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Form ADV Part 2A
Item 1
Brochure Cover Page
Grand Central Investment Group, LLC
324 S. Hyde Park Ave., Suite 390
Tampa, FL 33606
Phone: (813) 251-4200
www.grandcentralgroup.com
April 28, 2026
This brochure provides information about the qualifications and business practices of Grand
Central Investment Group, LLC. If you have any questions about the contents of this brochure,
please contact us at (813) 251-4200. 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. Registration does not imply a certain level of skill or training.
Additional information about Grand Central Investment Group, LLC is also available on the
SEC’s website at www.adviserinfo.sec.gov.
Item 2
Material Changes
Grand Central Investment Group, LLC (“Advisor”) has made the following material changes to its
Form ADV, Part 2A (“Brochure”) since it published its Brochure on March 13, 2025.
Item 4
Advisory Business
Second paragraph – previous version (03/13/2025)
The Firm was established in July 2014. Frank E. Cooper, III became the Advisor’s Chief Executive
Officer (“CEO”) in August 2014. The Advisor is solely owned by Frank E. Cooper, III.
Second paragraph – new version (11/05/2025)
The Firm was established in July 2014. The Advisor is solely owned by Charles E. Poe, the Advisor’s
Chief Investment Officer, who joined the Firm in November 2014.
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ADV 2A- 04/2026
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 ...................................................... 10
Item 7
Types of Clients ...................................................................................................................... 10
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss ................................................ 11
Item 9
Disciplinary Information ......................................................................................................... 13
Item 10
Other Financial Industry Activities and Affiliations ................................................................ 13
Item 11
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........... 13
Item 12
Brokerage Practices ................................................................................................................ 14
Item 13
Review of Accounts ................................................................................................................ 16
Item 14
Client Referrals and Other Compensation .............................................................................. 16
Item 15
Custody .................................................................................................................................. 17
Item 16
Investment Discretion ............................................................................................................ 17
Item 17
Voting Client Securities .......................................................................................................... 17
Item 18
Financial Information ............................................................................................................. 18
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ADV 2A- 04/2026
Item 4
Advisory Business
Grand Central Investment Group, LLC (the “Firm” or “Advisor”) is a limited liability corporation
formed under Florida law. The Advisor became a registered investment advisor in January 2015.1
The Firm was established in July 2014. The Advisor is solely owned by Charles E. Poe, the
Advisor’s Chief Executive Officer, who joined the Firm in November 2014.
Advisory services include separate account portfolio management, financial planning, and
consulting services. This Brochure provides information about the Advisor and its advisory
services.
limited partnerships, structured products, alternative
The Advisor provides advisory services for the following types of investments: equity securities,
warrants, options, debt securities, municipal bonds, real estate investment trusts (“REIT”),
mutual funds, closed end funds, exchange traded products (“ETP”), unit investment trusts,
private placements,
investments,
certificates of deposit (“CD”), and master limited partnerships (“MLP”). Advisory services are
tailored to an individual client’s needs.
The Advisor provides information in a separate disclosure brochure for its services offered
through the Grand Central Investment Group Wrap Program. The Grand Central Investment
Group Wrap Program services are similar to the portfolio management services described in this
Brochure, in that the Advisor provides customized investment advice and management to the
client. Under the Grand Central Investment Group Wrap Program, the Advisor exercises
discretion over the client’s account and the corresponding broker-dealer custodian’s execution
and transaction charges are included in the advisory fee the Advisor charges for its services. If a
client would like more information on the Grand Central Investment Group Wrap Program, the
client should contact their investment advisor representative (“IAR”) for a copy of the Grand
Central Investment Group Wrap Program Wrap Brochure that describes the program or go to
www.adviserinfo.sec.gov.
As of December 31, 2025, the Advisor managed approximately $165,924,407 in client assets on
a discretionary basis, and $30,314,492 on a non-discretionary basis.
1. Separate Account Portfolio Management
The Advisor provides ongoing investment advice and management of customized client
portfolios on a discretionary or non-discretionary basis according to each client’s investment
objective and financial situation.
