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Cover Page
Brochure
Investment Management Corporation
Investment Counsel & Wealth Management
1940 Electric Road
Roanoke, Virginia 24018
540.774.8899
800.576.4900
Fax: 866.666.1460
Website: InvestmentManagementCorp.com
Email: mail@investmentmanagementcorp.com
This brochure provides information about the qualifications and business practices
of Investment Management Corporation. Contact us by phone or email if you have
any questions about the contents of this brochure. The information in this brochure
has not been approved or verified by the United States Securities and Exchange
Commission or by any state securities authority. Additional information about
Investment Management Corporation also is available on the SEC’s website at:
www.adviserinfo.sec.gov
Material Changes
Investment Management Corporation is required to advise you of any material
changes to the Firm Brochure (“Brochure”) from our last annual update. There
have been no material changes.
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Table of Contents
Section
Page
1
1. Cover Page
2
2. Material Changes
3
3. Table of Contents
4
4. Advisory Business
4
5. Fees and Compensation
5
6. Performance-Based Fees/Side-By-Side Management
7. Types of Clients
5
8. Methods of Analysis/Investment Strategies/Risk of Loss 6
7
9. Disciplinary Information
8
10. Other Financial Industry Activities and Affiliations
8
11. Code of Ethics/Participation or Interest in Client
Transactions and Personal Trading
9
10
10
10
11
11
11
12. Brokerage Practices
13. Review of Accounts
14. Client Referrals and Other Compensation
15. Custody
16. Investment Discretion
17. Voting Client Securities
18. Financial Information
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Advisory Business
Investment Management Corporation, an SEC registered advisory firm, has been
managing client investment portfolios since 1986. We provide only discretionary
investment portfolio management for individuals, businesses, trusts, and estates
after evaluating the client’s individual objectives and risk tolerance. This means
that our clients authorize us to make any investment changes whenever we desire,
which is based on our sole judgment from our analysis of market conditions and
performance of the portfolio investments.
We are compensated only by fees received from our investment clients. We
receive no other compensation, which distinguishes our service from other advisors
that also may receive compensation from brokerage firms, insurance companies,
mutual fund companies, or other investment providers.
We invest portfolios in individual stocks, bonds, exchange traded funds and mutual
funds. On 12/31/2025, the total value of assets we managed for 193 clients was
$191,179,778 dollars.
We do not take custody of client assets. Instead, we select an independent
custodial firm to hold client investments, so that there will be independent
reporting of client values and transactions sent directly to the client on a monthly
basis from the independent custodian. To supplement this, Investment
Management Corporation provides its own quarterly reporting that provides
additional portfolio and investment returns, including any gains and losses.
Fees and Compensation
We recommend the use of investments that are “no-load”, meaning that we do not
receive any compensation from your investments when buying, selling, or holding
positions. We are compensated solely by our advisory fee and do not receive any
other compensation, such as brokerage commissions on investments selected for
your account. Our fees are either deducted from client assets or billed.
Investment Management Corporation’s estimated quarterly advisory fee for its
management service is not negotiable and is payable after delivery of a quarterly
client report for the previous quarter. Fees are payable quarterly in advance and
are calculated in accordance with the fee schedule that follows based on your
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investment portfolio’s average daily value for the quarter. Quarterly withdrawals
are made from your investment account(s) to pay advisory fees. The following
table illustrates our investment management fee schedule.
Assets Under Management
$100,000 - $500,000
$500,001 - $1,000,000
$1,000,001 - $2,500,000
$2,500,001 - $5,000,000
$5,000,001 - $10,000,000
Over $10,000,000
Annual Fee Rate
1.25%
1.10%
1.00%
0.80%
0.60%
0.50%
Quarterly Fee Rate
0.3125%
0.2750%
0.2500%
0.2000%
0.1500%
0.1250%
Minimum annual advisory fee is $1,250.
At any time, you may request that we terminate our advisory service by sending us
written notification. However, you will still owe the total advisory fee for the
remainder of the current quarter.
