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Item 1: Cover Page for Part 2A Appendix 1 of
Form ADV: Wrap Fee Program Brochure
February 2026
Diligent Investors, LLC
1447 Ford Street, Suite 200,
Redlands, CA 92374
(909) 792-2894
www.diligentinvestorsllc.com
Firm Contact:
Henk Fischer, Chief Compliance Officer
This wrap fee program brochure provides information about the qualifications and business
practices of Diligent Investors, LLC. If you have any questions about the contents of this brochure,
please contact by telephone at (909) 792-2894 or email at hfischer@diligentinvestorsllc.com. 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 Diligent Investors, LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov
Please note use of the term “registered investment adviser” and description of Diligent Investors, LLC
and/or our associates as “registered” does not imply a certain level of skill or training. You are
encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise
you for more information on the qualifications of our firm and its employees.
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Item 2: Material Changes to Part 2A Appendix 1 (Wrap Fee
Program Brochure) of Our Form ADV
Diligent Investors, LLC is required to advise you of any material changes to our Wrap Fee Program
Brochure (“Wrap Brochure”) from our last annual update, identify those changes on the cover page
of our Wrap Brochure or on the page immediately following the cover page, or in a separate
communication accompanying our Wrap Brochure.
Since our last annual amendment filed on 02/10/2025, we do not have any material change(s) to
disclose.
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Item 3: Table of Contents
Topic:
Page(s):
Item 1: Cover Page for Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure ......................... 1
Item 2: Material Changes to Part 2A Appendix 1 (Wrap Fee Program Brochure) of Our Form ADV ... 2
Item 3: Table of Contents ..................................................................................................................................................... 3
Item 4: Services, Fees & Compensation .......................................................................................................................... 4
Item 5: Account Requirements & Types of Clients .................................................................................................... 6
Item 6: Portfolio Manager Selection & Evaluation ..................................................................................................... 6
Item 7: Client Information Provided to Portfolio Manager(s) .............................................................................. 8
Item 8: Client Contact with Portfolio Manager(s) ...................................................................................................... 8
Item 9: Additional Information .......................................................................................................................................... 8
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Item 4: Services, Fees & Compensation
We offer wrap fee programs as described in this Wrap Fee Program Brochure. Our wrap fee accounts
are managed on an individualized basis according to the client’s investment objectives, financial
goals, risk tolerance, etc.
A wrap fee program allows our clients to pay a specified fee for investment advisory services. Our
firm pays for the execution of transactions. The advisory services may include portfolio management,
and the fee is not based directly upon transactions in your account. Fees for the execution of
transactions do not result in a higher advisory fee for you. However, you should be aware that we
may have an incentive to limit our trading activities in your account(s) because we are charged for
executed trades. By participating in a wrap fee program, you may end up paying more or less than
you would through a non-wrap fee program where a lower advisory fee is charged, but trade
execution costs are passed directly through to you by the executing broker.
Our recommended custodian, Charles Schwab & Co., Inc. (“Schwab”), does not charge transaction fees
for U.S. listed equities and exchange traded funds. Since we pay the transaction fees charged by the
custodian to clients participating in our wrap fee program, our firm’s expenses have decreased. This
presents a conflict of interest because we are incentivized to recommend equities and exchange
traded funds over other types of securities in order to reduce our costs.
Wrap Comprehensive Portfolio Management:
Our Wrap Comprehensive Portfolio Management service encompasses asset management as well as
providing financial planning/financial consulting to clients. It is designed to assist clients in meeting
their financial goals through the use of financial investments. We conduct at least one, but sometimes
more than one meeting (in person if possible, otherwise via telephone conference) with clients in order
to understand their current financial situation, existing resources, financial goals, and tolerance for risk.
Based on what we learn, we propose an investment approach to the client. We may propose an
investment portfolio, consisting of exchange traded funds, mutual funds, individual stocks or bonds, or
other securities. Upon the client’s agreement to the proposed investment plan, we work with the client
to establish or transfer investment accounts so that we can manage the client’s portfolio. Once the
relevant accounts are under our management, we review such accounts on a regular basis and at least
quarterly. We may periodically rebalance or adjust client accounts under our management. If the client
experiences any significant changes to his/her financial or personal circumstances, the client must notify
us so that we can consider such information in managing the client’s investments.
When applicable to client circumstances our investment approach may be implemented by enrolling
clients in a specific model portfolio. We currently use several models that line up our clients’ different
investment tolerances and time horizons.