1 Registration does not imply a certain level of skill or training.
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At our initial meeting with a prospective client, we discuss the client’s concerns, which then
leads to what they would like to accomplish, and finally the resources that they have to work
with through current liquid assets along with their ability to save annually.
From there, we begin to help the client better understand asset allocation and the resulting
potential volatility of the financial markets for each of our investment models. This helps us
identify where the client is the most comfortable on a risk scale to help accomplish the client’s
financial goals.
Portfolios typically include, but are not limited to, a variety of stock positions, ETPs, mutual funds,
and individual corporate or municipal bonds (based on the Advisor’s assessment of a client’s
personal finances and tax bracket). A client may impose restrictions by indicating any restrictions
in the Investment Advisory Agreement. A client may impose restrictions on specific industries or
securities that the client prefers not to invest. The Advisor will exercise its best efforts to adhere
to the client’s investment restrictions. Imposing restrictions may affect a client’s overall portfolio
performance in relation to other portfolios the Advisor may manage without such restrictions.
2. Financial Planning
The Advisor offers financial planning services. Financial planning services include areas such as
general cash flow planning, retirement planning, and insurance analysis.
The client retains the sole responsibility for determining whether to
implement any
recommendation made by the Advisor and for placing any resulting transaction. The Advisor
does not provide ongoing financial planning services and does not have discretionary
authority with respect to the client’s assets unless the client enters into a portfolio
management investment advisory agreement with the Advisor.
A conflict of interest may exist between the Advisor and the interests of the client if a
Financial Plan includes recommendations for products or services the Advisor provides. A client
is under no obligation to act upon the Advisor’s recommendation. If a client elects to act
on any of the Advisor’s recommendations, the client is under no obligation to effect the
transaction through the Advisor.
3. Consulting Services
The Advisor provides consulting services. The Firm’s advice takes into account information
collected from the client such as financial status, investment objectives, and tax status. The
Advisor will deliver to the client a written analysis or report as part of its services if requested in
the Investment Advisory Consulting Agreement. The Advisor tailors the consulting services to the
individual needs of the client based on the client’s investment objectives.
The Advisor does not have any discretionary investment authority when offering consulting
services. The Advisor will make recommendations as to general types of investment products or
securities that may be appropriate for a client to consider and may also provide
recommendations regarding specific investments or securities.
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For consulting services associated with retirement plans, the Advisor’s recommendations will be
limited to the investment options available within the client’s retirement plan. These investment
options may include brokerage windows or other similar plan arrangements that enable
participants to select investments beyond those designated by the client’s retirement plan (e.g.
investment trusts, pooled separate
mutual funds, exchange traded funds, collective
accounts, allocations among annuity sub-accounts, publicly traded employer stock (“company
stock”)). The Advisor does not provide any advice or recommendations regarding any
participant loans from a client’s retirement plan assets.
The client retains the sole responsibility for determining whether to
implement any
recommendations made by the Advisor and for authorizing any resulting transactions. The
Advisor does not have discretionary authority with respect to the client’s assets.
A conflict of interest may exist between the Advisor and the interests of the client if Consulting
Services include recommendations for products or services the Advisor provides. A client is under
no obligation to act upon the Advisor’s recommendation. If a client elects to act on any of the
Advisor’s recommendations, the client is under no obligation to effect the transaction through
the Advisor.
Item 5
Fees and Compensation
1. Separate Account Portfolio Management
Investment Advisory Fees
Investment advisory fees for portfolio management services are based on the value of assets
managed by the Advisor, calculated as a percentage of assets under management. This fee is
compensation for advisory services and portfolio management rendered by the Advisor.
Fees may be negotiated on a client-by-client basis depending on the client’s specific
financial needs as well as the size, complexity and nature of the portfolio managed and will be
set forth in the investment advisory agreement. Because the Advisor’s fees may be negotiated,
not all clients will pay the same fees.
A client may pay higher or lower fees depending on considerations such as the size of the client’s
account, the amount of time the client has maintained an account with the Advisor (or its
affiliated IAR), and/or the combined market value of related portfolios. While the Advisor believes
that its investment advisory fees are competitive, clients may find lower or higher fees for
comparable services from other sources.
