you, and on the financial
information you provide to us. You must promptly notify our firm if your financial situation, goals, objectives, or
needs change.
You are under no obligation to act on our financial planning recommendations. Should you choose to act on any
of our recommendations, you are not obligated to implement the financial plan through any of our other
investment advisory services. Moreover, you may act on our recommendations by placing securities transactions
with any brokerage firm.
At our discretion, we may offset our financial planning fees to the extent you implement the financial plan
through our Portfolio Management Service.
Types of Investments
We primarily offer advice on equity securities (including exchange listed securities, exchange traded funds (ETFs),
over-the-counter securities, and foreign issues, such as American Depository Receipts (ADRs), warrants,
corporate debt and municipal securities (bonds), investment company securities (including mutual funds),
exchange traded funds, US Government securities, and options contracts on securities). Additionally, we may
advise you on any type of investment that we deem appropriate based on your stated goals and objectives. We
may also provide advice on any type of investment held in your portfolio at the inception of our advisory
relationship.
You may request that we refrain from investing in particular securities or certain types of securities. You must
provide these restrictions to our firm in writing.
Our investment or portfolio management services are offered solely through the Boyle Capital Managed Account
Program. We do not offer portfolio management services outside of the program or in a non-wrap
capacity. Therefore, there are no differences in the portfolio management of client accounts.
Assets Under Management
As of December 31, 2025, we provided continuous management services for $249,618,153 in client assets on a
discretionary basis and $92,336,575 in client assets on a non-discretionary basis.
Boyle Capital
Form ADV Part 2A
Page 7
Fees and Compensation - Item 5
Boyle Capital Managed Account Program Fees
Please see Item 4 of our Form ADV Part 2A, Appendix 1: Wrap Fee Program Brochure for information regarding
our wrap program fees.
Non-Wrap Portfolio Management Fees
Our annual non-wrap portfolio management fees are based on a percentage of the assets under management
and are negotiable. The agreed-upon fee will be set forth in the management agreement.
Account Value
$0 - $1,999,999
$2,000,000 - $4,999,999
$5,000,000 - $24,999,999
Over $25,000,000
Quarterly Fee
0.375%
0.2250%
0.0875%
0.0625%
Annualized Fee
1.50%
0.90%
0.35%
0.25%
Our annual Program fee is billed and payable quarterly in advance based on the value of your account on the last
day of the previous quarter. If the advisory agreement is executed at any time other than the first day of a
calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in
proportion to the number of days in the quarter for which you are a client. Our advisory fee is negotiable,
depending on individual client circumstances.
At our discretion, we may combine the account values of family members living in the same household to
determine the applicable advisory fee. For example, we may combine account values for you and your minor
children, joint accounts with your spouse, and other types of related accounts. Combining account values may
increase the asset total, which may result in your paying a reduced advisory fee based on the available
breakpoints in our fee schedule, stated above.
The firm treats cash and cash equivalents as an asset class. Accordingly, unless otherwise agreed in writing, all
cash and cash equivalent positions (e.g., money market funds, etc.) are included as part of assets under
management for purposes of calculating the firm’s advisory fee. At any specific point in time, depending upon
perceived or anticipated market conditions/events (there is no guarantee that such anticipated market
conditions/events will occur), the firm may maintain cash and/or cash equivalent positions for defensive,
liquidity, or other purposes. While assets are maintained in cash or cash equivalents, such amounts could miss
market advances and, depending upon current yields, at any point in time, the firm’s advisory fee could exceed
the interest paid by the client’s cash or cash equivalent positions.
Unless otherwise agreed in writing, the gross amount of assets in the client’s account, including margin balances,
is included as part of assets under management for purposes of calculating the firm’s advisory fee. Clients should
note that this practice will increase total assets under management, used to calculate advisory fees that will, in
turn, increase the amount of fees collected by our firm. This practice creates a conflict of interest in that our firm
has an incentive to use margin in order to increase the amount of billable assets. At all times, the firm and its
Associated Persons strive to uphold their fiduciary duty of fair dealing with clients. Clients are free to restrict the
use of margin by our firm. However, clients should note that any restriction on the use of margin might negatively
impact an account’s performance in a rising market.
The firm has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment
advisory services, the firm will review client portfolios on an ongoing basis to determine if any changes are
necessary based upon various factors, including but not limited to investment performance, fund manager
tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s
Boyle Capital
Form ADV Part 2A
Page 8
investment objectives. Based upon these and other factors, there may be extended periods of time when the
firm determines that changes to a client’s portfolio are neither necessary nor prudent. Notwithstanding, unless
otherwise agreed in writing, the firm’s annual investment advisory fee will continue to apply during these
periods, and there can be no assurance that investment decisions made by the firm will be profitable or equal
any specific performance level(s).
We will deduct our fee directly from your account through the qualified custodian holding your funds and
securities. We will deduct our advisory fee only when you have given our firm written authorization in accordance
with the investment advisory agreement you sign with us that permits the fees to be paid directly from your
account. Further, the qualified custodian will deliver an account statement to you at least quarterly. These
account statements will show all disbursements from your account. You should review all statements for
accuracy. We will also receive a duplicate copy of your account statements. Under certain circumstances, you
may request to be billed directly for our fees instead of having them debited from your account.
Either you or the firm may terminate the advisory agreement within five days from the date of acceptance
without penalty to you. After the five-day period, either you or the firm may terminate the advisory agreement
upon 30-days’ written notice to the other party. You will incur a pro rata charge for services rendered prior to
the termination of the advisory agreement, which means you will incur advisory fees only in proportion to the
number of days in the quarter for which you are a client. If you have prepaid advisory fees that we have not yet
earned, you will receive a prorated refund of those fees.
Manager of Manager Program Fees
Our annual fee ranges between 0.25% and 1.50% annually and is based on the account size and/or the investment
strategy associated with the account. At our discretion, we may negotiate fees based on individual client
circumstances. The fees you pay to selected Managers are separate and in addition to the fees you pay to us for
our advisory services and are established and payable in accordance with the selected Manager’s Form ADV
Brochure and advisory agreement. The total annual combined fee payable to us and the selected Manager will
not exceed 2.25% of the assets under management. The selected Manager(s)may offer services on a wrap-fee or
non-wrap fee basis. The selected Manager’s fees may or may not be negotiable.
Since our compensation may differ depending upon our individual agreement with each selected Manager, we
have an incentive to recommend one Manager over another with whom we have less favorable compensation
arrangements or with others with whom we have no compensation arrangements. At all times, Boyle Capital and
its Associated Persons uphold their fiduciary duty of fair dealing with Clients.
Financial Planning Fees
We charge an hourly fee of $100-$300 per hour for financial planning services, which is negotiable depending on
the scope and complexity of the plan, your situation, and your financial objectives. An estimate of the total
time/cost will be determined at the start of the advisory relationship. In limited circumstances, the cost/time
could potentially exceed the initial estimate. In such cases, we will notify you and request that you approve the
additional fee.
We also offer advice on single-subject financial planning/general consulting services at the same hourly rate.
Fees are due upon completion of services rendered. You may terminate the financial planning agreement by
providing written notice to our firm. Since fees are payable in arrears, you will be responsible for a prorated fee
based on services performed.
At our discretion, we may offset our financial planning fees to the extent you implement the financial plan
through our Portfolio Management Service.
