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Part 2A of Form ADV: Firm Brochure
Table of Contents
Item 11 Code of Ethics, Participation or Interest in
Item 4 Advisory Business .................................................. 2
Client Transactions and Personal Trading ........ 7
Item 12 Brokerage Practices ............................................ 8
Item 5 Fees and Compensation .................................... 2
Item 6 Performance-Based Fees and
Side-By-Side Management ................................. 4
Item 13 Review of Accounts ............................................ 9
Item 7 Types of Clients .................................................... 4
Item 14 Client Referrals and Other Compensation ....... 9
Item 8 Methods of Analysis, Investment
Item 15 Custody ................................................................ 10
Strategies and Risk of Loss .................................. 4
Item 16 Investment Discretion .......................................... 10
Item 17 Voting Client Securities ........................................ 10
Item 9 Disciplinary Information ....................................... 6
Item 10 Other Financial Industry Activities
Item 18 Financial Information .......................................... 10
and Affiliations ..................................................... 6
This brochure provides information about the qualifications and business practices of Dustin Blodgett Insight
Capital, LLC, CRD No. 314558. If you have any questions about the contents of this brochure, please contact us
at (925) 362-9571 and/or dustin@insightcapmgmt.com. The information in this brochure has not been approved
or verified by the United States Securities and Exchange Commission or by any state securities authority.
Registration does not imply a certain level of skill or training.
Additional information about Dustin Blodgett Insight Capital, LLC, also is available on the SEC’s website
at www.adviserinfo.sec.gov
Material Changes (since last update on 7/10/25)
Insight Capital Management is required to identify and discuss material changes since the last time this
brochure was updated. Michael Chapman is now an Investment Advisor Representative
Our Name and Address:
Dustin Blodgett Insight Capital, LLC
d.b.a. Insight Capital Management
1390 Willow Pass Road Suite 960
Concord, CA 94520
Our Contact Information:
Dustin Blodgett, Managing Member,
Chief Compliance Officer
(925) 362-9571
(925) 362-9577 (fax)
dustin@insightcapmgmt.com
+1 (925) 362-9571 • info@insightcapmgmt.com • www.insightcapmanagement.com
2/04/26
Item 4 Advisory Business
This item gives you information about our advisory business.
information that is relevant to the management of
clients’ account(s).
Dustin Blodgett Insight Capital, LLC (d.b.a. Insight
Capital Management) is an LLC established in 2021,
and owned by Dustin Blodgett, President and Chief
Compliance Officer. The firm is registered with the
Securities and Exchange Commission (“SEC”).
We provide investment management, financial
planning services, and educational
workshops/seminars which generally encompass
advice concerning the following types of investments:
This information will then be used to make investment
decisions and recommendations that reflect clients’
individual needs and objectives on an initial and
ongoing basis. Adviser’s decisions and
recommendations will allocate portions of clients’
account(s) to various asset classes classified
according to historical and projected risks and rates of
return. For non-discretionary accounts, Insight Capital
Management will review all such recommendations
with clients, and clients will have the opportunity
Stocks and bonds listed on an exchange or traded
over- the counter, municipal bonds, foreign securities,
warrants, corporate debt, commercial
paper, variable insurance products, US
government securities, options contracts on
securities and commodities, futures contracts,
limited partnerships investing in real estate and in
oil and gas interests, annuities, certificates of
deposit and mutual funds.
to accept or reject any recommendations. Clients
are under no obligation to accept or implement
any recommendation made by Insight Capital
Management. For discretionary accounts, Insight
Capital Management is granted a limited power of
attorney to execute transactions without necessarily
consulting client in advance. Clients may impose
restrictions on investing in certain securities or types of
securities so long as such restrictions may reasonably
be implemented by Adviser.
We may provide educational seminars/workshops for
our clients as a compliment to existing investment
management or financial planning services. Clients
pay no additional fee and at this time we do not
forsee any other possible conflicts of interest from
these arrangements.
We may furnish investment supervisory services to you
in the following manner (tailored to your individual
needs and subject to any restrictions imposed by you
and subject to your prior acceptance): We will
monitor your situation periodically throughout the
year and call you as necessary. We may receive
discretionary authority from you to effect
transactions. You will be billed for this type of service
quarterly on the first day of the following quarter after
the work has been performed.
Insight Capital Management tailors its advisory
services to the individual needs of its clients by taking
We do not participate in any wrap fee programs.