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Maximum annual investment advisory fees for portfolio management are based on the
following tiered schedule that is based on asset levels:
Assets Under Management
First $250,000
Next $250,000
Next $500,000
Next $1,000,000
Next $3,000,000
Over $5,000,000
Maximum Annual Fee
2.00%
1.625%
1.50%
1.25%
1.00%
.75%
There is no minimum investment; however, the Advisor charges a minimum investment advisory
fee of $1,500 annually. If the account value falls below the minimum investment or is waived, the
client’s account will be subject to the minimum annual account fee, which will result in a higher
percentage fee than set forth in the advisory fee schedule above.
The amount of the investment advisory fee is set forth in the Investment Advisory Agreement
executed by the client at the time the relationship is established.
Investment advisory fees are charged quarterly in advance as a percentage of the portfolio value
on the last business day of the previous quarter or the last value provided by the custodian (if not
valued quarterly). These asset-based fees are assessed on all billable assets under management,
including securities, cash, and money market funds. The initial investment advisory fee will
be prorated based upon the number of days from the first day the Client’s assets are
in which the assets were
transferred to Custodian through the end of the quarter
transferred. Subsequently, investment advisory fees are charged and debited from a client’s
account within the first week of each calendar quarter.
The Advisor may make amendments to the investment advisory fee outlined in the Investment
Advisory Agreement at any time with at least 30 days written notice to the client.
Automatic Debiting of Investment Advisory Fees
Upon establishing an account with the Advisor, the client will authorize and direct the
client’s custodian broker-dealer to debit the client’s account for the investment advisory fee
payable from the account, which will result in the client’s custodian broker-dealer sending
the investment advisory fee payable directly to the Advisor.
At the beginning of the quarter, the Advisor will direct the client’s custodian broker-dealer to
debit the client’s designated account(s) the amount of the investment advisory fee.
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If the client’s account does not maintain a sufficient cash or money market balance to cover the
investment advisory fees or is restricted from automatic debiting of fees, the client may deposit
additional funds (subject to certain restrictions for IRA accounts and Qualified Retirement Plans)
or make payment in an alternative manner acceptable to the Advisor. If such funds are not
deposited, certain securities in the client’s account may be liquidated in an amount sufficient to
cover such debits.
Other Charges and Information
The Advisor’s investment advisory fees are separate from charges assessed by third parties, such
as broker-dealers, custodians, or mutual fund companies.
A client incurs brokerage and other transaction costs charged by broker-dealer(s) executing the
transactions and the custodians maintaining the client’s assets. These costs include, but are not
limited to, brokerage transaction and money movement costs, commissions, ticket charges, fed
fund wire fees, custodial fees, and margin interest. These costs are in addition to the Advisor’s
investment advisory fees and are not shared with the Advisor. For additional information, see
“Brokerage Practices” below.
Mutual funds charge an investment management fee, which is in addition to the investment
advisory fee a client pays to the Advisor. Generally, funds also assess administrative fees and
12b-1 fees. The Advisor does not receive any portion of these fees. These fees are in addition
to the investment advisory fees the Advisor charges. The client does not pay these fees directly;
rather, they are deducted from the mutual funds’ assets and will affect the performance
of the investments. These funds’ advisory, administrative, and 12b-1 fees are described in the
funds’ prospectuses. Mutual fund share prices and execution costs differ based on share
class. The Advisor will review the cost of a fund’s share classes in conjunction with execution
costs to assure that it meets its fiduciary duty to obtain best execution.
When investing in an ETP, e.g., exchange traded fund or exchange traded note, a client will bear
the ETP’s proportionate share of fees and expenses as an investor in the ETP. The client does not
pay these fees directly; rather they are deducted from the ETP’s assets and will affect the
performance of the investment.
The Advisor recommends that clients establish brokerage accounts with Trade-PMR, Inc., a FINRA-
registered broker-dealer, member SIPC, to maintain custody of their assets and to effect trades
for their accounts.