Boyle Capital
Form ADV Part 2A
Page 9
Additional Fees and Expenses
As part of our investment advisory services to you, we may invest, or recommend that you invest, in mutual funds
and exchange traded funds. The fees that you pay to our firm for investment advisory services are separate and
distinct from the fees and expenses charged by mutual funds or exchange traded funds (described in each fund’s
prospectus) to their shareholders. These fees will generally include a management fee and other fund expenses.
Accounts participating in Non-Wrap Portfolio Management Services or the Manager of Managers Program will
incur transaction charges and/or brokerage fees when purchasing or selling securities, as well as applicable
brokerage and custodial fees. The broker-dealer or custodian through which your account transactions are
executed typically imposes these charges and fees.
The Boyle Capital Managed Account Program Wrap Fee includes the costs of brokerage commissions for
transactions executed through the Qualified Custodian (or a broker-dealer designated by the Qualified
Custodian), and charges relating to the settlement, clearance, or custody of securities in the Account.
The Boyle Capital Managed Account Program Wrap Fee does NOT include costs associated with additional
services requested by you including, but not limited to - wire or electronic fund transfer fees, overnight delivery
fees, duplicate statement fees, account transfer fees, reorganization fees, administrative fees, dividend
reinvestment fees, extension fees, foreign dividend/custody/settlement fees, returned check fees, share class
exchange fees, special product fees, stop payment fees, termination fees, or any contingent deferred sales
charges that may be incurred upon the sale of a security transferred into the Program account at your request.
Client accounts may be traded on margin. Each client must sign a separate margin agreement before margin is
extended to that client's account. Fees for advice and execution on these securities are based on the total asset
value of the account, which includes the value of the securities purchased on margin. While a negative amount
may show on a client’s statement for the margined security as the result of a lower net market value, the amount
of the fee is based on the absolute market value. This could create a conflict of interest where we may have an
incentive to encourage the use of margin to create a higher market value and therefore receive a higher fee. The
use of margin may also result in interest charges in addition to all other fees and expenses associated with the
security involved.
IRA Rollover Considerations
As part of our investment advisory services to you, we may recommend that you withdraw the assets from your
employer's retirement plan and roll the assets over to an individual retirement account ("IRA") that we will
manage on your behalf. A plan participant leaving employment has several options. Each choice offers
advantages and disadvantages, depending on desired investment options and services, fees and expenses,
withdrawal options, required minimum distributions, tax treatment, and the investor's unique financial needs
and retirement plans. The complexity of these choices may lead an investor to seek assistance from us.
An Associated Person who recommends an investor roll over plan assets into an Individual Retirement Account
(“IRA”) may earn an asset-based fee as a result, but no compensation if assets are retained in the plan. Thus, we
have an economic incentive to encourage an investor to roll plan assets into an IRA. In most cases, fees and
expenses will increase for the investor as a result because the fees described herein will apply to assets rolled
over to an IRA, and the outlined ongoing services will be extended to these assets.
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
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Form ADV Part 2A
Page 10
applicable, which are laws governing retirement accounts. We have to act in your best interests and not put our
interests ahead of yours. At the same time, the way we make money creates some conflicts with your interests.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee
as set forth in the agreement you executed with our firm. This practice presents a conflict of interest because
persons providing investment advice on our behalf have an incentive to recommend a rollover to you to generate
fee-based compensation rather than solely based on your needs. You are under no obligation, contractually or
otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to
have the assets in an IRA managed by our firm.
Many employers permit former employees to keep their retirement assets in their company plans. Also, current
employees can sometimes move assets out of their company plan before they retire or change jobs. In
determining whether to complete the rollover to an IRA, and to the extent the following options are available,
you should consider the costs and benefits.
An employee will typically have four options:
1. Leaving the funds in your employer's (former employer's) plan.
2. Moving the funds to a new employer’s retirement plan.
3. Cashing out and taking a taxable distribution from the plan.
4. Rolling the funds into an IRA rollover account.
Each of these options has advantages and disadvantages, and before making a change, we encourage you to
speak with your CPA and/or tax attorney.
If you are considering rolling over your retirement funds to an IRA for us to manage, here are a few points to
consider before you do so:
1. Determine whether the investment options in your employer's retirement plan address your needs or
whether you might want to consider other types of investments.
a. Employer retirement plans generally have a more limited investment menu than IRAs.
b. Employer retirement plans may have unique investment options not available to the public,
such as employer securities or previously closed funds.
Your current plan may have lower fees than our fees.
2.
a. If you are interested in investing only in mutual funds, you should understand the cost structure
of the share classes available in your employer's retirement plan and how the costs of those
share classes compare with those available in an IRA.
b. You should understand the various products and services you might take advantage of at an IRA
provider and the potential costs of those products and services.
3. Our strategy may have a higher risk than the option(s) provided to you in your plan.
4.
5.
Your current plan may also offer financial advice.
If you keep your assets titled in a 401k or retirement account, you could potentially delay your required
minimum distribution.
Your 401k may offer more liability protection than a rollover IRA; each state may vary.
6.
a. Generally, federal law protects assets in qualified plans from creditors. IRA assets may be
protected from creditors in bankruptcy. However, there can be some exceptions to the general
rules, so you should consult with an attorney if you are concerned about protecting your
retirement plan assets from creditors.
7.
8.
You may be able to take out a loan on your 401k, but not from an IRA.
IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and
may also be subject to an early distribution penalty unless they qualify for an exception.
Your plan may allow you to hire us as the manager and keep the assets titled in the plan name.
9.
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Form ADV Part 2A
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It is important that you understand the differences between these types of accounts and decide whether a
rollover is best for you. Before proceeding, if you have questions, contact your investment adviser representative
or call our main number as listed on the cover page of this brochure.
Performance-Based Fees and Side-By-Side Management - Item 6
Please see Item 6 of our Form ADV Part 2A, Appendix 1: Wrap Fee Program Brochure for information regarding
performance-based fees and side-by-side management. Recommended Managers typically do not charge
performance-based fees.
Types of Clients - Item 7
We offer investment advisory services to individuals, pension and profit sharing plans, trusts, estates, charitable
organizations, corporations, and other business entities.
In general, we require a minimum of $30,000 to open and maintain an advisory account. However, the stated
minimum may be waived at our discretion. For example, we may waive the minimum if you appear to have
significant potential for increasing your assets under our management. We may also combine account values for
you and your minor children, joint accounts with your spouse, and other types of related accounts to meet the
stated minimum.
Selected Managers may require different minimums for participation in certain strategies or programs; therefore,
we will only refer you to such programs for which you qualify.
Methods of Analysis, Investment Strategies and Risk of Loss - Item 8
We may use one or more of the following methods of analysis or investment strategies when providing
investment advice to you:
•
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.
•
Long-Term Purchases – securities purchased with the expectation that the value of those securities will
grow over a relatively long period of time, generally greater than one year.
•
Short-Term Purchases – securities purchased with the expectation that they will be sold within a
relatively short period of time, generally less than one year, to take advantage of the securities’ short-
term price fluctuations.
Boyle Capital
Form ADV Part 2A
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•
Short Sales – securities transactions in which an investor sells securities he or she borrowed in
anticipation of a price decline. The investor is then required to return an equal number of shares at
some point in the future. A short seller will profit if the stock goes down in price, but if the price of the
shares increases, the potential losses are unlimited.
