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ADV PART 2A - FIRM BROCHURE
Apple Tree Asset Management, LLC (CRD 298437), brochure dated October 22, 2026. Text extracted from the firm's SEC Form ADV Part 2 brochure.
View firm on SEC ↗ · Current Form ADV (PDF) ↗
APPLE TREE ASSET MANAGEMENT, LLC
4321 Flagstaff Cove
Fort Wayne, IN 46815
Phone: (260) 637-7278
Form ADV Part 2A
Firm Brochure
October 22, 2026
This brochure provides information about the qualifications and business practices of Apple Tree
Asset Management, LLC. If you have any questions about the contents of this brochure, please
contact us at (260) 637-7278. 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.
Apple Tree Asset Management, LLC is a registered investment adviser. Registration of an
investment adviser does not imply any level of skill or training.
Additional information about Apple Tree Asset Management, LLC is available on the SEC’s
website www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known
as a CRD number. Apple Tree Asset Management, LLC’s CRD number is 298437.
Item 2 - Material Changes
We have the following material changes to report since last annual update to this firm
brochure, which was on March 26, 2026.
None
This Item will discuss only specific material changes that are made to the Brochure and provide
clients with a summary of these changes. We will also reference the date of our last annual
update to this Brochure.
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Item 3 – Table of Contents
Item 2 - Material Changes ............................................................................................................................. 2
Item 3 – Table of Contents ............................................................................................................................ 3
Item 4 – Advisory Business ............................................................................................................................ 4
Item 5 – Fees and Compensation .................................................................................................................. 6
Item 6 – Performance-Based Fees and Side by Side Management ............................................................... 9
Item 7 – Types of Clients ............................................................................................................................... 9
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ......................................................... 9
Item 9 – Disciplinary Information ................................................................................................................ 10
Item 10 – Other Financial Industry Activities and Affiliations ...................................................................... 10
Item 11 – Code of Ethics, Participation or Interest in Client Transaction and Personal Trading ................. 11
Item 12 – Brokerage Practices ..................................................................................................................... 12
Item 13 – Review of Accounts ..................................................................................................................... 13
Item 14 – Client Referrals and Other Compensation ................................................................................... 13
Item 15 – Custody ....................................................................................................................................... 13
Item 16 – Investment Discretion ................................................................................................................. 13
Item 17 – Voting Client Securities ............................................................................................................... 14
Item 18 – Financial Information .................................................................................................................. 14
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Item 4 – Advisory Business
OWNERSHIP/ADVISORY HISTORY
Apple Tree Asset Management, LLC (“We”) is an Indiana limited liability company established in
October 2018 and became registered as an investment adviser in March 2021. We are owned
and managed by Keith Layman and Joseph Wiegand. Additional information about Mr. Layman
and Mr. Wiegand can be found under Item 19 along with their supplemental brochure.
ADVISORY SERVICES OFFERED
Before we enter into an adviser-client relationship, we may offer a complimentary general
consultation to determine a prospective client’s needs and discuss services available that meet
those needs. Only after a prospective client has had time to review our solutions/services can he
or she determine whether a relationship might benefit them. Our investment advisory services
begin only after we and the client formalize the relationship with a properly executed agreement.
FINANCIAL PLANNING
We offer comprehensive financial planning along with single issue financial consulting services.
Our comprehensive financial planning services includes an evaluation of the client’s financial
situations, goals, risk tolerance, and investment time horizon. Through a series of personal
interviews and the use of questionnaires, we collect pertinent data, identify goals, objectives,
financial problems, and potential solutions. We prepare and present specific recommendations,
which are implemented when agreed to by the client. Depending on the client’s situation the
written plan may cover any of the following topics: financial and cash management, risk
management through the use of insurance, net worth planning, investment planning, estate
planning, tax issues, retirement planning, educational funding, goal setting, or other needs as
identified by the client and us. The topics are tailored to the needs of the client. At the conclusion
of the comprehensive financial planning service, we present the client with a written financial
plan.
Our financial consulting service is provided when a client needs assistance with one or two
financial topics. This service generally does not involve creating a written financial plan. Typically,
we meet with the client to discuss his or her questions, conduct research and present its findings
through a second meeting.