Choosing an alternate broker-dealer may result in additional expenses, fees, and lack of efficiency
in reporting account information because the Advisor has established a relationship with
this broker-dealer to facilitate certain additional services, which are outlined in the section
“Brokerage Practices” below. However, if the client does not use Trade-PMR, Inc., the Advisor
will reserve the right not to accept the account. For information about the factors the
Advisor considers
in selecting and/or recommending brokerage firms, see “Brokerage
Practices” below.
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The Advisory may assume the cost of expenses incurred from engaging an outside tax
preparation service on behalf of the client. This service is negotiable and will be set out in
the Investment Advisory Agreement. The Advisor does not pay for tax preparation services for all
clients.
Termination
A client has the right to terminate the Investment Advisory Agreement for investment advisory
services without penalty within five (5) business days after entering into an Investment
Advisory Agreement. Thereafter, the Investment Advisory Agreement will terminate upon the
Advisor’s receipt of the client’s verbal or written notice. The Advisor may cease providing
investment advisory services upon its written notice of termination of the Investment Advisory
Agreement to the client or upon the occurrence of certain events as described in the
Investment Advisory Agreement.
Upon the effective date of termination, the client will be refunded fees on a prorated share
based on the remaining days of the quarter that have been prepaid.
2. Financial Planning Fees
is no minimum asset requirement
The Advisor charges hourly or flat rate fees for its financial planning services. The hourly
charge for financial planning services is a maximum of $450 per hour and the flat rate fee is the
greater of $1,000 or .25% of assets advised on. Fees are negotiated on a client-by-client basis
depending on the size, complexity, and nature of the client’s portfolio and will be set forth in
the Financial Planning Agreement. There
for a
financial planning engagement. The Advisor will request the client to pay 50% of the
financial planning fee upon engagement. Upon presentation of a completed financial plan
to the client, the Advisor will present an invoice reflecting the remaining fees owed for
services.
Termination
A client has the right to terminate a Financial Planning Agreement without penalty within five (5)
business days after entering into the Agreement. Thereafter, the Agreement will terminate
upon the Advisor’s receipt of the client’s written notice. The Advisor may terminate
providing investment advisory services upon written notice of termination to the client or
upon the occurrence of certain events as described in the Financial Planning Agreement.
The Financial Planning Agreement automatically terminates, unless otherwise agreed in
writing, upon delivery of the financial plan. The Advisor will present the client with an
invoice for any services provided up to termination.
3. Consulting Fees
The Advisor charges a flat rate fee for its consulting services. The maximum fee for
consulting services is 1.00% of assets advised on.
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Fees are negotiated on a client-by-client basis depending on the size, complexity, and nature of
the client’s portfolio and will be set forth in the Consulting Agreement. There is no minimum asset
requirement for a consulting engagement. For consulting services, the client is required to pay at
the time of consultation with the Advisor.
Upon establishing an account with the Advisor, the client will authorize and direct the client’s
custodian broker-dealer to debit the client’s account for the consulting fee payable from the
account, which will result in the client’s custodian broker-dealer sending the investment advisory
fee payable directly to the Advisor. The fee for consulting services will be deducted from the
client’s brokerage account held with the custodian and will be reflected on the client’s custodian
statement.
Termination
A client has the right to terminate a Consulting Agreement without penalty within five (5) business
days after entering into the Agreement. Thereafter, the Agreement will terminate upon
the Advisor’s receipt of the client’s written notice. The Advisor may terminate providing
investment advisory services upon written notice of termination to the client or upon the
occurrence of certain events as described in the Consulting Agreement.
The Consulting Agreement automatically terminates, unless otherwise agreed in writing, upon
client’s termination of the agreement. The Advisor will deduct any fee due from the client’s
brokerage account for any services provided up to termination.
Item 6
Performance-Based Fees and Side by Side Management
Performance-Based Fees
The Advisor does not accept performance-based fees, which are fees based on a share of
capital gains or appreciation of the client’s assets.