• Margin Transactions – a securities transaction in which an investor borrows money to purchase a
security, in which case the security serves as collateral on the loan. If the value of the shares drops
sufficiently, the investor will be required to either deposit more cash into the account or sell a portion
of the stock in order to maintain the margin requirements of the account. This is known as a "margin
call." An investor’s overall risk includes the amount of money invested plus the amount that was loaned
to them.
• Options Writing – a securities transaction that involves selling an option. An option is a right, but not an
obligation, to buy or sell a particular security at a specified price before the expiration date of the option.
When an investor sells an option, he or she must deliver to the buyer a specified number of shares if the
buyer exercises the option. The seller pays the buyer a premium (the market price of the option at a
particular time) in exchange for writing the option. Options are complex investments and can be very
risky, especially if the investor does not own the underlying stock. In certain situations, an investor’s risk
can be unlimited.
We may use short-term trading (in general, selling securities within 30 days of purchasing the same securities) as
an investment strategy when managing your account(s) when we determine that it is suitable, given your stated
investment objectives and risk tolerance. This may include buying and selling securities frequently in an effort to
capture significant market gains and avoid significant losses during a volatile market. However, frequent trading
can negatively affect investment performance, particularly through increased brokerage and other transactional
costs and taxes.
Our investment strategies and advice may vary depending on each client’s specific financial situation. As such,
we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon,
financial horizon, financial information, liquidity needs, and other various suitability factors. Your restrictions and
guidelines may affect the composition of your portfolio.
Tax Considerations
Our strategies and investments may have unique and significant tax implications. However, unless we specifically
agree otherwise, and in writing, tax efficiency is not our primary consideration in the management of your assets.
Regardless of your account size or any other factors, we strongly recommend that you continuously consult with
a tax professional before and throughout the investment of your assets.
Moreover, as a result of revised IRS regulations, custodians and broker-dealers will begin reporting the cost basis
of equities acquired in client accounts on or after January 1, 2011. Your custodian will default to the FIFO (First-
In First-Out) accounting method for calculating the cost basis of your investments. You are responsible for
contacting your tax advisor to determine if this accounting method is the right choice for you. If your tax advisor
believes another accounting method is more advantageous, please provide written notice to our firm
immediately, and we will alert the account custodian of your individually selected accounting method. Please
note that decisions about cost-basis accounting methods will need to be made before trades settle, as the cost-
basis method cannot be changed after settlement.
Risk of Loss
Investing in securities involves the risk of loss that you should be prepared to bear. We do not represent or
guarantee that our services or methods of analysis can or will predict future results, successfully identify market
tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any
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guarantees or promises that your financial goals and objectives will be met. Past performance is in no way an
indication of future performance.
Concentrated Position Risk: Certain Associated Persons may recommend that clients concentrate account assets
in an industry or economic sector. In addition to the potential concentration of accounts in one or more sectors,
certain accounts may, or may be advised to, hold concentrated positions in specific securities. Therefore, at
times, an account may, or may be advised to, hold a relatively small number of securities positions, each
representing a relatively large portion of assets in the account. As a result, the account will be subject to greater
volatility than a more sector-diversified portfolio. Investments in issuers within an industry or economic sector
that experiences adverse economic, business, political conditions, or other concerns will impact the value of such
a portfolio more than if the portfolio’s investments were not so concentrated. A change in the value of a single
investment within the portfolio will affect the overall value of the portfolio and will cause greater losses than it
would in a portfolio that holds more diversified investments.
Cybersecurity Risks: Our firm and our service providers are subject to risks associated with a breach in
cybersecurity. Cybersecurity is a generic term used to describe the technology, processes, and practices designed
to protect networks, systems, computers, programs, and data from cyber-attacks and hacking by other computer
users, and to avoid the resulting damage and disruption of hardware and software systems, loss or corruption of
data, and/or misappropriation of confidential information. In general, cyber-attacks are deliberate; however,
unintentional events may have similar effects. Cyber-attacks may cause losses to clients by interfering with the
processing of transactions, affecting the ability to calculate net asset value, or impeding or sabotaging trading.
Clients may also incur substantial costs as a result of a cybersecurity breach, including those associated with
forensic analysis of the origin and scope of the breach, increased and upgraded cybersecurity, identity theft,
unauthorized use of proprietary information, litigation, and the dissemination of confidential and proprietary
information. Any such breach could expose our firm to civil liability as well as regulatory inquiry and/or action. In
addition, clients could be exposed to additional losses as a result of the unauthorized use of their personal
information. While our firm has established a business continuity plan and systems designed to prevent cyber-
attacks, there are inherent limitations in such plans and systems, including the possibility that certain risks have
not been identified. Similar types of cybersecurity risks are also present for issuers of securities, investment
companies, and other investment advisers in which we invest, which could result in material adverse
consequences for such entities and may cause a client's investment in such entities to lose value.
Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase morbidity and mortality over a
wide geographic area, crossing international boundaries, and causing significant economic, social, and political
disruption. It is difficult to predict the long-term impact of such events because they are dependent on a variety
of factors, including the global response of regulators and governments to address and mitigate the worldwide
effects of such events. Workforce reductions, travel restrictions, governmental responses and policies, and
macroeconomic factors could negatively impact investment returns.
Cryptocurrency Risk: Cryptocurrency (e.g., bitcoin and ether), often referred to as “virtual currency,” “digital
currency,” or “digital assets,” is designed to act as a medium of exchange. Cryptocurrency is an emerging asset
class. There are thousands of cryptocurrencies, the most well-known of which is Bitcoin. Certain of the firm’s
clients may have exposure to bitcoin or another cryptocurrency, directly or indirectly, through an investment
such as an ETF or other investment vehicles. Cryptocurrency operates without a central authority or banks and
is not backed by any government. Cryptocurrencies may experience very high volatility, and related investment
vehicles may be affected by such volatility. As a result of holding cryptocurrency, certain of the firm’s clients may
also trade at a significant premium or discount to NAV. Cryptocurrency is also not legal tender. Federal, state, or
foreign governments may restrict the use and exchange of cryptocurrency, and regulation in the U.S. is still
developing. The market price of many cryptocurrencies, including bitcoin, has been subject to extreme
fluctuations. If cryptocurrency markets continue to be subject to sharp fluctuations, investors may experience
losses if the value of the client’s investments declines. Similar to fiat currencies (i.e., a currency that is backed by
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a central bank or a national, supra-national, or quasi-national organization), cryptocurrencies are susceptible to
theft, loss, and destruction. Cryptocurrency exchanges and other trading venues on which cryptocurrencies trade
are relatively new and, in most cases, largely unregulated and may therefore be more exposed to fraud and
failure than established, regulated exchanges for securities, derivatives, and other currencies. The SEC has issued
a public report stating that U.S. federal securities laws require treating some digital assets as securities.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical glitches,
hackers, or malware. Due to relatively recent launches, most cryptocurrencies have a limited trading history,
making it difficult for investors to evaluate investments. Generally, cryptocurrency transactions are irreversible,
such that an improper transfer can only be undone by the receiver of the cryptocurrency agreeing to return the
cryptocurrency to the original sender. Digital assets are highly dependent on their developers, and there is no
guarantee that development will continue or that developers will not abandon a project with little or no notice.