Prior to enrolling a client in a model portfolio we work diligently to gain a holistic understanding of our
client’s financial resources and goals so we can design and implement strategies tailored to meet their
individual investment needs. To assist them in meeting those goals we provide our institutional
investment management process which consists of the following:
1. Develop and establish objectives and goals. After understanding financial goals and
objectives, we customize an Investment strategy to align client’s objectives with a customized
portfolio. Goals and objectives determine the details of the portfolio, including asset allocation,
performance expectations, risk characteristics, etc.
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2. Recommend Asset Allocation and Manager Selection – Based on client’s objectives, we give
specific asset allocation and manager recommendations designed to best meet their goals.
3. Implement – We implement our recommendations by selecting investments appropriate to
their risk tolerance. Our portfolios span multiple asset classes with very different risk
characteristics (conservative dividend stocks, more aggressive emerging markets equities, high
quality bonds, commodities, etc.). To understand the overall risk level of such diverse portfolios,
we build and deploy proprietary mathematical models based on historical risk characteristics of
the various asset classes within our portfolios. These models quantify both the relative risks of
these asset classes and the extent to which those risks tend to expand or offset one another.
4. Monitor and Review – We continually monitor the asset allocation strategies and the
performance of all selected mangers to confirm their continued merit in the portfolio. Further,
we review our client’s plan with them and make adjustments when necessary as we progress
steadily toward their goals year after year.
Fee Schedule:
Assets Under Management Annual Percentage of Assets Charge:
Up to $1,000,000
$1,000,001 to $5,000,000
Over $5,000,000
1.50%
1.00%
Negotiable
Our firm’s fees are billed on a pro-rata annualized basis quarterly in advance based on the value of your
account on the last day of the previous quarter. Adjustments are made for deposits and withdrawals. As
a courtesy to smaller accounts, we do not charge a fee to accounts whose fee calculation is less than
$50.00. Unless indicated otherwise in writing, our firm bills on cash. Fees will generally be
automatically deducted from your managed account. As part of this process, you understand and
acknowledge the following:
a) Your independent custodian sends statements at least quarterly to you showing all
disbursements for your account, including the amount of the advisory fees paid to us.
b) You provide authorization permitting us to be directly paid by these terms.
c) If we send a copy of our invoice to you, our invoice will include a disclosure urging you to
compare the information provided in our statements with those from the qualified custodian.
In some cases, we agree to directly bill clients (i.e. qualified plans).
When establishing the asset charge for a specific account, the investment advisor representative will
consider various factors which include the size of the account, trading frequency and transactions
cost imposed. There are instances when the advisor will assess a lower asset charge to offset the cost
of transaction charges or the selection of higher share classes which do not assess a transaction
charge. The goal being to establish a total cost that is equivalent or lower than the asset management
schedule above.
Other Types of Fees & Expenses:
You may pay custodial fees, charges imposed directly by a mutual fund, index fund, or exchange
traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other
fund expenses), mark-ups and mark-downs, spreads paid to market makers, wire transfer fees and
other fees and taxes on brokerage accounts and securities transactions. These fees are not included
within the wrap-fee you are charged by our firm.
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Termination and Refunds:
Either party may terminate the Wrap Comprehensive Portfolio Management service at any time by
providing written notice to the other party. Upon notice of termination, our firm will process a pro-
rata refund of any unearned portion of the advisory fees charged in advance.
Wrap Fee Program Recommendations:
Our investment advisory representatives receive a portion of the advisory fee that you pay us, either
directly as a percentage of your overall fee or as their salary from our firm. In cases where our
investment advisory representatives are paid a percentage of your overall advisory fee, this may
create an incentive to recommend that you participate in a wrap fee program rather than a non-wrap
fee program (where you would pay for trade execution costs) or brokerage account where
commissions are charged. This is because, in some cases, we may stand to earn more compensation
from advisory fees paid to us through a wrap fee program arrangement if your account is not actively
traded. Inasmuch as our firm will pay to Schwab, the transaction/execution costs associated with
equities transaction, a potential disincentive to trade securities may be presented.
Regulatory Assets Under Management:
Our firm managed $663,058,489 on a discretionary basis and $0 on a non-discretionary basis as of
December 31st, 2025.
Item 5: Account Requirements & Types of Clients
Types of clients we typically manage wrap fee accounts on behalf of, include:
•
Individuals and High Net Worth Individuals;
• Trusts, Estates or Charitable Organizations;
• Pension, Profit Sharing Plans, IRAs and other qualified plans; and
• Corporations, limited liability companies and/or other business types.
Our firm does not impose requirements for opening and maintaining accounts or otherwise engaging
us.
