View Document Text
NAPLES GLOBAL ADVISORS, LLC
720 5th Avenue South, Ste. 200
Naples, Florida 34102
Website: www.NaplesGlobalAdvisors.com
VERO BEACH GLOBAL ADVISORS
3003 Cardinal Drive, Ste. E
Vero Beach, Florida 32963
Website: www.VeroBeachGlobalAdvisors.com
Contact Information:
Telephone: 239-776-7900
Email: compliance@naplesglobaladvisors.com
Facsimile: 239-776-7909
Updated
March 20, 2025
This Brochure provides information about the qualifications and business practices of
Naples Global Advisors, LLC and its affiliate, Vero Beach Global Advisors. If you have any
questions about the contents of this Brochure, please contact the Chief Compliance Officer,
Kelly Walker, via email at compliance@naplesglobaladvisors.com or via phone at 239-776-
7900. The information in this Brochure has not been approved or verified by the United
States Securities and Exchange Commission (SEC) or by any state securities authority.
Additional information about Naples Global Advisors, LLC is also available on the SEC’s
website at www.adviserinfo.sec.gov. You can search this site by a unique identifying
number, known as a CRD number. The Firm’s CRD number is 158544.
Naples Global Advisors, LLC is registered with the SEC as an investment adviser; however,
such registration does not imply a certain level of skill or training.
Item 2 – Material Changes
This Firm Brochure, dated March 20, 2025, provides a summary of the Firm’s advisory services
and fees, background and credentials of Firm professionals, certain business practices and
policies, as well as actual or potential conflicts of interest, among other things.
This Brochure provides clients with a summary of new and/or updated information. The Firm will
inform clients of the revision(s) based on the nature of the updated information. The Firm will
ensure that clients receive a summary of any material changes to this and subsequent Brochures
within 120 days of the close of the Firm’s fiscal year. Furthermore, the Firm will provide clients
with other interim disclosures about material changes as necessary.
The following summarizes new or revised disclosures based on information previously provided
in the Firm Brochure dated January 21, 2025:
-
There were no material events or changes.
2
Item 3 – Table of Contents
Item 1 – Cover Page & Contact Information ........................................................................................................... 1
Item 2 – Material Changes ............................................................................................................................................. 2
Item 3 – Table of Contents ............................................................................................................................................ 3
Item 4 – Advisory Business ........................................................................................................................................... 4
Item 5 – Fees and Compensation ................................................................................................................................ 4
Item 6 – Performance-Based Fees and Side-by-Side Management ............................................................... 6
Item 7 – Types of Clients ................................................................................................................................................ 6
Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss ...................................................... 6
Item 9 – Disciplinary Information .............................................................................................................................. 8
Item 10 – Other Financial Industry Activities and Affiliations ........................................................................ 8
Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading .. 8
Item 12 – Brokerage Practices ..................................................................................................................................... 9
Item 13 – Review of Accounts ................................................................................................................................... 10
Item 14 – Client Referrals and Other Compensation ....................................................................................... 10
Item 15 – Custody .......................................................................................................................................................... 10
Item 16 – Investment Discretion ............................................................................................................................. 11
Item 17 – Voting Client Securities ........................................................................................................................... 11
Item 18 – Financial Information .............................................................................................................................. 11
Appendix – Privacy Policy .......................................................................................................................................... 12
3
Item 4 – Advisory Business
Naples Global Advisors, LLC (NGA) is an SEC-registered investment advisory firm and was
organized in 2011 as an employee-owned investment firm with its principal place of business in
Naples, Florida. NGA has an affiliated location in Vero Beach, Florida doing business as Vero Beach
Global Advisors (VBGA).
Together with the affiliated office, NGA offers services through investment advisor representatives
(IARs). The IARs are under the supervision of Naples Global Advisors, LLC, and the advisory
services of the IARs are provided through Naples Global Advisors, LLC.