Third parties may assert intellectual property claims relating to the holding and transfer of digital assets, including
cryptocurrencies, and their source code. Any threatened action that reduces confidence in a network’s long-term
ability to hold and transfer cryptocurrency may affect investments in cryptocurrencies.
Many significant aspects of the U.S. federal income tax treatment of investments in cryptocurrency are uncertain,
and a cryptocurrency investment may produce income that is not treated as qualifying income for purposes of
the income test applicable to regulated investment companies. Certain cryptocurrency investments may be
treated as a grantor trust for U.S. federal income tax purposes, and an investment by the firm’s clients in such a
vehicle will generally be treated as a direct investment in cryptocurrency for tax purposes and “flow-through” to
the underlying investors.
Environmental, Social, and Governance Investment Criteria Risk: If a portfolio is subject to certain environmental,
social, and governance (ESG) investment criteria, it may avoid purchasing certain securities for ESG reasons when
it is otherwise economically advantageous to purchase those securities or may sell certain securities for ESG
reasons when it is otherwise economically advantageous to hold those securities. In general, the application of
the portfolio’s ESG investment criteria may affect the portfolio’s exposure to certain issuers, industries, sectors,
and geographic areas, which may affect the financial performance of the portfolio, positively or negatively,
depending on whether these issuers, industries, sectors, or geographic areas are in or out of favor. An adviser
can vary materially from other advisers with respect to its methodology for constructing ESG portfolios or
screens, including with respect to the factors and data that it collects and evaluates as part of its process. As a
result, an adviser’s ESG portfolio or screen may materially differ from or contradict the conclusions reached by
other ESG advisers concerning the same issuers. Further, ESG criteria are dependent on data and are subject to
the risk that such data reported by issuers or received from third-party sources may be subjective, or it may be
objective in principle but not verified or reliable.
Political Risk: Each administration presents its own set of policy risks that could impact investors. One of the
policy tools that an administration can implement is the imposition of tariffs, or the threats thereof. The scope,
implementation, and duration of tariffs can create uncertainty domestically and globally. Industries that rely on
imported raw material or that have heavily integrated cross-border manufacturing practices may be most
impacted by the imposition of tariffs. However, it is challenging to predict the impact of actual and/or threatened
tariffs and impossible to predict future policy decisions. When tariffs are imposed, there is also a higher
probability that retaliatory tariffs could be imposed, which could further impact industries and products. Tariffs
in general can also permanently alter global supply chains and have far-reaching indirect impacts. Tariffs can hurt
economic growth and add to inflation, which can lead to rising interest rates.
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Artificial Intelligence ("AI") Risk: We may rely on programs and systems that utilize AI, machine learning,
probabilistic modeling, and other data science technologies ("AI Tools") when delivering our services. AI Tools
are also used to record and transcribe client meetings. Clients should note that AI Tools are highly complex, and
are known to have been flawed, hallucinate, reflect biases included in the data on which such tools are trained,
be of poor quality, or be otherwise harmful. AI Tools present Cybersecurity Risk. The U.S. and global legal and
regulatory environment relating to the use of AI Tools is uncertain and rapidly evolving, and could require
changes in the firm’s implementation of AI Tools and increase compliance costs and the risk of non-compliance.
Further, the firm may rely on AI Tools developed by third parties, and the firm has limited control over the
accuracy and completeness of such AI Tools. Clients who do not want us to record their meetings have the option
to opt out at the time of the meeting.
Recommendation of Particular Types of Securities
We offer advice on many types of securities; however, we primarily recommend equity securities and mutual
funds. Since each client has different needs and different tolerance for risk, we may recommend other types of
investments as appropriate for you. Each type of security has its own unique set of risks associated with it, and
it would not be possible to list here all of the specific risks of every type of investment. Even within the same type
of investment, risks can vary widely. However, in very general terms, the higher the anticipated return of an
investment, the higher the risk of loss associated with it.
There are numerous ways of measuring the risk of equity securities (also known simply as “equities” or “stock”).
In very broad terms, the value of a stock depends on the financial health of the company issuing it. However,
stock prices can be affected by many other factors, including, but not limited to, the class of stock (for example,
preferred or common); the health of the market sector of the issuing company; and the overall health of the
economy. In general, larger, better-established companies (“large cap”) tend to be safer than smaller start-up
companies (“small cap”), but the mere size of an issuer is not, by itself, an indicator of the safety of the
investment.
Mutual funds are professionally managed collective investment systems that pool money from many investors
and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any
combination thereof. The fund will have a manager who trades the fund's investments in accordance with the
fund's investment objective. While mutual funds generally provide diversification, risks can be significantly
increased if the fund is concentrated in a particular sector of the market, primarily invests in small cap or
speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular
type of security (i.e., equities) rather than balancing the fund with different types of securities. The returns on
mutual funds can be reduced by the costs of managing the funds. In addition, while some mutual funds are “no
load” and charge no fee to buy into, or sell out of, other types of mutual funds do charge such fees, which can
also reduce returns.
Inverse mutual funds and ETFs, which are sometimes referred to as "short" funds, seek to provide the opposite
of the single-day performance of the index or benchmark they track. Inverse funds are often marketed as a way
to profit from, or hedge exposure to, downward-moving markets. Some inverse funds also use leverage, such
that they seek to achieve a return that is a multiple of the opposite performance of the underlying index or
benchmark (i.e., -200%, -300%). In addition to leverage, these funds may also use derivative instruments to
accomplish their objectives. As such, inverse funds are highly volatile and provide the potential for significant
losses.
Leveraged mutual funds and ETFs generally seek to deliver multiples of the daily performance of the index or
benchmark that they track. Inverse mutual funds and ETFs generally seek to deliver the opposite of the daily
performance of the index or benchmark that they track. Inverse funds often are marketed as a way for investors
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to profit from, or at least hedge their exposure to, downward-moving markets. Some Inverse funds are both
inverse and leveraged, meaning that they seek a return that is a multiple of the inverse performance of the
underlying index. To accomplish their objectives, leveraged and inverse funds use a range of investment
strategies, including swaps, futures contracts, and other derivative instruments. Leveraged, inverse, and
leveraged inverse funds are more volatile and riskier than traditional funds due to their exposure to leverage and
derivatives, particularly total return swaps and futures. At times, we will recommend leveraged and/or inverse
funds, which may amplify gains and losses.
Most leveraged funds are typically designed to achieve their desired exposure on a daily (in a few cases, monthly)
basis, and reset their leverage daily. A "single day" is measured from the time the leveraged fund calculates its
net asset value ("NAV") to the time of the leveraged fund's next NAV calculation. The return of the leveraged
fund for periods longer than a single day will be the result of each day's returns compounded over the period.
Due to the effect of this mathematical compounding, their performance over longer periods of time can differ
significantly from the performance (or inverse performance) of their underlying index or benchmark during the
same period of time. For periods longer than a single day, the leveraged fund will lose money when the level of
the Index is flat, and the leveraged fund may lose money even if the level of the Index rises. Longer holding
periods, higher index volatility, and greater leverage all exacerbate the impact of compounding on an investor's
returns. During periods of higher Index volatility, the volatility of the Index may affect the leveraged fund's return
as much as or more than the return of the Index itself. Therefore, holding leveraged, inverse, and leveraged
inverse funds for longer periods of time increases their risk due to the effects of compounding and the inherent
difficulty in market timing. Leveraged funds are riskier than similarly benchmarked funds that do not use
leverage. Non-traditional funds are highly volatile and not suitable for all investors. They provide the potential
for significant losses.
