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Item 1 – Cover Page
Form ADV Part 2A Brochure
February 05, 2026
This Brochure provides information about the qualifications and business practices of FourPath Capital
Management, LLC. You should review this brochure to understand your relationship with our firm and
help you determine to hire or retain us as your investment adviser. If you have any questions about the
contents of this brochure, please contact us at (405) 253-6080. The information in this Brochure has not
been approved or verified by the United States of America Securities and Exchange Commission (“SEC”)
or by any state securities authority.
Additional information about FourPath Capital Management, LLC is also available on the SEC’s website
at www.adviserinfo.sec.gov. You can search this site by our firm name or by using a unique identifying
number, known as a CRD number. The CRD number for FourPath Capital Management, LLC is 313573.
FourPath Capital Management, LLC is a registered investment adviser. Registration of an investment
adviser does not imply any level of skill or training.
4727 Gaillardia Parkway, Suite 120, Oklahoma City, OK 73142
(405) 253-6080
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Item 2 – Material Changes
This item of the Brochure will discuss only specific material changes that are made to the Brochure since
the last annual update and provide clients with a summary of such changes.
In this update, we elaborated upon fee payment practices and our fee schedule in Item 5.
Additionally, we added our practices for alternative investments to the details of our advisory business in
Item 4.
Additionally, please note that we have updated the Assets Under Management information of Item 4 in
accordance with the filing of our Annual Updating Amendment on February 05, 2026.
We will provide you with a Summary of Material Changes made to this brochure annually at no cost. You
may receive an updated copy of this brochure at any time by contacting us at 405-253-6080.
(Brochure Date: 02/05/2026)
(Date of Most Recent Annual Updating Amendment: 02/05/2026)
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Item 3 – Table of Contents
Item 1 – Cover Page ............................................................................................................................................................... 1
Item 2 – Material Changes ....................................................................................................................................................... 2
Item 3 – Table of Contents ...................................................................................................................................................... 3
Item 4 – Advisory Business ...................................................................................................................................................... 4
Item 5 – Fees and Compensation ............................................................................................................................................ 9
Item 6 – Performance-Based Fees and Side-By-Side Management ...................................................................................... 13
Item 7 – Types of Clients ....................................................................................................................................................... 13
Item 8 – Methods of Analysis, Investment Strategies ............................................................................................................ 13
Item 9 – Disciplinary Information ........................................................................................................................................... 17
Item 10 – Other Financial Industry Activities and Affiliations ................................................................................................ 17
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading ........................................................... 17
Item 12 – Brokerage Practices ............................................................................................................................................... 19
Item 13 – Review of Accounts ............................................................................................................................................... 21
Item 14 – Client Referrals and Other Compensation ............................................................................................................ 21
Item 15 – Custody ................................................................................................................................................................. 22
Item 16 – Investment Discretion ........................................................................................................................................... 23
Item 17 – Voting Client Securities ......................................................................................................................................... 23
Item 18 – Financial Information ............................................................................................................................................. 23
Brochure Supplements (Provided to Clients)
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Item 4 – Advisory Business
About Our Firm
FourPath Capital Management, LLC (“FourPath”) is a registered investment adviser that provides
investment management and financial advisory services to individual and institutional investors to help
them achieve their financial needs and goals. Prior to February 2024, we operated under the name
Reuter James Wealth Management, LLC. Between February 2024 and January 2025, we operated under
the name Prospera Private Wealth, LLC. FourPath is solely owned by Kyle Reuter and Jeffrey James and
has been a registered investment adviser since 2021.
Our firm takes pride in providing personalized service to our clients and acknowledges that it is held to a
fiduciary standard of care.
Types of Advisory Services We Offer
FourPath offers a variety of advisory services to individuals, high net worth individuals, foundations,
businesses, and corporations. These services include:
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Investment and wealth management
• Selection of Independent Managers
• Financial planning and consulting
• Fiduciary and non-fiduciary services for plan sponsors
We work with our clients to determine their investment objectives and risk profile and develop a
customized investment plan based on their individual needs and goals. FourPath will utilize the financial
information provided by the client to analyze and develop strategies and solutions to assist the client in
meeting their financial goals.
Prior to FourPath rendering any of the foregoing services, clients are required to enter into one or more
written advisory agreements with FourPath setting forth the relevant terms and conditions of the advisory
relationship.
Investment and Wealth Management Services
FourPath manages our clients’ portfolios on a discretionary and non-discretionary basis. Our investment
and wealth management services are tailored to the needs of our clients and are based on a
comprehensive understanding of each client’s current situation, past experiences, and future goals.
With this acquired knowledge we create, analyze, strategize, and implement goal-oriented investment
solutions. These solutions become our clients’ investment policy. This policy and our matched
strategies are designed to be risk appropriate, cost effective and tax efficient.
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Our wealth management services generally include a broad range of comprehensive financial planning
and/or consulting services, as well as discretionary and non-discretionary management of investment
portfolios.
Client assets are primarily allocated among individual equity and debt securities, mutual funds and
exchange-traded funds ("ETFs") in accordance with the client's stated investment objective and
risk/volatility parameters. We may also recommend clients allocate a certain portion of their assets to
independent investment managers ("Independent Managers"). Where appropriate, FourPath may also
provide advice about many types of legacy positions or other investments held in client portfolios.