Assets Under Management (as of 02/04/2026):
Insight Capital Management manages
$330,500,000 in client assets on a discretionary
basis and $0 on a non-discretionary basis.
the time to understand clients’ current financial
condition, goals, risk tolerance, income, liquidity
requirements, investment time horizon, and
other
Item 5 Fees and Compensation
This item gives you information about the fee or other compensation we may receive from you or from others in
connection with or as a result of giving you investment advice.
accounts.
We can prepare a financial plan based on your
specific needs and circumstance. Our fee to create a
financial plan can be up to $2,500. For the specific
financial plan, fees are payable when the advice and
plan is delivered to you. You will be billed for
investment supervisory services quarterly after the work
Our fees range from 0% to 2% of the assets under
management per annum, prorated quarterly and
based on the managed assets at the end of the
quarter just completed. Our fees are negotiable. We
also charge a one-time financial planning fee for
clients wishing to have this service. This fee is in
addition to the asset-based fee for managing the
obligation to effect any transactions through any
particular broker-dealer or through any associated
person. You have the option to purchase investment
products or insurance products that we recommend
through any brokers or agents that you desire to use.
has been performed on the first day of the following
quarter. We do not bill any fees in advance. Our
quoted fee will be based on the assets under
management per annum, prorated quarterly and
based on the managed assets at the end of the
quarter.
You will pay additional fees to others in connection
with your investments, such as 12b-1 and other
mutual fund expenses, brokerage and other
transaction costs to the executing broker, custodial
fees and so on. We do not receive any portion of any
broker-dealer and/ or custodial fees.
(Please also see Item 12 for additional information on
our recommendation of brokers for you).
Direct Debiting: We will deduct these fees from your
account with the custodian if you have elected in
writing for us to do so. The custodian will send you a
quarterly statement showing all disbursements for your
account, including the amount of the advisory fee.
You should compare the account statements you
receive from your account custodian(s) with those
account statements you receive from us. It is not the
responsibility of the custodian(s) to do this for you.
If you decide to terminate your relationship with
Insight Capital Management, upon termination of
our agreement to manage your accounts, we will
bill the prorated amount of investment advisory fees
from your account.
Lower or higher fees for comparable services may be
available from other sources.
Either you or we may terminate a contract by written
notice to the other delivered either personally or by
mail.
Stripe billing: Initial Set-Up: We will connect you to a
third-party credit card processing service, Stripe. They
will work with you to establish payment method and
require you to sign their disclosures and agreements.
Making Payments: Once your agreement has been set
up, payments will automatically collect as per your
method of payment established with Stripe. Each time
a payment is debited from your card as part of your
agreement, a transaction confirmation email
is generated by their system and sent to the email
address they have on record.
We do not have any dollar minimums or other
requirements for accepting investment advisory
accounts.
For a new account that is opened during the quarter,
we may bill the prorated amount for the time we spent
managing your account as determined by the date
the account was funded.
From time to time and when appropriate for the
particular client, Insight Capital Management will
recommend annuities as a part of its insurance
offerings, to its clients from Great West, an insurance
provider. We are compensated from this arrangement
based on our standard fee schedule and are paid
from the clients’ investment accounts.
Certain of our supervised persons are registered
representatives of Independent Financial Group,
LLC, an independent and unaffiliated broker-dealer
and member of the Financial Industry Regulatory
Authority. From time to time and when appropriate
for the client, such supervised persons will earn an
ordinary and customary commission from the sale of
a security to a client in such capacity. This creates a
conflict of interest, because such supervised persons
have the potential to earn both commissions and
advisory fee revenue from a client. The supervised
persons address this potential conflict of interest by
fully disclosing their relationships with Investment
Architects, informing clients that they are under no
obligation to purchase a security through them, and
maintaining policies and procedures to reinforce our
fiduciary duty to clients.
Great West does not provide us with any economic
benefit nor any commissions. We do not charge our
clients any additional fees nor do we foresee any
conflicts of interest from this relationship. We do not
receive any incentives from offering these products
to our clients. For invoicing, Great West deducts our
management fee from their annuity investment
account. Our clients will incur brokerage and
transaction fees from TD Ameritrade, and Great West
based on the sale and annuity services offered by our
firm.
Additionally, our Chief Compliance Officer reviews all
investment advice given and all trading instructions
given for you by us to watch for conflicts.