Buffer ETFs are also known as defined-outcome ETFs since the ETF is designed to offer downside protection for
a specified period of time. These ETFs are modeled after options-based structured notes, but are generally
cheaper and offer more liquidity. Buffer ETFs are designed to safeguard against market downturns by employing
complex options strategies. Buffer ETFs typically charge higher management fees that are considerably more
than the index funds whose performance they attempt to track. Additionally, because buffer funds own options,
they do not receive dividends from their equity holdings. Both factors result in the underperformance of the
Buffer ETF compared to the index they attempt to track. Clients should carefully read the prospectus for a buffer
ETF to fully understand the cost structures, risks, and features of these complex products.
Structured Notes: Below are some specific risks related to the structured notes recommended by our firm:
•
Complexity: Structured notes are complex financial instruments. Clients should understand the
reference asset(s) or index(es) and determine how the note’s payoff structure incorporates such
reference asset(s) or index(es) in calculating the note’s performance. This payoff calculation may include
leverage multiplied by the performance of the reference asset or index, protection from losses should
the reference asset or index produce negative returns, and/or fees. Structured notes may have
complicated payoff structures that can make it difficult for clients to accurately assess their value, risk,
and potential for growth through the term of the structured note. Determining the performance of each
note can be complex, and this calculation can vary significantly from note to note depending on the
structure. Notes can be structured in a wide variety of ways. Payoff structures can be leveraged, inverse,
or inverse-leveraged, which may result in larger returns or losses. Clients should carefully read the
prospectus for a structured note to fully understand how the payoff on a note will be calculated and
discuss these issues with our firm.
• Market risk. Some structured notes provide for the repayment of principal at maturity, which is often
referred to as “principal protection.” This principal protection is subject to the credit risk of the issuing
financial institution. Many structured notes do not offer this feature. For structured notes that do not
offer principal protection, the performance of the linked asset or index may cause clients to lose some
or all of their principal. Depending on the nature of the linked asset or index, the market risk of the
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•
•
•
structured note may include changes in equity or commodity prices, changes in interest rates or foreign
exchange rates, and/or market volatility.
Issuance price and note value: The price of a structured note at issuance will likely be higher than the
fair value of the structured note on the date of issuance. Issuers now generally disclose an estimated
value of the structured note on the cover page of the offering prospectus, allowing investors to gauge
the difference between the issuer’s estimated value of the note and the issuance price. The estimated
value of the notes is likely lower than the issuance price of the notes to investors because issuers include
the costs for selling, structuring, and/or hedging the exposure on the note in the initial price of their
notes. After issuance, structured notes may not be resold on a daily basis and thus may be difficult to
value given their complexity.
Liquidity: The ability to trade or sell structured notes in a secondary market is often very limited, as
structured notes (other than exchange-traded notes known as ETNs) are not listed for trading on
securities exchanges. As a result, the only potential buyer for a structured note may be the issuing
financial institution’s broker-dealer affiliate or the broker-dealer distributor of the structured note. In
addition, issuers often specifically disclaim their intention to repurchase or make markets in the notes
they issue. Clients should, therefore, be prepared to hold a structured note to its maturity date or risk
selling the note at a discount to its value at the time of sale.
Credit risk: Structured notes are unsecured debt obligations of the issuer, meaning that the issuer is
obligated to make payments on the notes as promised. These promises, including any principal
protection, are only as good as the financial health of the structured note issuer. If the structured note
issuer defaults on these obligations, investors may lose some or all of the principal amount they invested
in the structured notes, as well as any other payments that may be due on the structured notes.
Preferred Securities have similar characteristics to bonds in that preferred securities are designed to make fixed
payments based on a percentage of their par value and are senior to common stock. Like bonds, the market value
of preferred securities is sensitive to changes in interest rates as well as changes in issuer credit quality. Preferred
securities, however, are junior to bonds with regard to the distribution of corporate earnings and liquidation in
the event of bankruptcy. Preferred securities that are in the form of preferred stock also differ from bonds in
that dividends on the preferred stock must be declared by the issuer’s board of directors, whereas interest
payments on bonds generally do not require action by the issuer’s board of directors, and bondholders generally
have protections that preferred stockholders do not have, such as indentures that are designed to guarantee
payments – subject to the credit quality of the issuer – with terms and conditions for the benefit of bondholders.
In contrast, preferred stocks generally pay dividends, not interest payments, which can be deferred or stopped
in the event of credit stress without triggering bankruptcy or default. Another difference is that preferred
dividends are paid from the issue’s after-tax profits, while bond interest is paid before taxes.
Alternative Investments in Private Funds, such as hedge funds, private equity, venture capital, private real estate,
private debt, and other private partnerships, typically engage in highly speculative trading strategies. These
private funds are illiquid, their assets may also be illiquid, and their performance results can be extremely volatile.
Alternative funds may rely substantially on fair valuation techniques, which are subjective, and there is no
guarantee that the client would realize proceeds equal to fair value upon the sale of a security. Private funds
typically charge higher management fees and performance fees, and these funds also incur their own operating
expenses, which may be substantial. Such investments are long-term. A portfolio’s ability to transfer and/or
dispose of private investments is expected to be highly restricted. The ability to withdraw funds is usually
restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition,
substantial withdrawals by investors within a short period of time could require a fund to liquidate securities
positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of
the fund’s assets and/or disrupting the fund’s investment strategy.
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Use of Other Managers
In the event we recommend a third-party Manager to manage all or a portion of your assets, we will advise you
on how to allocate your assets among various classes of securities, Managers, programs, or managed model
portfolios. As such, we will primarily rely on investment model portfolios and strategies developed by the
Manager(s) and their portfolio managers. If there is a significant deviation in characteristics or performance from
the stated strategy and/or benchmark, we may recommend changing models, strategies, programs, or Managers
(or, where you grant us discretion to do so, we may change models or strategies within the same Manager’s
program(s). The primary risk associated with investing with a third party is that while a particular third party may
have demonstrated a certain level of success in the past, it may not be able to replicate that success in future
markets. In addition, as we do not control the underlying investments in third-party model portfolios, there is
also a risk that a third party may deviate from the stated investment mandate or strategy of the portfolio, making
it a less suitable investment for our clients. To mitigate this risk, we seek third parties with proven track records
that have demonstrated a consistent level of performance and success over time. A third party’s past
performance is not a guarantee of future results, and certain market and economic risks exist that may adversely
affect an account’s performance, which could result in capital losses in your account. Please refer to the specific
Manager’s advisory agreements, Form ADV Brochure, and associated disclosure documents for details on their
specific investment strategies, methods of analysis, and associated risks.
Disciplinary Information - Item 9
We are required to disclose the facts of any legal or disciplinary events that are material to a client's evaluation
of our advisory business or the integrity of our management. We do not have any required disclosures under this
item.