Clients may also engage FourPath to manage and/or advise on certain investment products that are not
maintained at their primary custodian, such as variable life insurance and annuity contracts and assets
held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these
situations, FourPath will direct or make recommendations on a non-discretionary basis for the
allocation of client assets among the various investment options available with the product. These
assets are generally maintained at the underwriting insurance company or custodian for the plan trustee
or administrator and clients retain responsibility for effecting trades in these accounts.
FourPath consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time
horizon, liquidity constraints and other related factors relevant to the management of their portfolios.
You should promptly notify us if there are changes in your financial situation or if you wish to place any
limitations on the management of your account. You may impose reasonable restrictions or mandates
on the management of your account if FourPath determines, in our sole discretion, the conditions would
not materially impact the performance of a management strategy or prove overly burdensome to the
firm's management efforts.
To the extent a client’s assets are managed by an Independent Manager or are invested in a particular
fund, those managers and funds will have their own investment practices. Those investment practices
are described in each manager’s Form ADV or fund’s prospectus, or in its offering or other disclosure
documents. In addition, selected money managers or funds typically have discretion to determine the
type, and amount, of securities to be purchased or sold for the portion of the assets managed by the
money manager or fund.
Selection of Independent Managers
FourPath may select certain Independent Managers to actively manage all or a portion of its clients'
assets. Pursuant to the terms of the investment advisory agreement, FourPath shall have the discretion
to appoint and terminate these third-party advisers. The specific terms and conditions under which a
client engages an Independent Manager may also be set forth in a separate written agreement with the
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designated Independent Manager. In addition to this brochure, clients will also receive the written
disclosure documents of the respective Independent Managers engaged to manage their assets.
FourPath evaluates a variety of information about Independent Managers, which may include the
Independent Managers' public disclosure documents, materials supplied by the Independent Managers
themselves and other third-party analyses it believes are reputable. To the extent possible, FourPath
seeks to assess the Independent Managers' investment strategies, past performance, and risk results in
relation to its clients' individual portfolio allocations and risk exposure. FourPath also takes into
consideration each Independent Manager's management style, returns, reputation, financial strength,
reporting, pricing, and research capabilities, among other factors. When utilizing Wells Fargo &
Company as the Independent Manager or managers available through a program offered by Wells Fargo
Advisors, portfolio services can be provided via a Customized Portfolio Program (separately managed
account), personalized Unified Managed Account Program, Private Advisor Network or the FundSource
Program.
FourPath continues to provide services relative to the discretionary or non-discretionary selection of the
Independent Managers. On an ongoing basis, FourPath monitors the performance of those accounts
being managed by Independent Managers. FourPath seeks to ensure the Independent Managers'
strategies and target allocations remain aligned with clients' investment objectives and overall best
interests.
Financial Planning and Consulting Services
FourPath offers different levels of financial planning and consulting services to help our clients identify,
prioritize and work towards their goals and objectives. Our consulting services give our clients the ability
to receive a broad range of financial advice and services, including specific security recommendations,
for the duration of the advisory agreement.
Our process starts with an extensive review of a client's family situation, which includes assets and
liabilities as well as estate, tax, and insurance needs. We then employ a risk tolerance and risk capacity-
focused simulation to get a detailed cash flow analysis and proposed asset allocation. Together, this
information is analyzed to develop a proposed financial plan, which is designed to be dynamic in nature,
ever-evolving due to life changes, along with changes in cash flow needs, risk tolerance, time horizon, or
investment objectives.
FourPath’s financial planning and consulting services may include any of the following topics:
• Charitable Giving
• Cash Flow Analysis
• Education Planning
• Financial Record Organizing
• Business Planning
• Estate Planning
• Concentrated Stock
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• Federal Benefits & Health Care
• Tax Planning
Insurance Review
• Death & Disability
•
• Divorce Planning
• Family Governance
• Liability Management
• Retirement Plan Consulting and Employee
Benefits Analysis
Investment Consulting
•
While each of these services is available on a stand-alone basis, certain services may also be rendered
in conjunction with investment portfolio management services as part of a comprehensive wealth
management engagement. In performing these services, FourPath is not required to verify any
information received from the client or from the client's other professionals (e.g., attorneys,
accountants, etc.), and is expressly authorized to rely on such information. FourPath may recommend
clients engage the firm for additional related services, or we may recommend other professionals to
implement our recommendations. These additional services by FourPath or another professional are
provided at an additional cost to you, which is based on the nature, extent, complexity, and other
characteristics of the services. This creates a conflict of interest because we will have an incentive to
recommend additional services based on the compensation to be received, rather than solely based on
your needs, and in some cases, based on the prospect of cross-referrals of advisory clients from the
other professional or his or her firm. Implementation of financial planning recommendations is entirely
at your discretion. You have complete freedom in selecting a financial adviser to assist you with
implementing the recommendations made in your financial plan and are under no obligation to act on
the advice of FourPath. Financial planning recommendations are of a generic nature and are not limited
to any specific product or service offered by a broker dealer or insurance company. Should you choose
to implement the recommendations contained in the plan, FourPath suggests you work closely with your
attorney, accountant and/or insurance agent.
FourPath will act solely in our capacity as a registered investment adviser and does not provide any legal,
accounting or tax advice. You should seek the counsel of a qualified accountant and/or attorney when
necessary. As part of our advisory services, we may assist clients with tax loss harvesting and will work
with the client’s tax specialist to answer any questions related to the client’s portfolio.