Your other costs in addition to our advisory fee will include any custodial or
brokerage transactions that require charges, such as may be incurred when
individual stocks, bonds, or ETFs are traded. You may be charged a brokerage
account closing fee, mutual fund early redemption fees, and mutual fund company
fund expenses, such as a mutual fund’s portfolio management fee.
Performance-Based Fees and Side-By-Side Management
Investment Management Corporation does not charge performance-based fees.
Types of Clients
We manage investment accounts for individuals, business entities, pension and
profit-sharing plans, and trusts. We require a minimum of $100,000 in managed
accounts to be retained under our investment management agreement.
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Method of Analysis, Investment Strategies and Risk of Loss
Investment Management Corporation makes decisions to buy or sell portfolio
investments based on both “fundamental” and “technical” analysis of economic
data and investment markets. We compare current data to historical data to
determine whether we should increase or decrease investments in specific asset
classes such as stocks, bonds, and cash. We update our analysis each week to
reflect new data for the previous week. An example of the fundamental data is the
level of interest rates that the Federal Reserve establishes for its lending to banking
institutions. An example of technical data is tracking the current price of an
investment compared to its price in the past.
New investment funds may be allocated to the strategies chosen by clients in
varying amounts over a period of time at our discretion based on our assessment of
current investment market conditions.
It is important to understand that any investment of funds in investment securities
in any of our strategies listed below involves the risk of loss which you should be
prepared to bear whenever it may occur. There are no other material risks when
compared to this. All investment funds remain “liquid”, which means they are
readily available, since we only invest in investments that can be sold at any time,
unless specifically directed otherwise by you.
We do not trade investment securities above a frequency that could negatively
affect investment performance, since trading that is too frequent may adversely
affect investment performance.
The following strategies asset class exposures may be changed at our discretion
within these ranges:
Variable Equity Models
Focused Growth, Focused Growth TM, Dynamic Opportunities,
Diversified Index
100% Maximum Stock to 0% Minimum Stock
100% Maximum Bonds to 0% Minimum Bonds
100% Maximum Cash to 0% Minimum Cash
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Conservative Growth-
75% Maximum Stock to 0% Minimum Stock
75% Maximum Bonds to 0% Minimum Bonds
100% Maximum Cash to 0% Minimum Cash
Maximum Income-
30% Maximum Stock to 0% Minimum Stock
80% Maximum Bonds to 0% Minimum Bonds
100% Maximum Cash to 0% Minimum Cash
The following strategies asset class exposures remain near the following levels:
Fixed Equity Models
IS Growth, IS 25, Strategic Dividends-
100% to 90% Stock (Individual Securities)
10% to 0% Cash
In addition to the quarterly account statement issued by the custodian, IMC
provides a quarterly letter to report model portfolio returns and exposure to stocks,
bonds, and cash. The purpose is to provide the client with a way to verify account
performance and holdings are in-line with the desired investment model strategy.
Disciplinary Information
Our firm and the personnel associated with us have never had any violations or
disciplinary actions taken by the regulatory authorities who periodically audit our
firm for compliance with the Securities and Exchange Commission federal and
state regulations.
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Other Financial Industry Activities and Affiliations
To eliminate potential conflicts of interest, our management persons and other
employees are not permitted to be registered as or have relationships or
arrangements with a broker-dealer or represent any broker-dealer, futures
commissions merchant, commodity pool operator, commodity trading advisor, or
associated person of any such entities. Our management persons and other
employees are also not permitted to have any relationships or arrangements with
others such as: other investment advisors or financial planners, banking or thrift
institution, accountant or accounting firm, lawyer or law firm, insurance company
or agency, pension consultant, real estate broker or dealer, sponsor or syndicator of
limited partnerships, investment companies or other pooled investment vehicles
that are material to our investment advisory business or that creates a conflict of
interest.
Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
All persons working for our firm adhere to our Code of Ethics to protect material
nonpublic information about clients and their transactions. It is based on the
principle that Investment Management Corporation and its employees have a
fiduciary duty to place the clients’ interests above their own. Employees are
expected to maintain the highest standards of ethics and conduct in all of their
business relationships. A complete copy of our Code of Ethics is available upon
request.