Side-By-Side Management
Side-by-side management refers to the practice of managing accounts for which an advisor
charges performance-based fees while at the same time managing accounts that are not charged
performance-based fees.
The Advisor does not participate in side-by-side management.
Item 7
Types of Clients
The Advisor generally offers advisory services to individuals, high net worth individuals, pension
and profit-sharing plans, charitable organizations, and corporations or other businesses.
There is no minimum investment for Separate Account Portfolio Management; however, the
Advisor charges a minimum investment advisory fee of $1,500 annually.
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Item 8
Methods of Analysis, Investment Strategies and Risk of Loss
Generally, the Advisor is a “top-down manager” and will first determine the U.S. and Global asset
allocation between stocks, bonds, and cash. The Advisor uses a wide variety of investment
research and industry publications to assist in its analysis, which may include, but is not limited
to:
Jeff Cooper’s Hit & Run Trading
• Valueline Pro
•
• The Forest for the Trees
• Trading with Cody
• Wall Street Journal
• MarketSmith
• The Aden Forecast
Investech
• Barron’s
• Briefing.com
• Dorsey Wright
• Elliott Wave
• Fleckenstein Capital
• High Tech Strategist
•
• Momentum Structural Analysis (MSA)
• MoneyGuide Pro
Once the Advisor determines these allocations, we place in the client’s portfolio a foundation of
dividend paying equities (stocks) separated into two groups. One portion contains a basket of
stocks that the Advisor expects to continue to pay above-average dividends and the other portion
is comprised of a wide selection of the stock from companies that are historically increasing their
dividend payouts at a faster rate than an average sample of companies. The Advisor uses data
provided by Standard & Poor’s to analyze potential investments.
History shows that annual paid dividends remain a significant part of the total returns over
decades for investing in the equity markets, and the Advisor’s investment analysis is based on its
belief that this trend will continue. The Advisor follows the investment theory of James P.
O’Shaughnessy, who over many years has done extensive quantitative analysis dating back to the
1950’s. The Advisor believes that his findings are factual and unbiased on what investing
strategies actually have worked in the equity markets over the past five decades and are helpful
in our stock allocations.3
The Advisor’s initial method of analysis is fundamental analysis and includes a number of factors
based on Mr. O’Shaughnessy findings of potential indicators of significantly enhanced potential
returns. These include, but are not limited to, the following:
•
financial strength ratios;
• price to earnings ratios;
3 Mr. O’Shaughnessy is not affiliated with the Advisor.
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• price to sales ratios;
• price to cash flow rates;
• dividend growth history;
• dividend yields; and
• growth rate to price earnings ratios.
On the fundamental front, the Advisor also uses a service that screens for stocks that are owned
by more than one of a list of fifteen value managers (hedge fund managers and mutual
fund managers) that historically have above-average track records and low turnover of stocks
in their funds’ portfolios. We think it makes sense not to always have to reinvent the wheel and
to follow the smart money when looking for stock ideas.
The Advisor also believes that while fundamental analysis is important, the Advisor should not
ignore technical analysis both on individual stock positions, sectors and on the various domestic
and international indexes to help determine the overall health of the financial markets.
The Advisor believes there is a seasonal pattern in the equity markets which makes the Advisor
more wary from May through October because market drawdowns and corrections tend to occur
during this timeframe. In addition, the Advisor tends to use U.S. and global index-based
investments to populate this portion of clients’ portfolios on an annual basis.
The Advisor tends to be a stock picker but has come to appreciate the use of fixed income to
help cushion and mitigate the volatility inherit in the financial markets.
The Advisor may also use alternative investments in a client’s portfolio allocation to enhance
diversification. This includes investing in individual stocks, ETPs, closed end funds or institutional
mutual funds to gain exposure to companies that invest in real assets like precious metals, natural
resources, and real estate. We may also include institutional mutual funds or closed end funds
that use hedge fund strategies like long-short equity, long-short debt, covered call strategies,
and macro strategies.
The Advisor prefers to invest in companies that it believes can grow top line revenue,
are dominant in their field, have strong cash flows and balance sheets, and create high
barriers to their competitors for entry. The Advisor considers these types of companies ‘growth
stocks’ and, where appropriate, looks to add a portion of these companies to each client’s
portfolio to round out its custom allocations.