Other Financial Industry Activities or Affiliations - Item 10
David Merritt, an investment adviser representative with our firm, is a licensed certified public accountant
("CPA"). Mr. Merritt owns a tax and accounting practice, Sterling Financial Advisory Services LLC ("Sterling
Financial"). Clients of our firm may also be clients of Sterling Financial. If you require tax or accounting services,
we may refer you to Sterling Financial. Our advisory services are separate and distinct from the compensation
paid to Sterling. We do not share in any fees paid to Sterling for tax or accounting services.
Brian F. Boyle, President of our firm, and Mr. Merritt are also licensed as independent insurance agents, and they
can effect transactions in life insurance products. It is possible that some clients to whom we offer advisory
services could also be clients for whom Mr. Boyle and Mr. Merritt act as insurance agents. They earn commission-
based compensation for selling insurance products, including insurance products they sell to our clients. In such
cases, clients are instructed that the fees paid to the firm for advisory services are separate and distinct from the
commissions earned by Mr. Boyle and Mr. Merritt for placing the client in insurance products. The sale of
insurance instruments and other commissionable products offered by our licensed individuals is intended to
complement our advisory services. However, this practice presents a conflict of interest because persons
providing investment advice on behalf of our firm who are insurance agents have an incentive to recommend
insurance products to you for the purpose of generating commissions rather than making recommendations
based solely on your needs. We address this conflict of interest by recommending insurance products only where
we, in good faith, believe that it is appropriate for the client’s particular needs and circumstances, and only after
a full presentation of the recommended insurance product to our client. In addition, we explain the insurance
underwriting process to our clients to illustrate how the insurer also reviews the client’s application and
disclosures prior to the issuance of a resulting insuring agreement. Moreover, clients are under no obligation to
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utilize the insurance services of Mr. Boyle or Mr. Merritt or of any particular insurance provider and may use any
insurance provider or agent they choose.
Referral arrangements with persons affiliated with our firm present a conflict of interest for us because we may
have a direct or indirect financial incentive to recommend insurance products or accounting services. While we
believe that the compensation charged by Mr. Merritt and Sterling is competitive, such compensation may be
higher than fees charged by others providing the same or similar services. You are under no obligation to use the
services of any tax, accounting, or insurance provider we recommend, whether affiliated or otherwise, and you
may obtain comparable services and/or lower fees through other providers.
Recommendation of Other Managers
As disclosed above, we may recommend the use of third-party Manager(s) or programs to manage all or a portion
of your portfolio. Please see Items 4, 5, and 8 of this brochure for additional information regarding this topic.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11
We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code of Ethics
includes guidelines for professional standards of conduct for persons associated with our firm. Our goal is to
protect your interests at all times and to demonstrate our commitment to our fiduciary duties of honesty, good
faith, and fair dealing with you. All persons associated with our firm are expected to adhere strictly to these
guidelines. Our Code of Ethics also requires that certain persons associated with our firm submit reports of their
personal account holdings and transactions to a qualified representative of our firm who will review these reports
periodically. Persons associated with our firm are also required to report any violations of our Code of Ethics.
Additionally, we maintain and enforce written policies reasonably designed to prevent the misuse or
dissemination of material, non-public information about you or your account holdings by persons associated with
our firm.
Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the telephone number
on the cover page of this brochure.
Participation or Interest in Client Transactions and Personal Trading Practices
It is our policy that persons associated with our firm or our firm shall not have priority over any client transactions
in the purchase or sale of securities. We, our associated persons, and/or third-party Managers may buy or sell
securities for you that we buy, sell, or currently own for our own accounts.
A conflict of interest exists in cases where we have the ability to trade ahead of you and potentially receive more
favorable prices than you will receive. To eliminate this conflict of interest, it is our policy that persons associated
with our firm or our firm shall not have priority over any client transactions in the purchase or sale of securities.
Although we would not necessarily be aware of the timing of trades being considered by a selected Manager
prior to the transaction, this could be considered a potential conflict of interest with clients. Where we and any
persons associated with our firm are aware that a Manager is considering specific transactions for clients’
accounts on a specific trading day where there is a potential material conflict, we will make every effort to be
“last in” and “last out” for the trading day when trading occurs in close proximity to client trades for which we
are aware.
Under certain circumstances, exceptions to the trading policy may be made. The foregoing policy does not apply
to investments in:
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• direct obligations of the Government of the United States;
• money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper,
repurchase agreements, and other high-quality short-term debt instruments, including repurchase
agreements;
• shares issued by mutual funds or money market funds; and,
• shares issued by unit investment trusts that are invested exclusively in one or more mutual funds.
Brokerage Practices - Item 12
Brokerage Practices
We and selected third-party Managers routinely require clients to utilize the brokerage and custodial services of
Charles Schwab & Co., Inc. (Schwab), a registered broker-dealer, member of the Financial Industry Regulatory
Authority (FINRA) and the Securities Investor Protection Corporation (SIPC). We believe that Schwab provides
quality execution services for clients at competitive prices. Price is not the sole factor we consider in evaluating
best execution. We also consider the quality of the brokerage services provided, including the value of research
provided, the company’s reputation, execution capabilities, commission rates, and responsiveness to our clients
and our firm. In recognition of the value of research services and additional brokerage products and services
Schwab provides, lower commissions and/or trading costs may be available elsewhere.
We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your assets in
a brokerage account and buy and sell securities when we or you instruct them to. While we require that you use
Schwab as custodian/broker, you will decide whether to do so and will open your account with Schwab by
entering into an account Agreement directly with them. Conflicts of interest associated with this arrangement
are described below. You should consider these conflicts of interest when selecting your custodian.
We do not open the account for you, although we may assist you in doing so. If you do not wish to place your
assets with Schwab, then we cannot manage your account. Not all advisors require their clients to use a particular
broker-dealer or other custodian selected by the advisor. Even though your account is maintained at Schwab,
and we anticipate that most trades will be executed through Schwab, we can still use other brokers to execute
trades for your account as described below (see “Your Brokerage and Custody Costs”).
How We Select Brokers/Custodians
We use Schwab to hold your assets and execute transactions. When considering whether the terms that Schwab
provides are, overall, most advantageous to you when compared with other available providers and their
services, we take into account a wide range of factors, including:
•
•
•
Combination of transaction execution services and asset custody services (generally without a separate
fee for custody)
Capability to execute, clear, and settle trades (buy and sell securities for your account)
Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill
payments, etc.)
• Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs),
etc.)
• Availability of investment research and tools that assist us in making investment decisions
• Quality of services
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•
Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.)
and willingness to negotiate the prices
Prior service to our clients and us
Services delivered or paid for by Schwab
• Reputation, financial strength, security, and stability
•
•
• Availability of other products and services that benefit us, as discussed below
Your Brokerage and Custody Costs
For our clients’ accounts that Schwab maintains, Schwab generally does not charge separately for custody
services but is compensated by charging commissions or other fees on trades that it executes or that settle into
your Schwab account. Schwab is also compensated by earning interest on the uninvested cash in your account
in Schwab’s Cash Features Program. Certain trades (for example, mutual funds and ETFs) do not incur Schwab
commissions or transaction fees. However, the wrap fee we charge includes redemption fees resulting from
mutual fund trades along with any commissions, markups, and markdowns resulting from transactions effected
through or with a broker-dealer other than Schwab (also known as “step-out” or “trade away” fees). For some
accounts, Schwab charges a percentage of the dollar amount of assets in the account in lieu of commissions.