Alternative Investments
For certain qualified clients, FourPath can recommend third-party private fund vehicles. FourPath will
research, source and monitor alternative investments such as private equity, venture capital and hedge
fund vehicles to present for consideration to qualified clients. FourPath will assist clients in
implementing any recommendations made, including assisting with completing the relevant
subscription documents, however client shall be required to execute all relevant documentation.
Fiduciary and Non-Fiduciary Services for Plan Sponsors
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Retirement plan sponsors may retain our firm to provide advisory and consulting services for plan assets.
Fiduciary services available to plan sponsors include:
• Reviewing and assisting in the establishment of investment policies and objectives on behalf of
the plan
• Assistance with development of an Investment Policy Statement
• Recommending core investments to be offered to plan participants for selection by the plan
sponsor
• Recommending investment managers, within the meaning of ERISA Section 3(38), on behalf of the
plan, to be offered as investment options for plan participants
• Monitoring of the plan’s investments or investment managers in accordance with the plan’s
Investment Policy Statement or other relevant guidelines
Non-fiduciary consulting services available to plan sponsors include:
• Educating plan participants on investment options available within the plan
• Preparation of periodic performance reports for the plan’s investments
• Assistance with monitoring the reasonableness of the fees and expenses of the plan’s
investments or investment managers in accordance with the plan’s Investment Policy Statement
or other relevant guidelines
• Benchmarking existing plan service providers to industry peers, and where appropriate,
conducting a search for new providers for the plan sponsor’s consideration and providing our
recommendation.
Portfolio Management Services for Wrap Fee Program
FourPath offers portfolio management services through a wrap fee program. A bundled or “wrap fee”
program is an advisory fee program under which you pay one bundled fee to compensate FourPath for
portfolio management and trade execution. A wrap fee program may not be the lowest cost option if you
would like to restrict your investments to open-end mutual funds or other long-term investment
products.
Amount of Assets We Manage
As of December 31, 2026, FourPath manages approximately $758,562,923 on a discretionary basis and
$300,099,448 on a non-discretionary basis for a total of $1,058,662,371 of assets under management.
Discretionary assets under management are those for which we have an ongoing responsibility to select
and make securities recommendations that are in line with your financial needs and objectives and then
effect those securities transactions without first consulting you. Non-discretionary assets under
management are those for which we have an ongoing responsibility to select and make securities
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recommendations that are in line with your financial needs and objectives and then effect those
securities transactions only after consulting with you to inform you of the transaction(s) and obtaining
your approval to move forward.
Item 5 – Fees and Compensation
How We Are Compensated for Our Advisory Services
FourPath offers our advisory services on a fee-only basis. Our fees vary among the different types of
advisory services we offer and may be negotiated at our sole discretion. The specific fees and manner in
which fees are charged and calculated are described in your investment advisory agreement. You should
carefully review the investment advisory agreement prior to signing it.
Fees for our advisory services may be higher than fees charged by other advisers who offer similar
services. You may be charged different fees than similarly situated clients for the same services. You
should carefully review this brochure to understand the fees and other sources of compensation that
exist among our services prior to entering into an investment advisory contract with our firm.
Investment and Wealth Management Services
FourPath offers investment and wealth management services for an annual fee based on the amount of
assets under the firm’s management. Fees are generally billed in advance each calendar quarter based
on the market value of the assets under management/advisement on the last day of the previous
calendar quarter.
Our fees for investment management services are set forth in our investment advisory agreement with
the client. Our fees are generally based on a percentage of the client’s assets under management with
FourPath, generally as much as 1.25%; are negotiable, will vary from client to client, and are based on a
number of factors, such as the client’s assets under FourPath’s management, scope of services to be
provided, origins of the client relationship, and potential future revenues from the client relationship.
Advisory fees shall apply to cash balances, accrued interest, accrued dividends, and the value of
securities held on margin unless negotiated or agreed upon otherwise. FourPath will charge a minimum
of 0.10% for assets under management.
These fees may be based on cumulative household assets under management. However, certain ERISA
rules prevent householding corporate plans with personal assets for fee reductions. Existing clients will
be grandfathered and charged according to their existing fee rate and may pay a higher fee than laid out
above. You should refer to your advisory agreement for your specific fee rate(s).
FourPath, in our sole discretion, may waive the annual fee based upon certain criteria, including, but not
limited to, anticipated future earning capacity and/or additional assets, dollar amount of assets to be
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managed, related accounts, account composition, pre-existing client relationships, account retention,
and pro bono activities. For investment and wealth management services FourPath provides to certain
clients or for specific client holdings (e.g., held-away assets, 529 plans, etc.), we may negotiate a fee rate
that differs from our standard fee schedule.
Programs Offered Through Wells Fargo Advisors
Fees for advisory programs offered through Wells Fargo Advisors are inclusive of FourPath’s and Wells
Fargo Advisors’ advisory fees and are as follows:
Program
Program Type
Maximum Annual Advisory
Fee
Private Advisor Network
Separately Managed Account $0 - $1,000,000: 2.00%
Next $1,500,000: 1.75%
Next $2,500,000: 1.50%
Above $5,000,000: 1.25%
2%
Unified Managed Account
Personalized Unified Managed
Account
FundSource®
1.5%
Mutual Fund Advisory
Program
Wells Fargo Advisors will calculate and directly debit advisory fees from the clients’ accounts for assets
within their programs. The value of assets held in any Wells Fargo Advisor program are excluded from the
amount of total household assets used to determine FourPath’s advisory fees for other assets of a client
that are managed by FourPath.