Because investment styles move in and out of favor over time, we strive to maintain a flexible
approach that uses multiple strategies. We like the idea of having more than one horse pulling
our investment portfolio wagon.
Clients are advised and should understand that:
Investing in securities involves risk of loss that clients should be prepared to bear.
•
• Asset allocation does not ensure a profit or protect against a loss.
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• Past performance is not a guarantee of future results.
• Market conditions, interest rates, and other investment-related risks may cause losses in
their portfolio.
• Risk parameters established for their portfolio are guidelines only – the selected risk
parameters may be exceeded, and index comparisons may outperform their portfolio.
• Portfolio values are subject to a variety of factors, such as liquidity and volatility of the
securities markets.
• There may be a higher level of risk with leveraged and inverse ETPs because, to accomplish
their objectives, they may pursue a range of investment strategies through the use of
swaps, futures contracts, and other derivative instruments in order to provide a return
that is a multiple of an underlying index or benchmark’s return. Most leveraged and
inverse ETFs “reset” daily, meaning that they are designed to achieve their stated
objectives on a daily basis. Their performance over longer periods of time can differ
significantly from the performance (or inverse of the performance) of their underlying
index or benchmark during the same period of time. This effect can be magnified in
volatile markets.
investments
including
limited
• Risks related to alternative investments may be greater than risks associated with
liquidity, tax considerations, potentially
traditional
speculative investment strategies, illiquidity, and potential for substantial losses including
entire investment.
Item 9
Disciplinary Information
Registered investment advisors are required to disclose specific information related to certain
legal or regulatory events that may be material to choosing an advisor. The Advisor has not been
the subject of any material legal or disciplinary proceedings. Please see Form ADV Part 2B
regarding disciplinary events involving the Advisor’s Covered Persons.
Item 10
Other Financial Industry Activities and Affiliations
None.
Item 11
Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
The Advisor has adopted a Code of Ethics (“Code”) pursuant to industry standards. The Code is
predicated upon serving the best interest of our clients. All persons covered under the Code
(“Covered Persons”) must at all times reflect the professional standards expected of those
engaged in the investment advisory business and shall act within the spirit and the letter of the
federal, state, and local laws and regulations pertaining to investment advisors and the general
conduct of business. These standards require all personnel to be judicious, accurate, objective,
and reasonable in dealing with both clients and other parties so that their personal integrity is
unquestionable.
The Code is certified annually with Covered Persons of the Firm. For a copy of the Code, a written
request should be sent to Grand Central Investment Group, Attention: T. Gregory Reymann II,
Chief Compliance Officer, 780 94th Avenue N., Suite 110, St. Petersburg, FL 33702.
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On occasion, the Advisor may buy or sell securities that it recommends to clients or
may recommend securities transactions in which the Advisor or its Covered Persons has some
financial interest. This practice would create a conflict of interest if the transactions were
structured to trade on the market causing an impact on recommendations made to the
Advisor’s clients. The Advisor addresses this conflict by prohibiting the execution of a personal
transaction in a security for which a client has a pending buy or sell order, until such client order
is executed or withdrawn.
The Chief Financial Officer will review a Covered Person’s personal transactions quarterly. The
Code requires pre-approval of personal transactions in some cases. The Advisor believes that
it has adopted sufficient controls so that personal transactions are consistent with advice given
to clients.
Item 12
Brokerage Practices
The Advisor does not provide brokerage services.
The Advisor recommends that clients establish brokerage accounts with Trade-PMR, Inc., a
FINRA-registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to
effect trades for their accounts. Although the Advisor may recommend that clients establish
accounts at Trade-PMR, Inc., it is a client’s decision to custody assets with Trade-PMR, Inc. or
another custodian. The Advisor is independently owned and operated and is not affiliated with
or supervised by Trade-PMR, Inc.
Clients may utilize the broker-dealer of their choice and have no obligation to purchase or
sell securities through Trade-PMR, Inc. However, if the client does not use Trade-PMR,
Inc., the Advisor will reserve the right not to accept the account.