You are under no obligation to act on our
recommendations. Furthermore, if you elect to act on
any of our recommendations, you are under no
Some of our supervised persons are licensed to sell
insurance products. This creates a conflict of interest
in that our supervised persons have an incentive to
recommend term life insurance since they will
receive additional commission compensation as a
result of such sales. We address this conflict of
interest by fully disclosing our insurance agency
relationships, but informing clients of the commission
to be earned, and by advising clients that they are
under no obligation to purchase any insurance
product through our supervised persons or otherwise.
Item 6 Performance-Based Fees and Side-by-Side Management
This item discusses whether we charge any Performance-Based Fees and, if we do, the procedures we have
set up to protect you.
We do not charge Performance-Based Fees.
Item 7 Types of Clients
This item tells you about the types of clients to whom we give investment advice.
We do not have any dollar minimums or other
requirements for accepting investment advisory
accounts.
We provide investment advice to the following
types of clients: Individuals (including high net worth
individuals), trusts, estates, foundations and
charitable organizations, corporations or other
business entities, pension and profit-sharing plans.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
This item discusses the way we analyze securities investments, the investment strategies we use in suggesting
investments for you and the risk of loss you may incur in making investments.
minimize this risk.
Below is a discussion of some types of risk that you
may encounter in securities investing: Credit risk
We may use charting or fundamental analysis
technical or cyclical analysis in looking at your
accounts. One of the reasons that we utilize more
than one type of analysis is to reduce risks induced by
utilizing only one type of analysis (see discussion of risk
below).
The issuer of a security in which you invest, either
directly or through a mutual fund, may default
(may be unable to pay the principal or to make
interest payments, or otherwise fulfill its obligations to
investors) or in some cases may even decide to stop or
reduce dividends.
In general, the investment strategies we use to
implement any investment advice that we give
to you might include either long term purchases
(securities held at least a year), or short-team
investments (securities sold within a year).
If the issuer of your security falls out of favor or has its
credit rating cut, the price could fall and you could
lose money if you need to sell before maturity. If the
issuer goes bankrupt, you could lose it all.
Every type of investment analysis has its drawbacks
and risks (see discussion of risk above). So does each
type of investment strategy. Many of the risk
factors discussed above apply to the various types of
analysis and strategy.
Economic Risk
The state of the nation’s or the world’s economy
may change drastically and that may well affect
your investments.
Foreign Exchange Risk
If you invest in a foreign security, it may go up in
value but, when you sell it and attempt to turn it
into cash from selling it you may find that a change
in the rate for exchanging foreign funds into US
dollars wipes out some or all of your profit.
There is always a risk of loss connected with investing.
This is true whether you are investing in securities or in
other types of investments. You, as an investor,
should be prepared to accept this risk. One way to
lessen it is to diversify your investments so that when
one goes down another may rise Part of our job as
your investment advisor is to help you understand
and manage this risk and to suggest ways for you to
Inflation Risk
Investors typically are locked into the interest rate
paid on bonds. If inflation should rise dramatically,
the after inflation return on bonds can be
negatively affected. As a result, the bond would
likely lose value in the open market.
Market risk
In making an investment you are usually betting
that the market will behave in a way that will be to
your advantage. That does not often hold true over
a long period of time and it sometimes does not
even hold true over a short period either.
Revenue Risk
Bonds that are dependent on revenue streams from
specific projects such as toll roads and bridges may
rely on the ability of the project to meet revenue
projections (note that many municipal bonds are
backed by the taxing authority of the issuer, rather
than a revenue source as outlined here).
Interest Rate Risk
If you are investing to realize a certain amount of
income and that income stream is dependent on
the investment paying a certain interest rate,
changing conditions may affect that interest rate
and your income from that investment. If rates in the
market rise, the underlying market value of existing
bonds with a lower yield can decline. If you decide
to sell a bond before maturity, this could result in a
loss of principal value.
Volatility Risk
This is the measure of uncertainty in the future price
of an asset. It is a measure of price fluctuations over
time represented by annualized standard
deviation. If an asset has rapid dramatic price
swings, volatility will be high. If asset price is
consistent and rarely changes, volatility will be low.
If you buy a bond or other fixed-income investment
and interest rates subsequently rise, the price of
your bond will probably fall. The longer the maturity
of your bond, the bigger the drop. If you need to
sell it before it matures, you could get back less
than you paid. (The reverse is also true: if interest
rates fall, the bond’s price will rise.)
You can mitigate this risk by never buying a bond that
matures before you need the money. Liquidity risk
The ability to sell a bond in the open market requires a
buyer. If an investment has gained value since you
bought it but you can’t find a buyer for it when you
want to sell it, it is illiquid at that point and you may
not be able to liquidate it for current intrinsic value.