PORTFOLIO MANAGEMENT SERVICES
We offer ongoing portfolio management services that are based on the individual goals,
objectives, time horizon, and risk tolerance of each client. We evaluate the current investments
of each client with respect to their risk tolerance levels and time horizon. With this information
we create a customized portfolio using a combination of our proprietary model portfolios. We
will request discretionary authority from a client to select securities and execute transactions
without permission from the client prior to each transaction. We base its investment
recommendations on a variety of factors including, but not limited to, performance risk, fees, tax
efficiency of different investment strategies, as well as client input and preferences regarding the
strategies.
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RECOMMENDATION AND MONITORING OF THIRD PARTY ADVISERS
We recommend and monitor third-party investment advisers (“Third-Party Adviser”). We may
recommend one or more Third-Party Advisers to the client. The recommendation will depend
on the client’s circumstances, goals and objectives, strategy desired, account size, risk tolerance,
or other factors. We work with each client to determine which Third-Party Adviser may be
appropriate. Clients are never obligated to use a recommended Third-Party Adviser.
We review the Third-Party Advisers prior to making a recommendation to the client. We consider
the following factors during its review: fees, reputation, performance, financial strength,
management, price, reporting capabilities, client’s financial situation, client’s goals, client’s
needs, and client’s investment objectives. After our review, we present the client with one or
more recommendations.
If the client wishes to proceed with the recommendation, we will enter into a solicitor agreement
with the recommended Third-Party Adviser. Under these arrangements, the Third-Party Adviser
is responsible for portfolio management, best execution, portfolio reporting, trading, trade error
resolution, and custodian reconciliations. We maintain our relationship with the client by
monitoring the status of the client’s accounts with the Third-Party Adviser, making
recommendation about the Third-Party Adviser, usually meeting with the client either in person,
by zoom meeting, or by telephone on an annual basis and acting as the client’s primary financial
adviser. All questions regarding the Third-Party Adviser’s services and performance should be
directed to us.
Clients who are referred to Third-Party Advisers will receive full disclosure, including services
rendered and fee schedules, at the time of the referral, by delivery of a copy of the relevant Third-
Party Adviser’s Form ADV Part 2A or equivalent disclosure document before receiving investment
advisory services from the Third-Party Adviser.
QUALIFIED PLAN CONSULTING
We offer qualified plan consulting services. We can provide any of the following services to ERISA
Plans: Education Services to Plan committee; Participant Education Services; Plan Search
Support; Review of Fiduciary Liability Insurance Coverage; Monitoring or Qualified Fiduciary; or
Participant Advice. When requested by the client, we will provide any of the following services:
create an investment Policy Statement; provide investment Recommendations & Performance
Monitoring; or Selection of Qualified Default Investment Alternative.
We also provide services to other non-ERISA qualified plans such as 457 Plans. We offer a variety
of services to the qualified plan’s trustee. These services include, but not limited to: plan
benchmarking of fees, investment policy statement development and drafting, research on
investment manager, investment monitoring, participant education services, request for
statement of qualification services and request for proposal services. We work with the qualified
plan’s trustee to tailor a program specifically for the plan.
TAX PREPARATION
We offer tax preparation and filing services to clients through a separate tax services engagement
letter. We provide preparation and filings for federal and applicable state income tax returns to
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individuals and families. Our services are only available to our clients who engage us in our
financial planning and investment management services.
TAILORED SERVICES
The goals and objectives for each client are documented before any investing takes place. Clients
may impose restrictions on investing in certain securities or types of securities.
WRAP PROGRAM
We are not a sponsor or portfolio management of a wrap fee program.
CLIENT ASSETS MANAGED
As of January 5, 2026, we co-manage accounts with Third-Party Advisers $26,220,066. We also
manage on our own $118,206,639 of discretionary assets and $33,643,466 of non-discretionary
assets.
Item 5 – Fees and Compensation
FINANCIAL PLANNING SERVICES
Comprehensive Financial Planning: We charge a fixed fee that ranges from $1,000 to $5,000 for
comprehensive financial planning. The fee varies and depends upon the nature and complexity
of each client’s individual circumstances.
Financial Consulting Services: We assess an hourly rate of $250 for financial consulting services
with a minimum of one hour per engagement. The number of hours will vary depending upon
the complexity of the financial situation, preparation, research and number of meetings.
All financial planning and consulting fees are agreed upon signing the financial planning and
consulting agreement and collected upon delivery of the financial plan or consulting service. The
fees are negotiable and may be waived at the firm’s discretion.