Trade-PMR, Inc. provides the Advisor with access to its trading and custody services, which
are typically not available to retail investors. These services generally are available to
independent investment advisors on an unsolicited basis.
These services are not contingent upon the Advisor committing to Trade-PMR, Inc. any
specific amount of business (assets
in custody or trading commissions). Trade-PMR’s
brokerage services include the execution of securities transactions, custody, research, and
access to mutual funds and other investments.
for custody services but
is compensated by account holders
For the Client’s accounts maintained by Trade-PMR, Inc., it generally does not charge
separately
through
commissions and other transaction-related or asset-based fees for securities trades that are
executed through Trade- PMR, Inc. or that settle into Trade-PMR, Inc. brokerage accounts.
Research & Other Soft Dollar Benefits
By recommending Trade-PMR, Inc., the Advisor receives soft-dollar benefits which may
include access to Trade-PMR, Inc.’s products and services that assist the Advisor
in
managing and administering clients’ accounts including software and other technology that:
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(i)
(ii)
provide access to client account data (such as trade confirmations and account
statements);
facilitate trade execution and allocate aggregated trade orders for multiple client
accounts;
provide research, pricing and other market data;
facilitate payment of the Advisor’s fees from its clients’ accounts; and
assist with back-office functions, recordkeeping, and client reporting.
(iii)
(iv)
(v)
Best Execution
In recommending broker-dealers, the Advisor considers “best execution.” Best execution means
in recommending a broker-dealer, the Advisor will comply with its fiduciary duty to obtain best
execution and as defined by the Securities Exchange Act of 1934 and will take into account such
relevant factors as:
(i)
(ii)
(iii)
(iv)
price;
the broker-dealer’s facilities, reliability, and financial responsibility;
the ability of the broker-dealer to effect transactions, particularly with regard to
such aspects as timing, order size, and execution of order;
the research and related brokerage services provided by such broker-dealer to the
Advisor, notwithstanding that a client’s account may not be the direct or exclusive
beneficiary of such services; and
any other factors the Advisor considers to be relevant.
(v)
Aggregation of Orders
When the Advisor buys or sells the same security for more than one client, it may place
concurrent orders with the brokerage firm to be executed together as a single “block” in order
to facilitate orderly and efficient execution. Where orders are aggregated, each client’s account
will be charged or credited with the average price per unit. The Advisor receives no additional
compensation or remuneration from aggregating transactions.
Directed Brokerage
If a client directs the Advisor to use a specific firm for brokerage or custodial services, the client
should be aware that there may be brokerage and execution services available elsewhere at lower
cost. Clients should consider whether directing brokerage to a particular broker-dealer firm may
result in certain costs or disadvantages, such as higher commissions, less favorable executions,
or being limited in investment options.
If a client’s account is invested in mutual funds, these directed brokerage arrangements might
limit the investment options for the Advisor’s use in managing the client’s account. The reasons
for a brokerage firm to limit these options are many, such as the brokerage firm offers only its
proprietary investment products or is paid a higher commission when the volume of a particular
product attains a certain level.
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In addition, with directed brokerage arrangements, the client is responsible for negotiating the
brokerage firm’s commission rates and other fees.
Trading Errors
If a trading error results in a profit, the Advisor may retain the profit for the Advisor’s account to
offset any losses that occur from future trade errors or allocate it to a charity.
Item 13
Review of Accounts
The client’s IAR reviews client account activity no less than quarterly. The level of review
is determined by the complexity of the portfolio at the discretion of the IAR. Other factors that
may trigger review are changes in economic or market conditions, and individual client
situations.
The custodian will deliver account statements at least quarterly that include a summary of
the client’s activity. In addition, written portfolio performance summaries that provide
historical information regarding a client’s investments are provided annually or upon the client’s
request. Performance summaries should not be relied upon as predictive of future performance.