Some bonds, from smaller issuers in particular, may not
have broad appeal to investors, potentially driving
down the price in the open market.
Many fixed-income investments don’t trade in large
numbers or very often. If you need to sell in a hurry, it
might be at a fire sale price.
Management risk
If you are investing in mutual fund shares and the
particular mutual fund is an “actively managed fund”
then there is no guarantee that the investment
manager’s decisions regarding investment
techniques, risk analysis and other matters will
produce the desired results that you are seeking.
Item 9 Disciplinary Information
This item discusses any disciplinary events that have involved this firm.
There have been no disciplinary problems involving our firm or any of our firm’s personnel.
Item 10 Other Financial Industry Activities and Affiliations
This item discusses any other financial industry activities and associations of us or of our executive officers.
funds and direct participation programs through
Independent Financial Group, LLC, and Great West,
an insurance company.
Neither our firm nor any of its management persons
has any relationship or arrangement that is material to
its advisory business or to its clients with any related
person listed below:
i.
investment company or other pooled investment
vehicle (including a mutual fund, closed-end
investment company, unit investment trust, private
investment company or “hedge fund,” and
offshore fund)
ii. other investment adviser or financial planner
iii.
futures commission merchant, commodity pool
operator, or commodity trading advisor
iv. banking or thrift institution
v. accountant or accounting firm
vi.
lawyer or law firm
Certain of our supervised persons are registered
representatives of Independent Financial Group,
LLC From time to time and when appropriate for
the client, such supervised persons will earn an
ordinary and customary commission from the sale of
a security to a client in such capacity as registered
representatives. This creates a conflict of interest,
because such supervised persons have the
potential to earn both commissions and advisory
fee revenue from a client. The supervised persons
address this conflict of interest by fully disclosing
their relationships with Investment Architects, and
informing clients that they are under no obligation
to purchase a security through them.
vii. pension consultant
viii. sponsor or syndicator of limited partnerships
Persons associated with us are also engaged in
the businesses of giving investment advice and of
selling fixed and variable insurance products, mutual
From time to time and when appropriate for the
particular client, Insight Capital Management will
recommend annuities as a part of its insurance
offerings to its clients from Great West, an
insurance provider. We are compensated from
this arrangement based on our standard fee
schedule 1% and are paid from the clients’
investment accounts. Great West does not
provide us with any economic benefit nor any
commissions. We do not charge our clients any
additional fees nor do we foresee any conflicts of
interest from this relationship. We do not receive
any incentives from offering these products to our
clients.
Insight Capital Management has entered a solicitor
arrangement with The Pacific Financial Group (“TPFG”)
(CRD No. 105203), an SEC registered investment
adviser that provides investment advisory services to,
among others, the participants of retirement plans
subject to the Employee Retirement Income Security
Act of 1974 (“ERISA”).
Insight Capital Management has entered an
agreement to be a Financial Advisor for 401(k)
plans offered through Paychex Retirement Services.
Insight Capital can now help manage the
investments for businesses that use Paychex.
Insight Capital may solicit participants of retirement
plans to become clients of TPFG and makes
recommendations to those participants to allocate
their self-directed brokerage account assets into
managed portfolios and/or mutual funds managed by
TPFG.
You are under no obligation to act on our
recommendations. Furthermore, if you elect to act
on any of our recommendations, you are under no
obligation to effect any transactions through us,
through any particular broker-dealer or through
any associated person.
In making investment allocation recommendations
pursuant to this arrangement, plan participants
should be aware that Insight Capital has a
potential conflict of interest when it recommends
that participants allocate assets from their core
account to their self-directed brokerage account
and also has a conflict of interest when it
recommends that self-directed brokerage account
assets be invested in TPFG’s managed portfolios
and/or mutual funds.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
This item refers to our Code of Ethics and how you may obtain a copy.
We have a Code of Ethics with provisions requiring
supervised persons to comply with all applicable
Federal and state securities laws that apply to our
dealings with you and our other clients.
already own. Any of these things may present a
conflict of interest in that we or our associated
persons may both receive investment advisory
fees and securities earnings on our own. All such
conflicts will be spelled out when we are working
with you and you are under no obligation to act
on our recommendations.
All persons associated with us are considered to be
“supervised persons”.
All access persons must report their personal
securities transactions and holdings periodically to
the Chief Compliance Officer. He is required to
review these reports.
Furthermore, if you elect to act on any of our
recommendations, you are under no obligation
to effect any transactions through us, through any
particular broker-dealer or through any associated
person.