Selection of Other Independent Managers
Fees for other Independent Managers used to manage all or a portion of a client’s account are set forth
by the Independent Manager and are in addition to FourPath’s fees. You should refer to the Independent
Manager’s investment management agreement and Form ADV Part 2A Brochure for information on their
fees and compensation.
Financial Planning and Consulting Services
Fees for financial planning and/or consulting services are billed on a fixed rate in advance. There is no
minimum fee required for financial planning or consulting services; however financial planning and
consulting fees shall generally not exceed $20,000 annually. Fees are due and payable as incurred.
Factors we consider when determining our financial planning and consulting fees include, but are not
limited to:
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• The amount of time we expect to spend completing the financial planning or consulting services
and providing related advice;
• The complexity of your goals, issues and/or needs;
• The extensiveness and complexity of the data needed regarding your personal financial
information;
• Your net worth or the value of your investment accounts and/or other assets that are the subject
of the financial planning or consulting services; and/or
• Special circumstances related to life changes, marital status, health or special income needs, or
growth or decline of a personal business.
FourPath may request a retainer to initiate financial planning and consulting services; however, we will
not request the prepayment of fees more than $1,200 in advisory fees more than six months in advance.
You may engage FourPath for additional investment management services to assist with implementing
one or more financial planning recommendations. You will incur additional fees if you retain our firm for
such services. You have complete freedom in selecting an investment adviser to assist you in
implementing any recommendations by FourPath and are under no obligation to act upon the advice we
provide.
For consulting services, the investment advisory agreement between FourPath and the client will
continue in effect until terminated by either party. For stand-alone financial planning services, the
agreement between FourPath and the client will terminate upon delivery of the plan or completion of the
service.
Fiduciary and Non-Fiduciary Services for Plan Sponsors
Fees for retirement plan sponsors are either set at a flat rate or based upon the value of the plan assets
that are the subject of the consulting services and are generally payable in arrears on a quarterly basis.
Fees for one-time projects are payable either upon completion of the project or half paid upon execution
of the agreement with the balance due upon completion of the project. A graduated fee schedule may be
set by the firm for fees based on the value of plan assets, which will be described in your services
agreement.
Payment of Fees
Clients authorize FourPath to instruct the account custodian to directly debit fees from the client’s
account. Accounts initiated or terminated during a calendar quarter will be charged a prorated fee.
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Fees for our advisory services generally require you to pay investment advisory fees in advance of
receiving services. If services are provided for less than a full calendar quarter or you withdraw or add
assets to your account, advisory fees will be prorated based on the number of days in the quarter
services were received or the assets were under FourPath’s management. For newly incepted
relationships, this prorated fee will be charged at the same as the first full quarter’s fee. For
terminations, any pre-paid, unearned fees will be promptly refunded.
• For investment and wealth management services, refunds are calculated by taking the total
advisory fee billed for the calendar quarter, dividing that amount by the number of days in the
calendar quarter and multiplying that amount by the number of days services were not provided
during the calendar quarter.
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If cash and/or securities are added or withdrawn between billing periods, a prorated fee
will be charged or refunded on the net value of the additions and/or withdrawals as of the
date of activity and will be based on the rate effective on that date. Fees will be assessed
or refunded in the following billing period if the net fee generates a fee or refund of at least
$10.
• For Independent Managers, the Independent Manager determines the manner in which advisory
fees are billed (in advance or arrears). You should refer to the manager’s Form ADV Part 2A
Brochure for additional information on how fees are paid for their services.
• For financial planning and consulting services, refunds are calculated based on the value of the
services that were completed prior to termination of the advisory agreement.
• Fees for fiduciary and non-fiduciary consulting services for plan sponsors are generally payable in
arrears. For one-time projects that are partly paid upon execution of the agreement, the amount
of the refund is calculated based on the value of the services that were completed. Any earned,
unpaid fees will be due and payable upon termination of the advisory contract.
Other Types of Fees and Expenses You May Incur
Clients may incur certain charges imposed by custodians, brokers, third-party investments and other
third parties, such as fees charged by Independent Managers, custodial fees, odd-lot differentials,
transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts
and securities transactions. Decisions to reallocate your account assets may result in you incurring a
redemption fee imposed by one or more mutual funds held in your account. 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 FourPath’s fee. FourPath shall not
receive any portion of these commissions, fees, and costs, including any distribution or “12b-1” fees
paid by the mutual funds in which your account assets are invested.
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Other Types of Compensation We Receive
FourPath has contracted with Trade-PMR, Inc. (“Trade-PMR”) for brokerage services, including trade
processing, collection of management fees, marketing assistance and research. Item 12 – Brokerage
Practices further describes the factors that FourPath considers in selecting or recommending broker-
dealers for client transactions and determining the reasonableness of their compensation (e.g.,
commissions).
Item 6 – Performance-Based Fees and Side-By-Side Management
FourPath does not charge any performance-based fees or participate in side-by-side management.
Item 7 – Types of Clients
FourPath provides portfolio management services to individuals, high net worth individuals and families,
pension and profit-sharing plans, trusts, estates, charitable institutions, foundations, corporations, and
other business entities.