NGA and VBGA (together the “Firm”) seek to provide discretionary investment management
services to individual and institutional clients. Prior to implementation of an investment strategy,
the Firm strives to gain a thorough understanding of a client's investment objective, time horizon,
and tolerance for risk. The Firm also reviews a client's investment history and analyzes the
personal circumstances and family dynamics that might impact the execution of the agreed upon
investment strategy.
The Firm’s core equity investment philosophy is best summarized as being global, multi-cap value.
Implementation is via an internal research process that relies initially on quantitative screening
methods that seek to identify attractively valued companies based on fundamental characteristics
including consistent profitability and a disciplined capital structure. The implementation of the
investment strategy is primarily accomplished through ownership of individual securities that
represent a wide range of capitalizations (micro to large cap) and an open geographical platform
(domestic and foreign).
The Firm also provides core fixed income strategies that emphasize a diversified grouping of
publicly traded fixed income securities, which are primarily considered investment grade. In
practice, a majority of the Firm’s clients maintain exposures to both key asset classes, equity and
fixed income, although there are clients that request dedicated equity and dedicated fixed income
mandates.
Item 5 – Fees and Compensation
The Firm's revenues are generated exclusively from advisory fees and are transparent to clients.
Advisory fees are based on a percentage of assets under management. The custodian separately
may impose certain fees related to custodial services provided to client accounts. Such fees may
be tied to security transactions or a flat fee determined by the custodian. Additionally, the
custodian may impose or deduct other expenses or fees such as foreign security taxes, American
Depositary Receipts (ADR) fees, fees for trading certain mutual funds, and charges for wire
transfers, as representative examples. Additionally, securities traded on foreign exchanges may
incur added transactional expenses or brokerage commissions that will vary by custodian,
country, and exchange.
The fees paid to the Firm for advisory services are identified distinctly and are separated from
custodial charges. Custodians typically have expenses inside their money market instruments that
4
are reflected as a reduction of net yield. Also, other expenses and fees may be embedded inside
exchange-traded funds and mutual funds.
The Firm's typical annualized advisory fees are based on the following schedule:
Annual Fee
$0 – $2,000,000
$2,000,000 – $4,000,000
$4,000,000 – $5,000,000
$5,000,000 – $50,000,000
$50,000,000 – $100,000,000
> $100,000,000
1.0%
0.8%
0.6%
0.5%
0.4%
0.3%
The applicable fee schedule may differ from client to client and affiliate to affiliate, but the general
advisory structure and source of fees collected remain consistent. Fees are generally deducted
directly from a client's account on a monthly basis. However, alternative arrangements may be
accommodated on a case-by-case basis. The advisory fees are determined using an end-of-month
valuation at the indicated level and billed in arrears. Individuals with multiple accounts, as well as
families, may be grouped together for relationship pricing, often resulting in a lower overall tiered
rate. In cases where an investment advisory relationship begins after the first day of a billing
period, or terminates prior to the last day, fees are prorated for the period.
The Firm may charge for services that are considered beyond usual and customary or otherwise
deemed extraordinary. Such other matters that are not routine in the conduct of an investment
include consultation on non-investment
advisory relationship subject to charges may
management matters, analysis, and advice relating to assets and holdings not managed by the
Firm.
The Firm does not recommend the use of margin for investment purposes; however, the Firm may
facilitate the establishment of a margin feature on a client’s behalf through the respective
custodian. In some instances, a client may direct the use of margin for investment or non-
investment access to liquidity. In any instance where margin is activated in a client account, the
Firm’s investment management fee payable will be assessed gross of margin. This is because the
nature and character of the underlying investable assets does not change. However, with a margin
balance, the market value of the client's account and corresponding fee payable by the client to the
Firm will be increased. Where investment management fees are assessed gross of margin, a
conflict of interest exists as the Firm has an incentive to use margin to increase its fees.
When deemed to be in the client’s best interest, the Firm will recommend that clients engage the
Firm to rollover their retirement accounts or move retirement assets to the Firm’s management.