All supervised persons are required to report any
violations of our Code of Ethics promptly to the Chief
Compliance Officer (or to such other persons we
designate, provided the Chief Compliance Officer
also receives reports of all violations).
If we or persons associated with us buy or sell the
same securities that we also submit trades for you at
about the same time that could possibly constitute
a conflict of interest. We will not trade ahead of you
or in any way that would affect your trades and all
trades (yours and ours) will be reviewed by our Chief
Compliance Officer to assure that you are
not harmed.
We will provide each supervised person with a copy of
our Code of Ethics and any amendments. Each
supervised person is required to sign a receipt for the
Code of Ethics and any amendments received by
them.
We will provide you, any of our clients or any
prospective advisory client who desires a copy of our
Code of Ethics with a copy of our code upon request.
Any material conflicts of interest regarding us, our
representatives or any of our employees, which
could be reasonably expected to impair the
rendering of unbiased and objective advice to
you, have been provided to you.
We or persons associated with us may buy or sell
the same securities that we recommend that you
buy or sell. We or persons associated with us may
also recommend that you trade securities that we
Item 12 Brokerage Practices
This item discusses the way we handle brokerage activities for you and for our other clients.
clients, or both. Such products and services include
We suggest discount brokers or custodians for
brokerage or custodial services for you based upon
the size of commission discounts when compared to
full service brokers and our opinion of the relative
quality of service, types of reports and other materials
furnished to you and other clients and to us by the
brokers, the services provided by the brokers or
custodians to you and our other clients and to us, and
the stability afforded by
the
recommended broker’s or custodian’s
financial condition and general reputation in the
investment community.
(a) an online platform through which Insight
Capital Management can monitor and
review client accounts, access to proprietary
technology that allows for order entry, (c)
duplicate statements for client
accounts and confirmations for client transactions,
(d) invitations to the custodial broker-dealer(s)’
educational conferences, (e) practice management
consulting, and (f occasional business meals and
entertainment.
The receipt of these products and services
creates a conflict of interest to the extent it
causes Insight
Capital Management to recommend TD Ameritrade
(now owned by Charles Schwab) as opposed to a
comparable broker-dealer. Insight Capital
Management addresses this conflict of interest by
fully disclosing it in this brochure, evaluating TD
Ameritrade (now owned by Charles Schwab) based
on the value and quality of its services as realized by
clients, and by periodically evaluating alternative
broker- dealers to recommend.
Insight Capital Management does not consider, in
selecting or recommending custodial broker-
dealers, whether Insight Capital Management or a
related person receives client referrals from a
custodial broker- dealer or third-party.
Insight Capital Management considers several factors
when recommending a custodial broker- dealer for
client transactions and determining the
reasonableness of such custodial broker-dealer’s
compensation. Such factors include the custodial
broker-dealer’s industry reputation and financial
stability, service quality and responsiveness, execution
price, speed and accuracy, reporting abilities, and
general expertise. Assessing these factors as a whole
allows Insight Capital Management to fulfil its duty to
seek best execution for its clients’ securities
transactions. However, Insight Capital Management
does not guarantee that the custodial broker-dealer
recommended for client transactions will necessarily
provide the best possible price, as price is not the sole
factor considered when seeking best execution. After
considering the factors above, Insight Capital
Management recommends TD Ameritrade (now
owned by Charles Schwab) as the custodial broker-
dealer for client accounts.
Insight Capital Management does not routinely
recommend, request, or require that a client direct
Insight Capital Management to execute transactions
through a specified custodial broker- dealer other
than TD Ameritrade (now owned by Charles
Schwab).
Insight Capital Management retains the ability to
aggregate the purchase and sale of securities for
clients’ accounts with the goal of seeking more
efficient execution and more consistent results
across accounts.
Insight Capital Management does not receive research
and other soft dollar benefits in connection with client
securities transactions, which are known as “soft dollar
benefits”. However, the custodial broker-dealer(s)
recommended by Insight Capital Management do
provide certain products and services that are
intended to directly benefit Insight Capital
Management,
Aggregated trading instructions will not be
placed if it would result in increased
administrative and other costs, custodial
burdens, or other disadvantages.
If client trades are aggregated by Insight Capital
Management, such aggregation will be done so
as to not to disadvantage any client and to treat
all clients as fairly and equally as possible.
Item 13 Review of Accounts
This item describes how we review your accounts and any reports you may receive.
We will review your accounts on a quarterly basis at
the least.