FourPath generally requires a minimum initial investment of $1,000,000 for investment management
services. The firm, in its sole discretion, may accept clients with a lower initial investment based upon
each client’s particular circumstances.
Certain Independent Managers may impose more restrictive account requirements and varying billing
practices than FourPath. In such instances, FourPath may alter its corresponding account requirements
and/or billing practices to accommodate those of the Independent Managers.
Item 8 – Methods of Analysis, Investment Strategies
Methods of Analysis and Investment Strategies
FourPath carefully constructs a risk-adjusted, tax-efficient, and cost-effective asset allocation strategy
based on a client’s unique cash flow needs, stated return and risk profile. Security selection is based on
qualitative, quantitative, technical, and relative strength metrics. Portfolio holdings are constantly
monitored and adjusted as market conditions and our clients’ circumstances dictate. Clients may hold
or retain other types of assets as well and FourPath may offer advice regarding those various assets as
part of our services. Advice regarding such assets generally will not involve asset management services.
FourPath predominantly utilizes a combination of active and passive strategies to allocate client assets
primarily among publicly traded securities, such as stocks, bonds, ETFs, mutual funds, and/or
separately managed portfolios. Nevertheless, individual client circumstances may dictate the use of
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other types of securities, actively managed portfolios, or alternative investments. Depending upon the
client’s financial needs, strategies implemented might include long term purchases (securities held at
least a year), short term purchases (securities sold within a year), short sales, margin transactions,
option writing, including covered options, uncovered options or spreading strategies, and other
securities transactions.
Risk of Loss
Investing in securities involves risk of loss that you should be prepared to bear. All investments present
the risk of loss of principal – the risk that the value of securities (e.g., stocks, mutual funds, ETFs, bonds,
etc.), when sold or otherwise disposed of, may be less than the price paid for the securities. Even when
the value of the securities when sold is greater than the price paid, there is the risk that the appreciation
will be less than inflation. In other words, the purchasing power of the proceeds may be less than the
purchasing power of the original investment. There is no guarantee that investment recommendations
made by FourPath will be successful. We cannot assure that your account will increase, preserve
capital, or generate income, nor can we assure that your investment objectives will be realized. Although
all investments involve risk, our investment advice seeks to limit risk through diversification among
various asset classes.
We may recommend a variety of security types for your account in an effort to achieve your individual
needs and goals. This may include, but is not limited to, stocks, bonds, ETFs, open-end and closed-end
mutual funds, hedge funds, private equity funds, venture capital funds, advisory accounts, real estate
investment trusts, or other private alternative or other investment funds. An investment in such other
funds or managers may present risks specific to the particular investment vehicle, such as long-term
illiquidity, redemption notice periods or other restrictions on redemptions, capital calls, or periodic
taxable income distribution.
Described below are the material risks associated with investing in the types of securities we generally
use in client accounts:
Equity Securities
In general, prices of equity securities (common, convertible preferred stocks and other securities whose
values are tied to the price of stocks, such as rights, warrants and convertible debt securities) are more
volatile than those of fixed-income securities. The prices of equity securities could decline in value if the
issuer’s financial condition declines or in response to overall market and economic conditions.
Investments in smaller companies and mid-size companies may involve greater risk and price volatility
than investments in larger, more mature companies.
Fixed-Income Securities
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The return and principal value of bonds fluctuate with changes in market conditions. Fixed-income
securities are subject to interest rate risk and credit quality risk. The market value of fixed-income
securities generally declines when interest rates rise, and an issuer of fixed-income securities could
default on its payment obligations. Changes in interest rates generally have a greater effect on bonds
with longer maturities than on those with shorter maturities. If bonds are not held to maturity, they may
be worth more or less than their original value. Credit risk refers to the possibility that the issuer of a
bond will not be able to make principal and/or interest payments. High yield bonds, also known as “junk
bonds,” carry higher risk of loss of principal and income than higher rated investment grade bonds.
Exchange-Traded Funds (ETFs)
ETFs are typically investment companies that are legally classified as open-end mutual funds or unit
investment trusts. ETFs differ from traditional mutual funds in that ETF shares are listed on a securities
exchange. Shares can be bought and sold throughout the trading day like shares of other publicly traded
companies. ETF shares may trade at a discount or premium to their net asset value. This difference
between the bid price and ask price is often referred to as the “spread.” The spread varies over time
based on the ETF’s trading volume and market liquidity. It is generally lower if the ETF has high trading
volume and market liquidity and higher if the ETF has low trading volume and market liquidity. Liquidity
risks are higher for ETFs with a large spread. ETFs may be closed and liquidated at the discretion of the
issuing company.
Mutual Funds
Mutual funds may invest in different types of securities, such as value or growth stocks, real estate
investment trusts, corporate bonds, or U.S. government bonds. There are risks associated with each
asset class.
An investment in a money market fund is not insured or guaranteed by the Federal Deposit Insurance
Corporation or any other governmental agency. Although money market funds seek to preserve the value
of your investment at $1.00 per share, it is possible to lose money by investing in the fund. Redemption is
at the current net asset value, which may be more or less than the original cost. Aggressive growth funds
are most suitable for investors willing to accept price per share volatility since many companies that
demonstrate high growth potential can also be high risk. Income from tax-free mutual funds may be
subject to local, state and/or the alternative minimum tax.