Such a recommendation creates a conflict of interest if the Firm earns a new (or increase its
current) advisory fee as a result of the transaction. No client is under any obligation to rollover a
retirement account to an account managed by the Firm.
The client agreement allows for cancellation in writing at any time by either the client or the Firm
for any reason. There are no termination fees, although management fees earned up to the date of
termination will be prorated and charged to the account or billed to the client.
5
Item 6 – Performance-Based Fees and Side-by-Side Management
The Firm does not utilize performance-based fees.
Item 7 – Types of Clients
The Firm provides discretionary investment management services to the following types of
clients:
-
-
-
-
-
-
High net worth individuals
Individuals (other than high net worth)
Retirement accounts, principally IRAs
Corporations
Trustees
Charitable Organizations
The targeted relationship minimum valuation is investable assets of $1 million. Family or related
accounts may be bundled together to attain the stated relationship minimum. There may be
exceptions to this guideline when there is the future opportunity to reach the threshold, or in a
situation where the minimum annual advisory fee is met or when an alternative agreement is
reached with the client.
Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss
The Firm's investment philosophy is built on the following three key tenets:
-
The Firm strives to first understand a client's objectives and capacity for risk.
The Firm seeks to then effectively manage the risk/return equation through
proper asset allocation.
-
The Firm strives to build logically diversified portfolios using a global
opportunity set of securities that are vetted and assembled using a fundamental
valuation discipline.
-
The Firm’s discretionary portfolios are administered with a view toward
absolute returns, principal stability, and with a healthy respect for the ever-
changing dynamics of global economies, the capital markets, and a client's
personal circumstances.
The analytical process for equity selection is centered on identifying and compiling a well-
diversified group of publicly traded global businesses that are undervalued based on fundamental
characteristics. The key equity characteristics used in the initial screening process include high
and consistent return on equity, low levels of debt, low relative valuation, and a history of sharing
profitability with equity holders. This is first accomplished with quantitative screens that allow
for identification of a manageable grouping of stocks that can then be analyzed more
fundamentally. Once vetted and ultimately identified for inclusion in the portfolios, a diverse (by
6
sector, geography, and capitalization) collection of publicly traded businesses is then assembled
on an account-by-account basis and actively monitored for progress.
Below are the types of publicly traded securities in which the Firm typically invests on behalf of
client portfolios:
Equities
-
-
-
-
-
Individual U.S. equities of varied capitalizations (large, mid, small, and micro-cap)
Individual international and emerging market equities
Equity closed end funds, open end funds, and exchange-traded funds
Real estate investment trusts
Master limited partnerships
Fixed Income
-
-
-
-
-
U.S. government and U.S. government agency issues
Investment grade corporate and municipal bonds
High yield corporate and municipal bonds
Preferred and hybrid debt securities
Fixed income closed end funds, open end funds, and exchange-traded funds
Cash Equivalents
Money market mutual funds
Bank certificates of deposit
Custodian-offered sweep accounts
-
-
-
Risk of Loss
Investing in the capital markets involves an inherent level of risk. The Firm strives to understand
a client’s goals, objectives, and tolerance for risk prior to constructing and implementing an
investment program. However, given the nature and history of the capital markets, there is the
possibility of principal loss. While the risk of principal loss has historically been greater with
equity-oriented portfolios, fixed income portfolios also bear the risk of principal loss stemming
from credit risk, duration risk, and illiquidity risk.
Additionally, no guarantee can be provided that the stated return goals will be attained, and
historical performance results are not a guarantee of future returns.
The Firm does not invest in hedge funds, private equity, nor other non-traded securities. The
Firm’s focus is on utilizing the array of existing publicly traded securities where marketability and
daily valuation are more readily accurate and available. The Firm does invest in securities that are,
at times, thinly traded in both the domestic and foreign markets, but the Firm’s advisory personnel
strives to be mindful of the added risk that thinly traded securities pose as client portfolios are
assembled.