PORTFOLIO MANAGEMENT SERVICES
We charge an annual management fee that is based on the assets under management in the
client’s account. The annual management fee is based on the following tiered fee schedule:
Custodian Reported Account Value Annual Management Fee
First $0 - $500,000
Next $501,000 - $750,000
Next $750,001 - $1,000,000
Next $1,000,000 +
1.50%
1.25%
1.00%
0.75%
An administrative fee of 0.25% is charged in addition to the management fee.
A tiered fee schedule means that the applicable rate will be applied to the custodian reported
value in each account value range. For example, with an account value of $750,000, the first
$500,000 will be charged 1.50% and the next $250,000 will be charged 1.25%. Each client’s fee
schedule will be described in his or her investment management agreement.
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The management fee is calculated and billed monthly in arrears using the daily average assets
under management (AUM). This means we collect the management fee at the end of the
monthly billing period. The management fee will be based on the average daily account balance
for the month as reported by the custodian. The fee will be directly deducted from the client’s
account (See Item 15 for additional details). The management fee is negotiable based on the
size of the account. The client may aggregate accounts to achieve a lower management fee.
Our management fee does not include ticket charges, transaction fees, and other related costs
and expenses that are normally incurred by the client. Clients may incur certain other charges
imposed by the custodian, trading broker, deferred sales charges, odd-lot differentials, transfer
taxes, wire transfer fee, electronic fund transfer fees, and other fees and taxes on brokerage
accounts and securities transactions. Mutual funds and exchange traded funds also charge
internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and
commissions are exclusive of and in addition to, our fee and we will not receive any portion of
these commissions, fees, and costs. For more information about our brokerage practice please
see Item 12.A.
RECOMMENDATION OF THIRD PARTY INVESTMENT ADVISER
In certain situations, when recommending a Third-Party Adviser, we will be treated as a solicitor
of the recommended Third-Party Adviser. When we are acting as a solicitor it does not charge a
separate fee for the Recommendation of Third-Party Investment Adviser Services. Instead, we
enter into an agreement with the Third-Party Adviser and share a portion of the Third-Party
Adviser’s management fee that is charged to the client. Our portion can be up to 50% of the
Third-Party Adviser’s management fee. The exact amount will be disclosed in the Third-Party
Adviser’s Solicitor Disclosure Document, which is given to the client upon engagement.
Additionally, when the management fee is withdrawn (quarterly or monthly, in advance or in
arrears) will vary with each Third-Party Adviser. These details will be disclosed in the Third-Party
Adviser’s ADV Part 2A and the Third-Party Adviser’s Solicitor Disclosure Document; both
documents will be given to the client upon solicitation.
As established in Item 10.D – Other Industry Affiliations, by receiving a portion of the Third-Party
Advisor’s management fee, this creates a conflict of interest for the Adviser. The sharing of the
management fees creates a financial incentive to recommend Third-Party Advisers that would
pay Adviser a higher percentage of their fee. Adviser attempts to mitigate the conflict of interest
to best of its ability by placing the client’s interest a head of its own, through its fiduciary duty
and by following its Code of Ethics that establishes ideals for ethical conduct.
QUALIFIED RETIREMENT PLAN CONSULTING
Our advisory fees may be an hourly fee, a fixed fee, or a fee based on a percentage of assets
under management in the plan. We negotiate the type of fee with the client.
Hourly Fee: Our hourly rate is $250. The fee may be negotiable based on the services provided.
Fixed Fee: We charge an annual fixed fee ranging between $1,000 to $50,000. The fixed fee is
negotiable based on the size of the plan.
Assets Under Management Fee: We charge an annual management fee based on the asset in the
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plan. The annual management fee is up to 0.75%. The management fee is negotiable based on
the size of the plan and services provided.
Hourly fees are billed monthly in arrears as the hours are accrued. Fixed and assets under
management fees are calculated and billed quarterly in arrears. This means we collect the fee at
the end of the quarterly billing period. The assets under management fee will be based on the
custodian reported plan value as of the last business day of the quarter.
The fees will either be direct deduction from the plan or an invoice will be sent to the client.
This will be negotiated with the client and memorialized in the client agreement.
TAX PREPARATION SERVICES
We will charge a fee per form that is completed and filed. The fees per form range between $5
to $200. Clients will receive a discount that is based on the amount of assets under
management they invest with us, the discounts are as follows:
AUM
0-$100,000
$100,001-$250,000
$250,001-$500,000
$500,001-$750,000
$750,001-$1,000,000
$1,000,000+
Discount
$ (25.00)
$ (50.00)
$ (75.00)
$ (125.00)
$ (175.00)
Free for client and children
Fees are due at the completion of the service and may be paid by check, digital payment vender,
or from an account managed by us if allowed by the custodian.