Because each mutual fund owns different types of investments, performance will be affected by a variety
of factors. The value of your investment in a mutual fund will vary from day to day as the values of the
underlying investments in a fund vary. Such variations generally reflect changes in interest rates, market
conditions and other company and economic news. These risks may become magnified depending on
how much a fund invests or uses certain strategies. A fund’s principal market segment(s), such as large-
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cap, mid-cap or small-cap stocks, or growth or value stocks may underperform other market segments
or the equity markets as a whole.
You can find additional information regarding these risks in the fund’s prospectus.
International Investing
The risks of investing in foreign securities include loss of value as a result of political or economic
instability; nationalization, expropriation or confiscatory taxation; changes in foreign exchange rates and
foreign exchange restrictions; settlement delays; and limited government regulation (including less
stringent reporting, accounting, and disclosure standards than are required of U.S. companies). These
risks may be greater with investments in emerging markets. Certain investments utilized by the Firm may
also contain international securities.
Cash and Cash Equivalents
A portion of your assets may be invested in cash or cash equivalents to achieve your investment
objective, provide ongoing distributions, and/or take a defensive position. Cash holdings may result in a
loss of market exposure.
Alternative Investments
Alternative investments are illiquid investments and do not trade on a national securities exchange.
Alternative investments typically include investments in direct participation program securities
(partnerships, limited liability companies, business development companies or real estate investment
trusts), commodity pools, private equity, private debt, or hedge funds. Alternative investments are
subject to various risks, such as illiquidity and property devaluation based on adverse economic and/or
real estate market conditions.
Alternative investments are not suitable for all investors. Investors considering an investment strategy
utilizing alternative investments should understand that alternative investments are generally
considered speculative in nature and may involve a high degree of risk, particularly if concentrating
investments in one or few alternative investments. These risks are potentially greater and substantially
different than those associated with traditional equity or fixed income investments. Additional
information regarding these risks can be found in the product’s prospectus or offering documents.
Options
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Certain types of option trading may be permitted in your account in order to generate income or hedge a
security held in the account. There are additional risks with using options. An option holder runs the risk
of losing the entire amount paid for the option in a relatively short period of time. The risks of covered call
writing include the potential for the market to rise sharply, which may cause the security to be called
away and no longer be held in the account. The risk of buying long puts is limited to the loss of the
premium paid for the purchase of the put if the option is not exercised or otherwise sold. The writer of a
put option bears a risk of loss if the value of the underlying interest declines below the exercise price,
and such loss could be substantial if the decline is significant. The obligation of a writer of a put that is
not cash-secured to meet margin requirements creates additional risks. Combination transactions, such
as option spreads, are more complex than buying or writing a single option and carry additional risks.
You can find additional information regarding the risks associated with options trading on the Options
Industry Council website, www.optionseducation.org.
Item 9 – Disciplinary Information
As a registered investment adviser, FourPath is required to disclose all material facts regarding any legal
or disciplinary events that would be material to your evaluation of our firm or the integrity of our
management. FourPath has no disciplinary information to report.
Item 10 – Other Financial Industry Activities and Affiliations
FourPath has no other financial industry activities or affiliations.
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading
Our Code of Ethics
FourPath is committed to providing investment advice with the utmost professionalism and integrity. Our
firm strives to identify manage and/or mitigate conflicts of interest and has adopted policies,
procedures, and oversight mechanisms to address conflicts of interest. We have adopted a Code of
Ethics that emphasizes our fiduciary obligation to put client interests first and is designed to ensure
personal securities transactions, activities, and interests of employees will not interfere with the
responsibilities to make decisions in the best interest of clients. All supervised persons of our firm must
acknowledge and comply with our Code of Ethics.
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You may request a copy of our Code of Ethics by contacting us at 405-253-6080.
Participation in Client Transactions
FourPath does not affect principal or agency cross securities transactions for client accounts. FourPath
also does not cross trades between client accounts. Principal transactions are generally defined as
transactions where an adviser, acting as principal for its own account or the account of an affiliated
broker-dealer, buys from or sells a security to an advisory client. An agency cross transaction is defined
as a transaction where a person acts as an investment adviser in relation to a transaction in which the
investment adviser, or any person controlled by or under common control with the investment adviser,
acts as broker for both the advisory client and for another person on the other side of the transaction.
Agency cross transactions may arise where an adviser is dually registered as a broker-dealer or has an
affiliated broker-dealer.
Employee Personal Trading
Supervised persons of FourPath may purchase or sell the same security that we recommend for
investment in client accounts. This creates a conflict of interest as there is a possibility that employees
of our firm might benefit from market activity by a client in a security held by the employee. Our Code of
Ethics is designed to assure that the personal securities transactions, activities and interests of the
employees of FourPath will not interfere with making decisions in the best interest of advisory clients and
implementing such decisions while, at the same time, allowing employees to invest for their own
accounts. Under the Code of Ethics, certain classes of securities have been designated as exempt
transactions, based upon a determination that these would not materially interfere with the best interest
of FourPath’s clients. Our Code of Ethics also places restrictions on our employees’ personal trading
activities. These restrictions include, but are not limited to, a prohibition on trading based on non-public
information and pre-clearance requirements for certain types of transactions. Employee trading is
continually monitored under the Code of Ethics in an effort to prevent conflicts of interest between
FourPath and our clients.