GreatWest will send our client’s a statement each
quarter. Each statement may also include the clients’
investment in mutual funds through sub- accounts with
an annuity company.
In addition to quarterly reports sent by custodians,
we will provide quarterly reports to you on your
various investments. All reports are reviewed
You will also receive reports from the custodians of
your securities.
You should compare the account statements you
receive from your account custodian(s) with those
account statements you receive from us. It is not the
responsibility of the custodian(s) to do this for you.
in detail for accuracy and performance by a principal
(at this point, by our Chief Compliance Officer), and if
deemed necessary, we will contact you for discussion
of relevant issues. You are encouraged to call at
anytime if there are questions or concerns.
Item 14 Client Referrals and Other
Compensation
This item discusses any compensation we may receive for referring you to other investment advisers or any
other compensation we may receive from persons other than yourself for giving you investment advice.
We do not currently compensate anyone for
referring clients to us.
Insight Capital Management has entered into a
solicitor arrangement with The Financial Planning
Group (“TPFG”) (CRD No. 105203), an SEC-
registered investment adviser that provides
investment advisory services to, among others,
participants in retirement plans subject to the
Employee Retirement Income Security Act of 1974
(“ERISA”).
In making investment allocation recommendations
pursuant to this arrangement, plan participants
should be aware that Insight Capital has a potential
conflict of interest when recommending that
participants allocate assets from their core accounts
to their self-directed brokerage accounts, and also
has a conflict of interest when recommending that
assets in self-directed brokerage accounts be
invested in managed portfolios and/or mutual
funds.
Insight Capital may solicit participants of
retirement plans to become clients of TPFG and
make recommendations to those participants to
allocate their self-directed brokerage account
assets into managed portfolios and/or mutual
funds managed by TPFG.
Insight Capital may host client appreciation events
and/or prospecting events and may receive
financial support from fund companies or other
‘partners’ of the firm. The conflict of interest may
arise from Insight Capital’s desire to send business or
client assets to these firms. However, Insight Capital
will never use client funds to seek an economic
benefit from any of these supporting firms and
explicitly states this to each firm wishing to support
any event marketing hosted by Insight Capital.
Item 15 Custody
This item reveals any types of custody we may have or may accept in the future.
clients’ funds or securities pursuant to the SEC’s
custody rule and subsequent guidance thereto. At
no time will Insight Capital Management accept full
custody of client funds or securities in the capacity
of a custodial broker-dealer, and at all times client
accounts will be held by a third-party qualified
custodian as described in Item 12, above.
For clients that do not have their fees deducted
directly from their account(s) and have not provided
Insight Capital Management with any standing
letters of authorization to distribute funds from their
account(s), Insight Capital Management will not
have any custody of client funds or securities. For
clients that have their fees deducted directly from
their account(s) or that have provided Insight
Capital Management with discretion as to amount
and timing of disbursements pursuant to a standing
letter of authorization to disburse funds from their
account(s), Insight Capital Management will typically
be deemed to have limited custody over such
If a client receives account statements from both
the custodial broker-dealer and Insight Capital
Management or a third-party report provider,
client is urged to compare such account
statements and advise Insight Capital
Management of any discrepancies between.
Item 16 Investment Discretion
This item discusses any types of investment discretion we may have or may accept to make securities trades for
you.
we have not obtained your written authorization to
manage your accounts or to make discretionary
trades for you we will each time obtain your
permission to make a trade(s).
We generally accept a written limited power of
attorney from you to make discretionary trades for
you. We would select the securities to be bought or
sold and the amount of securities to be bought or
sold for you, in accordance with your wishes. If
Item 17 Voting Client Securities
This item discusses our policy regarding voting proxies or other matters concerning your securities.
do so, you can contact the issuer’s investor services
department or the custodial broker to request that
information. If you need help in obtaining these
materials or have any questions, please contact us
and we will be happy to assist you in obtaining
those materials or answers to those questions.
We do not vote your client securities or proxies.
Usually the transfer agent of the company issuing the
security will send proxy materials or other solicitations
directly to you. In some cases, they will send those
materials to your custodial broker. If you do not
receive these materials directly and wish to
Item 18 Financial Information
This item shows any financial information we must provide to you.
We do not bill any fees in advance. We do not require
the prepayment of fees of more than $1,200 per client
and for six months or more in advance.
There are no financial conditions that would keep us
from meeting any financial commitment to you or
any other factors such as a bankruptcy petition that
would require us to provide any financial information
under this item.
We do not have any custody of client funds
or securities.