Termination of Services
The client may cancel the service for any reason during the first five (5) business days from the
date of signing the agreement and will receive a refund of 100% of all fees paid without cost or
penalty. After the first five (5) business days the client may cancel the agreement by giving ten
(10) days written notice. To cancel the agreement, the client must notify us in writing at Apple
Tree Asset Management, LLC, 4321 Flagstaff Cove, Fort Wayne, IN 46815. Upon receipt of written
notice of termination, if the client was being charged in advance, the client will receive a prorated
refund based on the amount of time services were rendered during the termination period. For
example, the client would receive a 50% refund if the client is being charged quarterly in advance
and services were provided for 45-days during a 90-day quarter. (45 divided by 90 equals 50%)
OTHER SECURITIES COMPENSATION
We do not receive any additional securities compensation.
RETIREMENT ROLLOVER CONFLICTS OF INTEREST
When we recommend you rollover a retirement account for us to manage, this creates a financial
incentive because we charge a fee for our services. We attempt to mitigate the conflict of interest
by acting in your best interest and applying an impartial conduct standard to all rollovers. Please
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note that you are not under any obligation to roll over a retirement account to an account
managed by us.
Item 6 – Performance-Based Fees and Side by Side Management
We do not charge any performance-based fees (fees based on a share of capital gains on or
capital appreciation of the assets of a client) or provide side by side management.
Item 7 – Types of Clients
We offer our services to individuals, high net worth individuals, charities, corporations and other
business entities, and pension and profit-sharing plans. We require a minimum account size of
$50,000. This may be waived at our discretion.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
METHODS OF ANALYSIS AND INVESTMENT STRATEGIES
We use asset allocation as our investment strategy. Asset allocation is an investment strategy
that aims to balance a risk and reward by apportioning a portfolio’s assets according to an
individual’s goals, risk tolerance and investment horizon. The asset classes typically include
equities, fixed-income, international, and cash and equivalents. The risk associated with asset
allocation is that each class has different levels of risk and return, so each will behave differently
over time. There is not guarantee that diversification amount asset classes will grow a portfolio.
The main sources of information include signal providers, financial newspapers and magazines,
inspections of corporate activities, research materials prepared by others, corporate rating
services, timing services, annual reports, prospectuses, filings with the Securities and Exchange
Commission, and company releases.
INVESTMENT RISKS
All investment programs have certain risks that are borne by the client and investing in securities
involves risk of loss that clients should be prepared to bear. Our goal is to reduce the risk of loss,
but not at the expense of portfolio growth. Recommended investment strategies seek to balance
risks and rewards to achieve investment objectives. To manage risk, we rebalance model
portfolios on an as needed basis to bring the asset allocations back to their intended balances.
The client should feel free to ask questions about risks that he or she does not understand; we
would be pleased to discuss them.
RECOMMENDED SECURITIES
We use several types of securities in client portfolios including, but not limited to, mutual funds,
ETFs, stocks and bonds. Some of the risk associated with these securities include:
Credit Risk: This is the risk that an issuer of a bond could suffer an adverse change in
financial condition that results in a payment default, security downgrade, or inability to
meet a financial obligation.
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Inflation Risk: This is the risk that inflation will undermine the performance of an
investment and/or the future purchasing power of a client's assets.
Interest Rate Risk: The chance that bond prices overall will decline because of rising
interest rates.
International investing Risk: Investing in the securities of non-U.S. companies involves
special risks not typically associated with investing in U.S. companies. Foreign securities
tend to be more volatile and less liquid than investments in U.S. securities, and may lose
value because of adverse political, social or economic developments overseas or due to
changes in the exchange rates between foreign currencies and the U.S. dollar. In addition,
foreign investments are subject to settlement practices, as well as regulatory and financial
reporting standards, that differ from those of the U.S.
Manager Risk: The chance that the proportions allocated to the various securities will
cause the client’s account to underperform relevant to benchmarks or other accounts
with a similar investment objective.
Portfolio Concentration: Accounts that are not diversified among a wide range of types
of securities, countries or industry sectors may have more volatility and are considered to
have more risk than accounts that are invested in a greater number of securities because
changes in the value of a single security may have more of a significant effect, either
negative or positive. Accordingly, portfolios are subject to more rapid changes in value
than would be the case if the client maintained a more diversified portfolio.