Item 6: Portfolio Manager Selection & Evaluation
Selection of Portfolio Managers:
Our firm utilizes our in-house portfolio managers as well as a selection of outside portfolio managers.
In-house accounts are managed by licensed investment adviser representatives (“IARs”) of our firm.
Prior to becoming licensed with our firm, each IARs industry experience, licensure, outside business
activities, client complaints (if any), disciplinary or regulatory history (if any) and financial well-
being will be reviewed. Each IAR will then have a Form U4 and ADV Part 2B on file with our firm.
Outside portfolio managers, either individually or firm-wide, are selected based on past performance,
investment philosophy, market outlook, experience of associated portfolio managers and executive
team, disciplinary, legal and regulatory histories of the firm and its associates, and/or whether
compliance procedures are in place to address at a minimum, insider trading, conflicts of interest,
and/or anti-money laundering.
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Performance returns of wrap portfolios are reviewed at least quarterly. The nature of these reviews
is to learn whether client accounts are in line with their investment objectives and appropriately
positioned based on market conditions. If these standards fall below the client objectives, our firm
will discuss the review with the portfolio manager for proactive action to realign the investment
strategy.
Advisory Business:
Please see Item 4 of this Wrap Fee Program Brochure for information about our wrap fee advisory
program. We offer individualized investment advice to clients utilizing our Wrap Comprehensive
Portfolio Management service. Each Wrap Comprehensive Portfolio Management client has the
opportunity to place reasonable restrictions on the types of investments to be held in the portfolio.
Restrictions on investments in certain securities or types of securities may not be possible due to the
level of difficulty this would entail in managing the account.
Participation in Wrap Fee Programs:
We only offer wrap fee accounts to our clients, which are managed on an individualized basis
according to the client’s investment objectives, financial goals, risk tolerance, etc. We do not manage
non-wrap fee accounts.
Performance-Based Fees and Side-By-Side Management:
We do not charge performance-based fees or side-by-side management fees to our clients.
Methods of Analysis, Investment Strategies and Risk of Loss:
Our firm will utilize fundamental analysis which examines earnings, dividends, new products,
research and the like. Our firm will make long term purchases (securities held at least a year), and
may make short term purchases (securities sold within a year). Investing in securities involves risk
of loss that clients should be prepared to bear. While the stock market may increase and your
account(s) could enjoy a gain, it is also possible that the stock market may decrease and your
account(s) could suffer a loss. It is important that you understand the risks associated with investing
in the stock market, are appropriately diversified in your investments, and ask us any questions you
may have.
Our firm has developed proprietary asset allocation models and investment strategies as part of our
investment process. The purpose of these models and strategies is to create a foundation for clients’
investment portfolios based on their individual risk tolerance, investment timeframe, and specific
investment goals. Our proprietary models provide recommended percentage allocation ranges to
specific asset classes based on risk tolerance. Our risk tolerance models typically range from growth
to conservative. Our firm then tailors our investment models to fit clients’ individual investment
needs and goals. The risks associated with our proprietary models reflect risks similar to that of asset
allocation strategies. This includes that a client may not participate in sharp increases in a particular
security, industry or market sector. Another risk is that a client’s actual holdings may deviate from
the model over time and if not corrected, may no longer be appropriate for the client’s goals.
We generally invest client’s cash balances in money market funds, high-grade commercial paper
and/or short term bond funds.
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Ultimately, we try to achieve the highest return on our client’s cash balances through relatively low-
risk conservative investments. In most cases, at least a partial cash balance will be maintained in a
money market account so that our firm may debit advisory fees for our services related to
comprehensive portfolio management service.
Voting Client Securities:
Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or
other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent
to our firm, our firm will forward them to the appropriate client and ask the party who sent them to
mail them directly to the client in the future. Clients may call, write or email us to discuss questions
they may have about particular proxy votes or other solicitations.
Item 7: Client Information Provided to Portfolio Manager(s)
We are required to describe the information about you that we communicate to your portfolio
manager(s), and how often or under what circumstances we provide updated information. Our firm
communicates with your portfolio manager(s) on a regular basis as needed (daily, weekly, monthly,
etc) to ensure your most current investment goals and objectives are understood by your portfolio
manager(s). In most cases, we will communicate such information as part of our regular investment
management duties. Nevertheless, we will also communicate information to your portfolio
manager(s) when you ask us to, when market or economic conditions make it prudent to do so, etc.
Item 8: Client Contact with Portfolio Manager(s)
Clients are always free to directly contact their portfolio manager(s) with any questions or concerns
they have about their portfolios or other matters.