Schwab’s commission rates and asset-based fees applicable to our client accounts were negotiated based on the
condition that our clients collectively maintain a total of at least $10 million of their assets in accounts at Schwab.
This commitment benefits you because the overall commission rates and asset-based fees you pay are lower
than they would be otherwise. If we have less than $10 million in client assets at Schwab, it may charge us
quarterly service fees, but those fees will not be passed on to you. Schwab also charges 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 charged by the executing broker-dealer.
As noted above, all such “trade away” fees are paid by us for wrap-fee accounts. Because of this, in order to
minimize trading costs, we will have Schwab execute most trades for your account.
fees, extension
fees,
fees, administrative
fees, dividend
reinvestment
Your account(s) may incur costs associated with additional services requested by you including, but not limited
to wire or electronic fund transfer fees, overnight delivery fees, duplicate statement fees, account transfer fees,
foreign
reorganization
dividend/custody/settlement fees, returned check fees, share class exchange fees, special product fees, stop
payment fees, termination fees, or any contingent deferred sales charges that may be incurred upon the sale of
a security transferred into the Program account at your request. Additionally, there may be other costs assessed
to your account that are not included in the Program Fee, such as national securities exchange fees, SEC or other
regulatory fees, charges for transactions with respect to assets not executed through the custodian, costs
associated with exchanging currencies, or other fees required by law.
We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker
provides execution quality comparable to other brokers or dealers. Although we are not required to execute all
trades through Schwab, 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, including those listed above (see “How We Select Brokers/Custodians”).
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Form ADV Part 2A
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Research and Other Soft Dollar Benefits
Although the following products and services are not purchased with “soft dollar” credits, we will receive certain
economic benefits (soft dollar benefits) from Schwab in the form of access to Schwab’s institutional brokerage
and support services at no additional cost or at a discounted cost. Below is a detailed description of Schwab’s
support services:
Products and Services Available to Us from Schwab
Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like ours. They
provide our clients and us with access to their institutional brokerage services (trading, custody, reporting, and
related services), many of which are not typically available to Schwab retail customers. However, certain retail
investors may be able to get institutional brokerage services from Schwab without going through us. 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. Schwab’s support services are generally available
on an unsolicited basis (we don’t have to request them) and at no charge to us.
Services that Benefit You: Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of client assets. The investment products
available through Schwab include some that we might not otherwise have access to, or that would require a
significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph
generally benefit you and your account.
Services that Do Not Directly Benefit You: Schwab also makes available to us other products and services that
benefit us but do not directly benefit you or your account. These products and services assist us in managing and
administering our clients’ accounts and operating our firm. They include investment research, both Schwab’s
own and that of third parties. We use this research to service all or a substantial number of our clients’ accounts,
including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available
software and other technology that:
provide access to client account data (such as duplicate trade confirmations and account statements)
facilitate trade execution and allocate aggregated trade orders for multiple client accounts
provide pricing and other market data
facilitate payment of our fees from our clients’ accounts
assist with back-office functions, recordkeeping, and client reporting
•
•
•
•
•
Services that Generally Benefit Only Us: Schwab also offers other services intended to help us manage and
further develop our business enterprise. These services include:
Educational conferences and events
Consulting on technology and business needs
Consulting on legal and compliance-related needs
Publications and conferences on practice management and business succession
•
•
•
•
• Access to employee benefits providers, human capital consultants, and insurance providers
• Marketing consulting and support
• Recruiting and custodial search consulting
Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide
the services to us. Schwab also discounts or waives its fees for some of these services or pays all or a part of a
Boyle Capital
Form ADV Part 2A
Page 23
third party’s fees. Schwab also provides us with other benefits, such as occasional business entertainment for
our personnel. If you did not maintain your account with Schwab, we would be required to pay for those services
from our own resources.
We understand our duty for best execution and consider all factors in making recommendations to clients. These
research services may be useful in servicing all our clients and may not be used in connection with any particular
account that may have paid compensation to the firm providing such services. While we may not always obtain
the lowest commission rate, we believe the rate is reasonable in relation to the value of the brokerage and
research services provided.
Our Interest in Schwab’s Services
The availability of these services from Schwab benefits us because we do not have to produce or purchase them.
We don’t have to pay for Schwab’s services.
Schwab has also agreed to pay for certain technology, research, marketing, and compliance consulting products
and services on our behalf. These services are not contingent upon our committing any specific amount of
business to Schwab in trading commissions or assets in custody.
The fact that we receive these benefits from Schwab is an incentive for us to require the use of Schwab rather
than making such a decision based exclusively on your interest in receiving the best value in custody services and
the most favorable execution of your transactions. This is a conflict of interest. We believe, however, that taken
in the aggregate, our selection of Schwab as custodian and broker is in the best interests of our clients. Our
selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How We Select
Brokers/Custodians”) and not by Schwab’s services that benefit only us.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as
brokerage services or research.
Directed Brokerage
We routinely require that you direct our firm to execute transactions through broker-dealers with whom we have
a business relationship, such as Schwab. As such, we may be unable to achieve the most favorable execution of
your transactions, and you may pay higher brokerage commissions than you might otherwise pay through
another broker-dealer that offers the same types of services. Not all advisers require their clients to direct
brokerage.
Block Trades
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”) whenever possible. 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. In rare instances, such as partial fills or limited shares of thinly traded or illiquid
stocks, it may be necessary to place block trades for only small groups of clients over a period of time. Subject to
our discretion regarding factual 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.
(Participants in our Wrap Fee Program do not pay separate transaction fees.) Accounts owned by our firm or
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Form ADV Part 2A
Page 24
persons associated with our firm may participate in block trading with your accounts; however, they will not be
given preferential treatment.
We combine multiple orders for shares of the same securities purchased for discretionary accounts; however,
we do not combine orders for non-discretionary accounts. Accordingly, non-discretionary accounts may pay
different costs than discretionary accounts pay. If you enter into non-discretionary arrangements with our firm,
we may not be able to buy and sell the same quantities of securities for you, and you may pay higher
commissions, fees, and/or transaction costs than clients who enter into discretionary arrangements with our
firm.
We do not combine multiple orders for shares of the same mutual funds purchased for advisory accounts we
manage because mutual funds do not trade in blocks.
Third-party Managers may or may not block trade client accounts. Please see the Manager’s disclosure
brochure for information regarding block trading and other brokerage practices.
Review of Accounts - Item 13
Account reviews are conducted on an ongoing basis by Brian Boyle, Managing Member and Chief Compliance
Officer, or Ryan O'Hare, Chief Operating Officer. It is your responsibility to advise us of any changes in your
investment objectives and/or financial situation. You are encouraged to review investment objectives and
account performance with us at least annually, either in person or by phone.
Additional reviews may be conducted based on various circumstances, including, but not limited to:
• contributions and withdrawals,
• year-end tax planning,
• market-moving events,
• security-specific events, and/or
• changes in your risk/return objectives.
We will not provide you with additional or regular written reports in conjunction with account reviews. However,
you will receive trade confirmations, monthly or quarterly statements, and year-end tax statements from your
account custodian(s) and/or from relevant third-party advisers in accordance with their disclosures and your
agreement with the relevant third-party adviser.