Stock Market Risk: The chance that stock prices overall will decline. Stock markets tend
to move in cycles, with periods of rising stock prices and periods of falling stock prices.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would-be material to your evaluation of each supervised person
providing investment advice. We do not have information applicable to this item.
Item 10 – Other Financial Industry Activities and Affiliations
BROKER DEALER AFFILIATION
We are not affiliated with a broker-dealer.
FUTURES/COMMODITIES FIRM AFFILIATION
We are not affiliated with a futures or commodities broker.
OTHER INDUSTRY AFFILIATIONS
Our owners and associates may be independent insurance agents and may recommend
insurance products to the firm’s clients. This other business activity pays them commissions that
are separate from the fees described in Item 5 above. This is a conflict of interest because the
commissions give our associates a financial incentive to recommend and sell clients insurance
products. However, they attempt to mitigate any conflicts of interest to the best of their ability
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by always acting in the client’s best interests through their fiduciary duty. Additionally, the client
is informed that he or she always has the right to choose whether to act on the recommendation
and he or she has the right to purchase recommended insurance through any licensed insurance
agent.
We provide Biblically Responsible Investment (BRI) screening services for other firms, including
Q3 Asset Management (Q3). As such, we may screen stocks, ETFs, and mutual funds for them to
utilize in their BRI Strategies. This service generates a fee that is separate from the fees described
in Item 5 above. This additional compensation creates a conflict of interest because we may
recommend that certain clients utilize Q3 through a solicitor arrangement (Item 4) where we will
receive a portion of Q3’s management fee, in addition to the fee for screening investments. To
mitigate any conflicts of interest to the best of our ability, , for clients that we place with Q3, we
will not collect a fund screening fee. Additionally, the client is informed that he or she always
has the right to choose whether to act on the recommendation and he or she has the right to
utilize other third-party investment adviser services through any firm.
RECOMMENDATION OF THIRD PARTY INVESTMENT ADVISER
We recommend the services of third party investment advisers. This information can be found
under Items 4 and 5. We will ensure that the Third-Party Adviser is properly registered or exempt
from registration in the client’s state of residence prior to making any recommendation. We
receive a portion of the Third-Party Adviser’s management fee, which creates a financial
incentive to recommend Third Party Advisers that pay a higher percentage of the management
fee. We attempt to mitigate the conflict of interest to best of our ability by placing the client’s
interest ahead of our own, through our fiduciary duty and by following our Code of Ethics that
establishes ideals for ethical conduct.
Item 11 – Code of Ethics, Participation or Interest in Client Transaction and
Personal Trading
DESCRIPTION
Our Code of Ethics establishes ideals for ethical conduct based upon fundamental principles of
openness, integrity, honesty, and trust. We will provide a copy of our Code of Ethics to any client
or prospective client upon request.
Our Code of Ethics covers all supervised persons and it describes our high standard of business
conduct and fiduciary duty to our clients. The Code of Ethics includes, among other things,
provisions relating to the confidentiality of client information, a prohibition on insider trading, a
prohibition on rumor mongering, restrictions on the acceptance of significant gifts and the
reporting of certain gifts and business entertainment items, and personal securities trading
procedures. All supervised persons must acknowledge the terms of the Code of Ethics annually
or as amended.
MATERIAL INTEREST IN SECURITIES
We do not have a material interest in any securities.
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INVESTING IN OR RECOMMENDING THE SAME SECURITIES
Our owners and associates may buy or sell for their own accounts the same securities at or about
the same time that they recommend those securities to you or purchase them for client accounts.
A conflict of interest may exist because they can trade ahead of client trades. We mitigate any
conflicts of interest in two ways. First, our Code of Ethics requires employees to: 1) report
personal securities transactions on at least a quarterly basis, and 2) provide us with a detailed
summary of certain holdings (both initially upon commencement of employment and quarterly
thereafter) in which employees have direct or indirect beneficial interest. The reports are
reviewed to ensure that we do not trade ahead of your accounts. Second, we require your
transactions be placed ahead of our associates’ personal trades or our associates can place
personal trades as part of a block trade (Please see Item 12.B for details on our block trading
practices). The records of all associates’ personal and client trading activities are reviewed and
made available to regulators to review on the premises.