The Firm's core investment philosophy centers on a security’s valuation: relative to peers, the
market, and its historical metrics. The Firm’s belief is that value-oriented investment disciplines
have historically placed the odds of success in the client's favor. In summary the Firm feels that
7
paying attention to security valuations, maintaining global diversification, insisting on dividends
as a check on earnings authenticity, keeping turnover low, and minimizing expenses are all
components that reduce volatility and ultimately risk. While these factors do not eliminate market
risk, the belief is that they are logical and understandable risk mitigations.
The Firm feels that maintaining the primary research responsibility in-house, at the portfolio
manager level, also serves to moderate risk and increase client comfort. There is an efficiency of
time gained for the client, company specific conviction is attained, and a proximity to the client’s
risk tolerance is more readily addressed. Also, the Firm’s preference for utilizing individual
securities, as opposed to outside funds or external managers, provides for greater tax and trading
control.
The external custodial platforms allow for favorable trade execution, trade efficiency,
transparency, and low transactional costs—all part of a value-oriented philosophy that places the
interest of the client first. Newly funded portfolios are typically worked into the markets over a
period of time to take advantage of valuation dislocations and to reduce principal volatility.
As a global investment manager there are additional risks associated with the portfolio
management process. These include, but are not limited to, higher transaction costs for direct
foreign trades, challenges regarding the timing of execution, foreign taxation, currency risks,
uncertain liquidity, and political risk.
Item 9 – Disciplinary Information
The Firm and its employees have not been subject to any disciplinary action or sanctions with
regards to business conduct or practices from clients, the SEC, or other law enforcement bodies.
Item 10 – Other Financial Industry Activities and Affiliations
The Firm has no other industry affiliations or activities.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal
Trading
The Firm has adopted a Code of Ethics pursuant to Rule 204A-1 of the Advisers Act. The Code of
Ethics is for all employees, and it outlines the standards of required business conduct with the
following tenets serving as the foundation:
-
The Firm and its employees have a fiduciary duty that at all times places the
clients’ interest first.
-
The Firm and its employees should avoid any actual or perceived conflicts that
might compromise their fiduciary responsibility.
8
-
The Firm and its employees are prohibited from trading securities, either
personally or on behalf of others, while in the possession of material non-public
information that is either directly or indirectly obtained.
All employees of the Firm are required to read and sign the Code of Ethics statement annually as
an acknowledgement of their fiduciary responsibility to clients. The Firm's fiduciary duties
include, but are not limited to, the necessity to provide full and fair disclosure of any conflict of
interest, a duty of loyalty to the client and to the Firm, and a commitment to always provide
suitable recommendations that are based on the client’s objective. The Code of Ethics includes
provisions that deal with client confidentiality, prohibitions of insider trading, disclosure of
personal security trading, and gift and entertainment guidelines.
Employees of the Firm are allowed to invest in individual securities for their personal portfolios.
These securities may include Firm recommended securities; however, the Code of Ethics requires
that employees may not take advantage of any information that they may have concerning the
Firm's current or pending strategies. This is inclusive of avoiding transactional front running.
The Firm’s Code of Ethics is available to clients upon request. Clients may obtain a copy of the
Firm’s Code of Ethics by contacting the Firm at the telephone number or email address listed on
the cover of this Brochure.
Item 12 – Brokerage Practices
The Firm’s trading procedures prohibit unfair trading practices and are designed to avoid conflicts
of interest with a client’s portfolio. The Firm customarily utilizes the client custodian broker or
dealer for transactions in client portfolios, both for equity and fixed income trading. With the
execution of any client trade, the typical key objective is obtaining best trade execution, which is
defined as a combination of net price and trade impact. Other factors may play into the broker
dealer selection including the source of a trade idea, the capacity for providing long-term market
liquidity, and a research capacity that benefits all clients. Receipt of soft dollars, products, or
services other than trade execution or research are not factors in allocating brokerage.