Certain affiliated accounts may trade in the same securities with client accounts on an aggregated basis
when consistent with FourPath’s obligation of best execution. In such circumstances, the affiliated and
client accounts will share commission costs equally and receive securities at a total average price.
FourPath will retain records of the trade order (specifying each participating account) and its allocation,
which will be completed prior to the entry of the aggregated order. Completed orders will be allocated as
specified in the initial trade order. Partially filled orders will be allocated on a pro rata basis. Any
exceptions will be explained on the order.
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Item 12 – Brokerage Practices
Selection and Recommendation of Broker-Dealers
Though FourPath recommends brokers with which we have negotiated pricing on behalf of our clients,
we do not have discretionary authority to select brokers. We endeavor to recommend broker-dealers
that will provide the best services at the lowest commission rates possible. The reasonableness of
commissions is based on the broker's ability to provide professional services, competitive commission
rates, research and other services that will help our firm provide investment management services to
clients. FourPath may recommend brokers who provide useful research and securities transaction
services even though a lower commission may be charged by a broker who offers no research services
and minimal securities transaction assistance.
We have negotiated competitive pricing and services with Trade-PMR for brokerage back-office and trade
execution services and First Clearing for clearing and custodial services. First Clearing is a trade name
used by Wells Fargo Clearing Services, LLC., a non-bank affiliate of Wells Fargo & Company. Trade-PMR
and First Clearing are members of SIPC and are unaffiliated registered broker-dealers and FINRA
members. The brokerage commissions and/or transaction fees charged by Trade-PMR are included in
FourPath’s advisory fee. FourPath regularly reviews the reasonableness of the compensation received by
the broker-dealers used for executing client transactions in an effort to ensure that our clients receive
favorable execution consistent with our fiduciary duty. Factors which FourPath considers in
recommending Trade-PMR and First Clearing or any other broker-dealer to clients include, but is not
limited to, their respective financial strength, reputation, execution, pricing, research, and service. The
commissions and/or transaction fees charged by these brokers may be higher or lower than those
charged by other broker-dealers.
In addition, Trade-PMR provides FourPath with access to its institutional trading and custody services,
which are typically not available to retail investors. These brokerage services include the execution of
securities transactions, custody, research, and access to mutual funds and other investments that are
otherwise generally available only to institutional investors or would require a significantly higher
minimum initial investment. Other benefits we may receive include receipt of duplicate client
confirmations and bundled duplicate statements; access to a trading desk that exclusively services its
participants; access to block trading, which provides the ability to aggregate securities transactions and
then allocate the appropriate shares to client accounts; and access to an electronic communication
network for client order entry and account information.
The commissions paid by FourPath’s clients are intended to be consistent with our duty to obtain “best
execution.” However, a client may pay a commission that is higher than what another qualified broker-
dealer might charge to affect the same transaction when FourPath determines, in good faith, that the
commission is reasonable in relation to the value of the brokerage and research services received. In
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seeking best execution, the determinative factor is not the lowest possible cost, but whether the
transaction represents the best qualitative execution, taking into consideration the full range of a broker-
dealer’s services, including among others, execution capability, commission rates, and responsiveness.
Consistent with the foregoing, while FourPath will seek competitive rates, it may not necessarily obtain
the lowest possible commission rates for client transactions.
Independent Managers selected to manage clients' assets will generally also request the discretion to
select brokers and negotiate commissions on behalf of a client. FourPath will not have control over
trading execution by such managers. Clients should review the Form ADV disclosure documents of such
managers regarding their trading practices.
Research and Other Soft Dollar Benefits
FourPath does not participate in soft-dollar relationships.
Brokerage for Client Referrals
When selecting broker-dealers for the execution of client securities transactions, FourPath does not
consider whether we will receive any client referrals from the broker-dealer or any other third-party.
Directed Brokerage
As FourPath will not request the discretionary authority to determine the broker-dealer to be used or the
commission rates to be paid, clients must direct FourPath as to the broker-dealer to be used. The
commissions and transaction fees charged by these broker-dealers could be higher or lower than those
charged by other custodians and broker-dealers. When directing the use of a particular broker-dealer, it
should be understood that FourPath will not have authority to negotiate commissions among various
broker-dealers or obtain volume discounts. As such, best execution may not be achieved. Not all
investment advisers require clients to direct the use of specific broker-dealers
Aggregation of Orders
FourPath will generally block trades where possible and when advantageous to clients. Certain trades
will be effected independently. The blocking of trades permits the trading of aggregate blocks of
securities composed of assets from multiple client accounts where transaction costs are shared equally
and on a pro-rated basis between all accounts included in the block. Block trading allows us to execute
equity or fixed income trades in a timely, equitable manner and to reduce overall commission charges to
clients. Clients who do not provide FourPath with discretion will not participate in block trades, and their
trades in similar securities will be placed with brokers after trades for discretionary accounts. Accounts
owned by supervised persons of our firm may participate in block trading with your accounts; however,
these individuals will not be given preferential treatment of any kind.
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Item 13 – Review of Accounts
Accounts at FourPath are reviewed on a periodic basis by an Advisor at FourPath. This informal review
includes assessing client goals and objectives, monitoring the account, and addressing the need to
rebalance, as necessary. These reviews are conducted using data made available to FourPath by client
custodians and utilizing portfolio management software. Individual securities held in client accounts are
periodically monitored by the firm, while any selected third-party managers are monitored on a quarterly
basis. Accounts are reviewed in the context of each client’s stated investment objectives and guidelines.