Item 12 – Brokerage Practices
RECOMMENDATION CRITERIA
When we recommend custodians, we seek brokerage firms who offer competitive commission
costs together with reliable services. We are not affiliated with a brokerage firm. Brokerage firm
does not supervise us, its agents or activities. A client’s choice of another broker-dealer is
acceptable if proven feasible. We recognize our fiduciary responsibility in negotiating brokerage
commissions, assuring best execution practices and assuring adequate
investment
availability/inventory on behalf of our clients. We do not receive compensation with respect to
executions of trades. In some instances, a client will incur a ticket charge for the sale and
purchase of securities.
NOTE: Clients may be able to obtain lower commissions and fees from other brokers/custodians,
and the value of products, research and services given to the applicant is not a factor in
determining the selection of broker/dealers or the reasonableness of their commissions.
RESEARCH AND SOFT DOLLARS
“Soft dollars” are defined as a form of payment investment firms can use to pay for goods and
services such as news subscriptions or research. When an investment firm gives its business to a
particular brokerage firm, the brokerage firm in return can agree to use some of its revenue to
pay for these types of services. We do not receive any soft dollars.
BROKERAGE FOR CLIENT REFERRALS
We do not receive client referrals or any other incentive from any brokerage firm or custodian.
TRADE AGGREGATION
We may aggregate transactions in equity and fixed income securities for a client with other clients
to improve the quality of execution. When transactions are so aggregated, the actual prices
applicable to the aggregated transactions will be averaged, and each client account will be
deemed to have purchased or sold its proportionate share of the securities involved at the
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average price obtained. We may determine not to aggregate transactions, for example, based
on the size of the trades, the number of client’s accounts, the timing of the trades, the liquidity
of the securities or the discretionary or non-discretionary nature of the trades. If we do not
aggregate orders, some clients purchasing securities around the same time may receive a less
favorable price than other clients. This means that the practice of not aggregating may cost
clients more money.
Item 13 – Review of Accounts
PERIODIC REVIEWS
We conduct a review of clients’ portfolio management account(s) at least quarterly and
determine if rebalancing is necessary. We will also attempt to meet with each client to review
their accounts on an annual basis either in person, by telephone, or by a zoom meeting.
OTHER REVIEWS
Additional reviews may also be triggered by events within client’s lives, as well a pertinent news
events, changes in federal and state regulatory or tax regimes, and overall economic events.
REPORTS
Comprehensive financial planning clients receive a written financial plan. Portfolio management
and the recommendation of third party adviser clients receive a written summary of accounts at
each meeting. Clients will also receive at least quarterly statements from the account’s custodian.
Item 14 – Client Referrals and Other Compensation
OTHER COMPENSATION
We do not receive extra compensation or any other economic benefit for providing investment
advice or other advisory services to clients.
CLIENT REFERRALS
We do not pay for client referrals or use solicitors.
Item 15 – Custody
All client funds, securities and accounts are held at a qualified custodian. We do not take
possession of a client’s securities. However, the client will be asked to authorize us with the ability
to instruct the custodian to deduct our management fee directly from the client’s account. This
authorization will apply to our management fee only. This is considered a limited form of custody.
The client will receive at least quarterly account statements from the qualified custodian that
holds the client’s assets. We urge each client to carefully review the account statements.
Item 16 – Investment Discretion
We offer our investment management services on a discretionary basis. The client will sign an
investment management agreement containing a limited power of attorney. The agreement
grants us discretion to select the time, amount and securities to be bought and sold in the client’s
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account. It also allows us to place the trades without the client’s prior approval. The client’s
custodian may request the client to sign the custodian’s limited power of attorney. This varies
with each custodian. We will discuss all limited powers of attorney prior to their execution. In all
cases, however, discretion is to be exercised in a manner consistent with the stated investment
objectives for the client’s account, and any other investment policies, limitation or restrictions.
Item 17 – Voting Client Securities
We will not be responsible for responding to proxies that are solicited with respect to annual or
special meetings of shareholders of securities held in clients’ accounts. Proxy solicitation
materials will be forwarded to clients directly from their accounts’ custodian for response and
voting. In the event a client has a question about a proxy solicitation, the client should contact
his/her investment adviser representative.
Item 18 – Financial Information
BALANCE SHEET
We do not require or solicit prepayment of more than $1,200 in fees per client, six months or
more in advance. Therefore, we are not required to provide a balance sheet.
FINANCIAL CONDITION
We are required in this Item to provide you with certain financial information or disclosures about
our financial condition if we have a financial commitment that impairs our ability to service you.
We do not have a financial commitment that impairs our ability to service our clients.
BANKRUPTCY
We have not been the subject of a bankruptcy proceeding.
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