In general, the code requires all employees to:
• Always place the interests of IMC’s clients ahead of their own personal
interests
• Ensure that all personal securities transactions are conducted in such a
manner as to avoid any actual or potential conflict of interest or any abuse of
an employee’s position of trust and responsibility
• Not take inappropriate advantage of information obtained as a result of their
positions.
Employees must disclose personal securities transactions in any account that they
have a beneficial ownership. IMC monitors its employees’ personal securities
trading activity on an ongoing basis. Employees who violate the code may be
reprimanded, fined, suspended or terminated.
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IMC is committed to acting in the best interests of our clients at all times. As a
Registered Investment Advisor (RIA), IMC operates as a fiduciary, meaning we
have a legal and ethical obligation to prioritize our clients’ interests above our
own.
Our fiduciary duty includes the following key principles:
• Acting in Good Faith – We provide investment advice and financial
planning services with honesty, integrity, and full transparency.
• Putting Clients’ Interests First – We avoid conflicts of interest whenever
possible and disclose any potential conflicts that may arise.
• Providing Full and Fair Disclosure – We communicate openly about fees,
compensation structures, and any relevant factors that may impact
investment recommendations.
• Exercising Due Care and Prudence – We conduct thorough research and
analysis to ensure our recommendations align with each client’s financial
goals, risk tolerance, and time horizon.
• Ongoing Monitoring and Duty of Care – We continuously review client
portfolios, market conditions, and financial plans to ensure they remain
aligned with our clients’ evolving needs and objectives.
Our commitment to the fiduciary standard ensures that our clients receive
objective, personalized financial guidance designed to help them achieve long-
term financial success.
Brokerage Practices
Since our firm does not receive any compensation from brokerage firms that
execute transactions for our clients, we select a broker based on their industry
status and insured fiduciary standing. Any transactions that would result in a
transaction fee to the broker must be highly competitive in comparison to other
brokers.
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So that there will be no conflict of interest, we do not permit the receipt of any
benefits of any kind that may be considered a “soft-dollar” benefit, such as a
product or service that we might otherwise have to spend money to obtain.
We do not accept referrals from brokerage firms and do not permit clients to select
brokerage firms for accounts managed by us. Aggregation of trades to lower
transaction costs for clients is utilized by us when trading securities.
Review of Accounts
Investment Management Corporation reviews all Variable Equity Model strategies
on a weekly basis. Fixed Equity Model strategies are reviewed on at least an
annual basis. In addition, we review client accounts on at least an annual basis to
learn whether clients’ accounts are in line with their investment objectives.
Strategies utilizing individual securities, annuities, insurance, and any other
investment accounts that require access to prior existing custodians that do not
provide direct data downloads to us are reviewed on a quarterly basis. If, as a
result of any model strategy review, an investment change is made, all client
accounts following the affected strategy are changed to the new investment
position. On a quarterly basis we provide a written report to our clients showing
account values, additions, withdrawals, and rates of return.
Client Referrals and Other Compensation
Referrals come from existing clients and professionals such as Certified Public
Accountants and Attorneys at their discretion.
Custody
We do not take custody of client funds or securities. An independent custodian,
such as a stock brokerage firm, is selected to hold client investments. The
independent custodian provides account statements to clients on a monthly basis
showing all investment positions and transactions. We also send clients a quarterly
report that we prepare summarizing our investment actions and investment returns.
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Investment Discretion
Under our client advisory agreement, we require that you agree to our having
“investment discretion”. This means that you are giving us unrestricted authority
to make investment changes on your behalf without having to notify you or ask for
your approval beforehand. All investment changes will be made taking into
consideration the asset class exposure limitations that are described in section #5
titled Method of Analysis/Investment Strategies/Risk of Loss of this brochure.
Voting Client Securities
We do not accept authority to vote client securities. All clients will receive proxies
and other such investment security solicitations to vote on shareholder issues
directly from the brokerage firm acting as independent custodian of their account.
Financial Information
We do not have any financial condition that would impair our ability to meet
contractual commitments to clients. We also do not require clients to pay advance
fees for our services that are more than $1200.00
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