More frequent reviews may be triggered by material changes to a client’s individual circumstances,
market conditions, or the political or economic environment.
FourPath may also review tax-planning needs, cash-flow needs, as well as charitable giving, insurance,
and estate planning as part of our ongoing client reviews. Reviews are tailored to the services we provide
to you, as well as your individual needs and goals. We encourage you to discuss your needs, goals, and
objectives with us and keep us informed of any changes. If you engage our firm for ongoing investment
advisory services, we will contact you at least annually to determine whether there have been any
changes to your financial situation or investment objectives and whether you wish to impose any
reasonable restrictions on the management of your account or reasonably modify any existing
restrictions. At this time, we will advise you of any account changes we feel are necessary to help you
stay on track with meeting your financial goals and consider whether the current services provided by our
firm continue to be suitable for your needs.
As a convenience to our clients, in addition to reporting on clients’ financial assets, at a client’s request
we may prepare a global consolidated report that also includes certain non-financial assets (e.g., real
assets). In such instances, FourPath relies on the client to provide current and accurate price or other
valuation information for those assets to be included in the client’s consolidated account report. In no
instance are non-financial assets included in any performance reporting. FourPath does not
independently verify, and expressly disclaims responsibility for, the accuracy of any non-financial asset
values clients provided to us to include in their reporting.
Item 14 – Client Referrals and Other Compensation
Other Compensation Arrangements
FourPath receives compensation from Trade-PMR, Inc., the broker-dealer used for your account, and
your account custodian in the form of access to electronic systems that assist us in the management of
client accounts, as well as research, software and other technology that provide access to client
account data (such as trade confirmations and account statements), pricing information and other
market data, facilitate trade execution (and allocation of aggregated trade orders for multiple client
accounts), and client reporting capabilities. Your account custodian also offers us discounts for
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products and services offered by vendors and third-party service providers, such as software and
technology solutions. These economic benefits create a conflict of interest in that it gives our firm an
incentive to recommend one broker-dealer or custodian over another that does not provide similar
electronic systems, support, or services. We address this conflict of interest by disclosing to our clients
the types of compensation that our firm receives so clients can consider this when evaluating our firm. It
is important that you consider the fees, level of service and investment strategies, among other factors,
when selecting an investment manager.
Client Referrals
FourPath does not pay any referral fees to other individuals for referring clients to our firm.
Item 15 – Custody
When you establish a relationship with our firm for investment management services, your assets will be
maintained by a bank, broker -dealer, mutual fund transfer agent or other such institution deemed a
‘qualified custodian’ by the SEC. We rely on the custodian to price and value assets, execute and clear
transactions, maintain custody of assets in your account and perform other custodial functions.
FourPath does not maintain physical possession of any client account assets. Clients’ assets must be
held by a bank, broker dealer, mutual fund transfer agent or other such institution deemed a qualified
custodian. We utilize First Clearing as the qualified custodian for client accounts.
FourPath is deemed to have custody, pursuant to Rule 206(4)-2 of the Investment Advisers Act of 1940,
as amended, due to its authority over certain accounts to distribute assets subject to a third-party
standing letter of authorization. The firm relies on the seven requirements outlined in the SEC’s No-
Action Letter to the Investment Advisers Association, dated February 21, 2017, which provides relief from
an annual surprise custody examination by an independent public accountant.
You will receive monthly and/or quarterly account statements directly from the qualified custodian.
FourPath may also provide you with written quarterly performance reports for your account upon your
request. We urge you to carefully review your account statements and compare the account balances
with the balances reflected on any performance report you may receive from our firm for accuracy.
Balances on our reports may vary slightly from custodial statements due to differences in accounting
procedures, reporting dates, valuation methodologies of certain securities or other operational factors.
You should promptly notify us if you do not receive account statements from your custodian at least
quarterly or if you believe the information on your account statements is inaccurate.
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Item 16 – Investment Discretion
FourPath typically has investment discretion over clients’ securities accounts. Investment discretion is
the authority to determine the securities or other assets to purchase or sell on behalf of an account.
Investment discretion may also include the authority to select or terminate a third-party asset manager.
This authority is exercised in a manner consistent with your stated investment objective for the particular
account. You must provide written authorization to our firm before we can assume discretionary
authority over your account. Any investment guidelines or restrictions you would like to place on your
account must be provided to FourPath in writing.
Item 17 – Voting Client Securities
As a general policy, FourPath will retain proxy voting authority for clients that have given us the authority
to do so. In such cases, we will follow the proxy voting guidelines outlined in our Proxy Voting Policies
and Procedures. You may obtain a copy of our Proxy Voting Policies and Procedures and/or a record of
ballots voted upon by contacting us at 405-253-6080. In certain situations, the Independent Manager
may be responsible for the voting of client proxies.
Clients may also elect to have us participate in class action lawsuits and related settlements on their
behalf. In such cases, we utilize a third-party service provider to assist the firm with the filing process,
who receives 20% of any settlement awarded to the client for their services.
Item 18 – Financial Information
As a registered investment adviser, FourPath is required to provide you with certain financial information
about our firm.
Prepayment of Fees
We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in
advance.
Our Financial Condition
We do not have any financial commitment that is reasonably likely to impair our contractual
commitments to our clients, nor has our firm ever been the subject of a bankruptcy proceeding.
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