Item 9: Additional Information
Disciplinary Information:
We have determined that our firm and management have no disciplinary information to disclose.
Financial Industry Activities & Affiliations:
Representatives of our firm are registered representatives of M. S Howell & Co., member FINRA/SIPC,
and licensed insurance agents. As a result of these transactions, they receive normal and customary
commissions. A conflict of interest exists as these commissionable securities sales create an incentive
to recommend products based on the compensation earned. To mitigate this potential conflict, our
firm will act in the client’s best interest.
Custody:
The SEC issued a no‐action letter (“Letter”) with respect to the Rule 206(4)‐2 (“Custody Rule”) under
the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody
Rule as well as clarified that an adviser who has the power to disburse client funds to a third party
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under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, our firm has
adopted the following safeguards in conjunction with our custodian, Schwab:
• The client provides an instruction to the qualified custodian, in writing, that includes the
client’s signature, the third party’s name, and either the third party’s address or the third
party’s account number at a custodian to which the transfer should be directed.
• The client authorizes the investment adviser, in writing, either on the qualified custodian’s
form or separately, to direct transfers to the third party either on a specified schedule or from
time to time.
• The client’s qualified custodian performs appropriate verification of the instruction, such as
a signature review or other method to verify the client’s authorization, and provides a
transfer of funds notice to the client promptly after each transfer.
• The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
• The investment adviser has no authority or ability to designate or change the identity of the
third party, the address, or any other information about the third party contained in the
client’s instruction.
• The investment adviser maintains records showing that the third party is not a related party
of the investment adviser or located at the same address as the investment adviser.
• The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
Code of Ethics, Participation or Interest in Client Transactions & Personal Trading:
We recognize that the personal investment transactions of members and employees of our firm demand
the application of a high Code of Ethics and require that all such transactions be carried out in a way that
does not endanger the interest of any client. At the same time, we believe that if investment goals are
similar for clients and for members and employees of our firm, it is logical and even desirable that there
be common ownership of some securities.
Therefore, in order to prevent conflicts of interest, we have in place a set of procedures (including a pre-
clearing procedure) with respect to transactions effected by our members, officers and employees for
their personal accounts1. In order to monitor compliance with our personal trading policy, we have a
quarterly securities transaction reporting system for all of our associates.
Furthermore, our firm has established a Code of Ethics which applies to all of our associated persons. An
investment adviser is considered a fiduciary. As a fiduciary, it is an investment adviser’s responsibility
to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our
clients at all times. We have a fiduciary duty to all clients. Our fiduciary duty is considered the core
underlying principle for our Code of Ethics which also includes Insider Trading and Personal Securities
Transactions Policies and Procedures. We require all of our supervised persons to conduct business with
the highest level of ethical standards and to comply with all federal and state securities laws at all times.
Upon employment or affiliation and at least annually thereafter, all supervised persons will sign an
acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our
1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our
associate, his/her spouse, his/her minor children or other dependents residing in the same household, (b) for
which our associate is a trustee or executor, or (c) which our associate controls, including our client accounts which
our associate controls and/or a member of his/her household has a direct or indirect beneficial interest in.
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firm and supervised persons must conduct business in an honest, ethical, and fair manner and avoid all
circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients.
This disclosure is provided to give all clients a summary of our Code of Ethics. However, if a client or a
potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon
request.
Related persons of our firm may buy or sell securities and other investments that are also recommended
to clients. In order to minimize this conflict of interest, our related persons will place client interests
ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon
request.
Related persons of our firm may buy or sell securities for themselves at or about the same time they buy
or sell the same securities for client accounts. In order to minimize this conflict of interest, our related
persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a
copy of which is available upon request. Further.
Review of Accounts:
We review accounts on at least a quarterly basis for our clients subscribing to our Wrap
Comprehensive Portfolio Management service. The nature of these reviews is to learn whether
clients’ accounts are in line with their investment objectives, appropriately positioned based on
market conditions, and investment policies, if applicable. Only our Financial Advisors or Portfolio
Managers will conduct reviews.
We may review client accounts more frequently than described above. Among the factors which may
trigger an off-cycle review are major market or economic events, the client’s life events, requests by
the client, etc.
We provide quarterly performance reports to clients upon request. Verbal reports to clients take
place on at least an annual basis when we meet with clients who subscribe to our firm’s Wrap
Comprehensive Portfolio Management service.
Client Referrals & Other Compensation:
Charles Schwab & Co., Inc.