The custodian, broker-dealer, or other investment vendor will value the securities held in a
client’s portfolio. The values of some investments, such as alternative investments or private
placements, are provided by the investment’s manager, which may be monthly, quarterly,
but not less than annually; often, these values are estimates made by the alternative
investment’s manager and may not be the liquidation value.
Item 14
Client Referrals and Other Compensation
Any compensation that the Advisor may receive from non-clients is described in “Other Financial
Industry Activities and Affiliations” and “Brokerage Practices.”
The Advisor enters into solicitation arrangements with third parties (“Promoters”) to offer the
Advisor’s advisory services or programs. The Advisor enters into agreements with Promoters
pursuant to Rule 206(4)-1 of the Investment Advisers Act of 1940. The Advisor will compensate
the Promoter directly if a client enters into a relationship with the Advisor. This compensation is
ongoing and made up of a portion of the investment advisory fee the Advisor charges the client,
which may be up to 25% of the Advisory Fee. A Promoter will provide the client with a statement
disclosing the terms of the Promoter’s arrangement with the Advisor. The Advisor assures that
Promoters are properly licensed or registered in accordance with state securities laws.
The Advisor endeavors at all times to put the interests of its clients first. Clients should be aware,
however, that the receipt of economic benefits by the Advisor or its related persons in and of itself
creates a potential conflict of interest.
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Item 15
Custody
The Advisor has custody of clients’ funds to the extent that it has the ability to deduct fees from
clients’ accounts. The custodian will send quarterly account statements to clients. Neither the
Advisor nor its associated persons will accept delivery of a client’s securities or funds in the name
of the Advisor or its associated person.
Executing broker-dealers, custodians, or other investment vendors provide account statements
and confirmations. The Advisor urges clients to compare statements received from custodians
with any reports the Advisor may provide. If there are any differences, please contact the Advisor
immediately for resolution.
An unaffiliated, qualified custodian, such as a bank, broker/dealer (e.g., Trade-PMR, Inc.), mutual
fund company or transfer agent, will maintain client assets. The Advisor or any associated person
of the Advisor does not hold client assets. If a client chooses Trade-PMR, Inc. as custodian for their
brokerage account, Trade-PMR, Inc. acts as an introducing broker clearing on a fully disclosed
basis through Wells Fargo Clearing Services, LLC for the Advisor’s clients.
Item 16
Investment Discretion
Clients who have entered into a discretionary Investment Advisory Agreement with the Advisor
grant the Advisor power of attorney to exercise discretion over the selection of the investments,
timing of placing the trade, and amount of securities to be bought or sold. This investment
authority may be subject to specified investment objectives and guidelines and/or conditions
imposed by the client in writing, as described above in “Advisory Business.”
Clients who do not choose a discretionary arrangement retain the responsibility for the final
decision on all actions taken with respect to their portfolios and the Advisor must contact them
prior to the execution of any recommended trade. This may result in a delay in executing trades,
which could adversely affect the performance of a client’s portfolio. Non-discretionary trades may
not participate in block trading and as a result, may incur higher fees. For additional information
regarding block trading, see “Brokerage Practices” above.
Item 17
Voting Client Securities
The Advisor does not vote proxies on behalf of client owned securities. A client maintains
exclusive responsibility for: (i) directing the manner in which proxies solicited by issuers of
securities they beneficially own will be voted, and (ii) making all elections relative to mergers,
acquisitions, tender offers, bankruptcy proceedings or other types of events pertaining to the
client’s investments.
The Advisor does not render advice to or take any actions on behalf of clients with respect to any
legal proceedings, including bankruptcies, and shareholder litigation, to which any securities or
other investments held in client accounts, or the issuers thereof, become subject, and does not
initiate or pursue legal proceedings, including without limitation shareholder litigation, on behalf
of clients with respect to transactions, securities or other investments held in client accounts. The
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right to take any actions with respect to legal proceedings, including shareholder litigation, with
respect to transactions, securities or other investments held in a client account is expressly
reserved to the client.
Item 18
Financial Information
The Advisor has no financial commitment that impairs its ability to meet contractual and fiduciary
commitments to its clients nor has it been the subject of a bankruptcy proceeding.
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