Dave Merritt, Investment Adviser Representative, will review financial plans as needed, depending on the
arrangements made with you at the inception of your advisory relationship to ensure that the advice provided is
consistent with your investment needs and objectives. Generally, we will contact you periodically to determine
whether any updates may be needed based on changes in your circumstances. Changed circumstances may
include, but are not limited to, a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss, and/or
disability, among others. We recommend meeting with you at least annually to review and update your plan if
needed. Additional reviews will be conducted upon your request. Such reviews and updates may be subject to
our then-current hourly rate. We will not provide regular written reports for financial planning and consulting
services. If you implement financial planning advice, you will receive trade confirmations and monthly or
quarterly statements from relevant custodians.
Boyle Capital
Form ADV Part 2A
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Client Referrals and Other Compensation - Item 14
We directly compensate non-employee (outside) consultants, individuals, and/or entities (Promoters) for client
referrals. In order to receive a cash referral fee from our firm, Promoters must comply with the requirements of
the jurisdictions in which they operate. If you become a client, the Promoter that referred you to our firm will
receive a percentage of the advisory fee you pay our firm for as long as you are a client with our firm, or until
such time as our agreement with the Promoter expires. You will not pay additional fees because of this referral
arrangement. Referral fees paid to a Promoter are contingent upon your entering into an advisory agreement
with our firm. Therefore, a Promoter has a financial incentive to recommend our firm to you for advisory services.
This creates a conflict of interest; however, you are not obligated to retain our firm for advisory services.
Comparable services and/or lower fees may be available through other firms.
Promoters that refer business to more than one investment adviser may have a financial incentive to recommend
advisers with more favorable compensation arrangements. We request that our Promoters disclose to you
whether multiple referral relationships exist and that comparable services may be available from other advisers
for lower fees and/or where the Promoter’s compensation is less favorable.
Third-party Manager fees are separate and in addition to Boyle Capital’s fees. Boyle Capital does not share in
fees charged by other Managers.
Custodial Benefits
As described in Item 12 above, we receive economic benefits from our custodial broker-dealer in the form of
support products and services they make available to us and other independent investment advisors whose
clients maintain their accounts at these custodial broker dealers. The availability of custodial products and
services is not dependent upon or based on the specific investment advice we provide our clients, such as buying
or selling specific securities or specific types of securities for our clients. The products and services provided by
the custodial broker-dealer, how they benefit us, and the related conflicts of interest are described above (see
Item 12 – Brokerage Practices).
Economic Benefits Received from Vendors and Product Sponsors
Occasionally, our firm and our Associated Persons will receive additional compensation from vendors.
Compensation could include such items as gifts, an occasional dinner or ticket to a sporting event, reimbursement
in connection with educational meetings with an Associated Person, reimbursement for consulting services,
client workshops, or events, or marketing events or advertising initiatives, including services for identifying
prospective clients. Receipt of additional economic benefits presents a conflict of interest because our firm and
Associated Persons have an incentive to recommend and use vendors based on the additional economic benefits
obtained rather than solely on the client’s needs. We address this conflict of interest by recommending vendors
that we, in good faith, believe are appropriate for the client’s particular needs. Clients are under no obligation
contractually or otherwise, to use any of the vendors recommended by us.
Custody - Item 15
We do not have physical custody of any of your funds and/or securities. Your funds and securities will be held
with a bank, broker-dealer, or other independent, qualified custodian. As a paying agent for our firm, your
independent custodian will directly debit your account(s) for the payment of our advisory fees upon our
instruction. Therefore, we are deemed to have custody of client funds or securities limited to the fee deduction
authority granted by you in the investment advisory agreement with us, and in certain situations where we accept
standing letters of authorization from you to transfer assets to third parties. We maintain safeguards in
accordance with regulatory requirements regarding the custody of client assets. Additionally, you will receive
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Form ADV Part 2A
Page 26
account statements from the independent, qualified custodian(s) holding your funds and securities at least
quarterly. Third-party Managers will calculate and deduct their fees from the accounts pursuant to the advisory
agreements you sign with us and/or them. The account statements from your custodian(s) will indicate any
deductions from your accounts, including the amount of advisory fees deducted from your account(s) each billing
period and paid to us and applicable third-party Managers. You should carefully review account statements for
accuracy. If you have a question regarding your account statement, or if you did not receive a statement from
your custodian, please contact us directly at the telephone number on the cover page of this brochure.
Investment Discretion - Item 16
Before we can buy or sell securities on your behalf, you must first sign our management agreement and/or
trading authorization forms.
If you enter into discretionary arrangements with our firm, you will grant our firm discretion over the selection
and amount of securities to be purchased or sold for your account(s) without obtaining your consent or approval
prior to each transaction. You may specify investment objectives, guidelines, and/or impose certain conditions
or investment parameters for your account(s). For example, you may specify that the investment in any particular
stock or industry should not exceed specified percentages of the value of the portfolio and/or restrictions or
prohibitions of transactions in the securities of a specific industry or security. Please refer to the “Advisory
Business” section in this brochure for more information on our discretionary management services.
If you enter into non-discretionary arrangements with our firm, we will obtain your approval prior to the
execution of any transactions for your account(s). You have an unrestricted right to decline to implement any
advice provided by our firm on a non-discretionary basis.
Voting Client Securities - Item 17
Proxy Voting
Boyle Capital does not accept authorization to vote proxies on behalf of clients. At your request, we may offer
you advice regarding corporate actions and the exercise of your proxy voting rights. If you own shares of
applicable securities, you or your designated representative is responsible for exercising your right to vote as a
shareholder. 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 any
electronic solicitations to vote proxies. Other Managers typically do not vote proxies.
Financial Information - Item 18
Our firm does not have any financial condition or impairment that would prevent us from meeting our contractual
commitments to you.
Boyle Capital
Form ADV Part 2A
Page 27
Miscellaneous
Your Privacy
We view protecting your private information as a top priority. Pursuant to applicable privacy requirements, we
have instituted policies and procedures to ensure that we keep your personal information private and secure.
We do not disclose any nonpublic personal information about you to any non-affiliated third parties, except as
permitted by law. In the course of servicing your account, we may share some information with our service
providers, such as transfer agents, custodians, broker-dealers, accountants, consultants, and attorneys.
We restrict internal access to nonpublic personal information about you to employees who need that information
in order to provide products or services to you. We maintain physical and procedural safeguards that comply
with regulatory standards to guard your nonpublic personal information and to ensure our integrity and
confidentiality. We will not sell information about you or your accounts to anyone. We do not share your
information unless it is required to process a transaction, at your request, or required by law.
You will receive a copy of our privacy notice prior to or at the time you sign an advisory agreement with our firm.
Thereafter, we will deliver a copy of the current privacy policy notice to you on an annual basis. Please contact
our main office at the telephone number on the cover page of this brochure if you have any questions regarding
this policy.
Class Action Lawsuits and Other Legal Matters
Please note that Boyle Capital will not advise or act for the Client with respect to any legal matters, including
bankruptcies and class actions, with respect to the securities held in the Client’s Account(s). We do not determine
if securities held by you are the subject of a class action lawsuit or whether you are eligible to participate in class
action settlements or litigation, nor do we initiate or participate in litigation to recover damages on your behalf
for injuries as a result of actions, misconduct, or negligence by issuers of securities held by you.