Our firm has an arrangement with Schwab. Schwab offers to independent investment Advisers
services which include custody of securities, trade execution, clearance and settlement of
transactions. We receive some benefits from Schwab through our participation in the program.
However, our firm is independently owned and operated and not affiliated with Schwab. Our firm
may also recommend that clients establish accounts with firms other than Schwab.
Our firm places trades for its clients' accounts subject to its duty to seek best execution and its other
fiduciary duties. Our firm may use broker-dealers other than Schwab to execute trades for client
accounts maintained at Schwab, but this practice may result in additional costs to clients so that we
are more likely to place trades through Schwab rather than other broker-dealers. Schwab's execution
quality may be different than other broker-dealers.
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For our client accounts maintained in its custody, Schwab generally does not charge separately for
custody services but is compensated by account holders through commissions or other transaction-
related or asset-based fees for securities trades that are executed through Schwab or that settle into
Schwab accounts.
Some of the products, services and other benefits provided by Schwab benefit us and may not benefit
our firm's client accounts. Our recommendation/requirement that a client place assets in Schwab's
custody may be based in part on benefits Schwab provides to us, and not solely on the nature, cost or
quality of custody and execution services provided by Schwab.
Schwab also makes available to our firm other products and services that benefit us but may not
benefit clients’ accounts. These benefits may include national, regional or specific to our firm,
educational events organized and/or sponsored by Schwab Institutional. Schwab provided the firm
with a $50,000 soft dollar budget to be used for research, advertising, marketing, and record keeping
in 2016 which was exhausted during 2017. Other potential benefits may include occasional business
entertainment of personnel of our firm by Schwab Institutional personnel, including meals,
invitations to sporting events, including golf tournaments, and other forms of entertainment, some
of which may accompany educational opportunities. Other of these products and services assist us in
managing and administering clients’ accounts. These include software and other technology (and
related technological training) that provide access to client account data (such as trade confirmations
and account statements), facilitate trade execution (and allocation of aggregated trade orders for
multiple client accounts), provide research, pricing information and other market data, facilitate
payment of our fees from its clients’ accounts, and assist with back-office training and support
functions, recordkeeping and client reporting. Many of these services generally may be used to
service all or some substantial number of our firm’s accounts, including accounts not maintained at
Schwab Institutional. Schwab Institutional also makes available to us other services intended to help
our firm manage and further develop its business enterprise.
These services may include professional compliance, legal and business consulting, publications and
conferences on practice management, information technology, business succession, regulatory
compliance, employee benefits providers, human capital consultants, insurance and marketing. In
addition, Schwab may make available, arrange and/or pay vendors for these types of services
rendered to our firm by independent third parties. Schwab Institutional may discount or waive fees
it would otherwise charge for some of these services or pay all or a part of the fees of a third-party
providing these services to us. While, as a fiduciary, our firm endeavors to act in our clients’ best
interests, our recommendation/requirement that clients maintain their assets in accounts at Schwab
may be based in part on the benefit to our firm of the availability of some of the foregoing products
and services and other arrangements and not solely on the nature, cost or quality of custody and
brokerage services provided by Schwab, which may create a potential conflict of interest.
As a result of receiving such products and services for no cost, we may have an incentive to continue
to place client trades through broker-dealers that offer the aforementioned products and services.
This may present a conflict of interest with our duty to achieve best execution of client transactions.
From time-to-time our firm may make an error in submitting a trade order on a client’s behalf. When
this occurs, we may place a correcting trade with the broker-dealer which has custody of the client’s
account. If an investment gain results from the correcting trade, the gain will remain in the client’s
account unless the same error involved other client account(s) that should have received the gain, it
is not permissible for the client to retain the gain, or our firm confers with the client and the client
decides to forego the gain (e.g., due to tax reasons). If the gain does not remain in the client’s account
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and Schwab is the custodian, Schwab will donate the amount of any gain $100 and over to charity. If
a loss occurs greater than $100, we will pay for the loss. Schwab will maintain the loss or gain (if such
gain is not retained in the client’s account) if it is under $100 to minimize and offset its administrative
time and expense. Generally, if related trade errors result in both gains and losses in the client’s
account, they may be netted.
Client Referrals:
In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not provide
cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or
endorsements (which include client referrals).
Financial Information:
Our firm is not required to provide financial information in this Brochure because:
• Our firm does not require the prepayment of more than $1,200 in fees when services cannot
be rendered within 6 months.
• Our firm does not take custody of client funds or securities.
• Our firm does not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
Our firm has never been the subject of a bankruptcy proceeding.
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