As a multi-asset class manager of global equity and fixed income securities there are other
considerations that become part of the trade execution equation. These may include the level of
historical spreads, expected timing of a trade, trade confidentiality, historical settlement
experience, along with the financial soundness and reputation of the executing broker. All these
factors surround the trade process, but because the Firm does not participate in soft dollar rebates
there is a reduced risk of any actual or perceived conflict as it relates to client trades.
The Firm will at times group transactions together to efficiently trade a security in larger blocks.
Trades are then allocated on a pro-rata basis that seeks to prohibit any account favoritism. Clients
will generally receive the same average price in any grouped trade. The Firm may allocate any
partial execution in a manner determined in good faith to be fair and equitable. It is the Firm's
policy not to sell assets from the portfolio of one account to another except in situations where
specific bond swaps may be to the mutual advantage, and never a disadvantage to either party, of
each of the affected portfolios.
9
Item 13 – Review of Accounts
The Firm’s Portfolio Managers and Advisors develop specific goals and objectives with each client
prior to implementing an investment program. Portfolio Managers are charged with monitoring
account holdings and overall valuations on a daily basis. Actual portfolio asset allocation may vary
from time-to-time within established objective ranges and even beyond upper and lower targets,
depending on investment market valuation swings and portfolio manager judgement. Cash
balances are also analyzed on an on-going basis.
The Investment Committee consists of the Chief Executive Officer, Chief Investment Officer, and
other key employees. The Firm’s Investment Committee meets on a monthly basis to review
investment guidelines and overall policies for all investment management accounts. Portfolios are
formally reviewed when they are first established and rotationally thereafter at least annually to
ensure the accounts are being invested in accordance with the stated objectives. Any exceptions
are identified and resolution tactics determined. Strategic and tactical decisions are also discussed
at these monthly meetings but typically occur more frequently as market conditions dictate. More
practically, portfolios are continuously monitored with ultimate responsibility given to the
Portfolio Manager for strategy implementation and adjustments based on the market environment
and each client’s individual circumstances.
Clients of the Firm are provided access (electronically or by mail) to statements each month by
their custodian (Charles Schwab or Fidelity Investments) and have daily access for account
viewing over the internet. In addition, the Firm provides separate quarterly reports showing
performance and relevant index returns. The Firm also strives to meet with clients periodically, or
as requested, to review results and update records regarding material changes impacting
objectives.
Item 14 – Client Referrals and Other Compensation
The Firm does not pay referral fees.
Item 15 – Custody
The Firm does not custody any client securities or portfolios. Clients choose their own qualified
and independent custodian. The custodians send electronic or physical statements each month
directly to the client reflecting total holdings, total valuation, as well as trading and transactional
activity. The Firm has a reasonable belief that the custodians are providing statements to clients
in accordance with Rule 206 under the Investment Advisers Act of 1940, as amended.
Although the Firm does not hold client assets, the Firm is deemed to have custody for purposes of
amended Rule 206(4)-2 of the Advisers Act, in a limited number of client accounts, for one or more
of the following reasons:
-
The Firm is authorized by its clients to debit Firm management fees directly from
client accounts.
10
-
The Firm has authorization to direct payments from client accounts held by a
custodian primarily due to the courtesy service of bill payment, including tax
payments made on behalf of certain clients as they request or as initiated
through standing instructions to third-party providers.
Because the Firm is deemed to have custody of certain accounts, the Firm is required to an annual
surprise examination by an independent public accounting firm. The results of this annual audit
are provided to the SEC.
Item 16 – Investment Discretion
The Firm usually operates under full discretion for its investment management services. However,
for all clients this discretion is exercised within the bounds of a written client investment objective
statement. As well, it is not unusual that there are tax or legal constraints, and/or unique
considerations, which may override a portion of the discretion for individual assets or segments
of the portfolios.
Item 17 – Voting Client Securities
The Firm has adopted written policies and procedures that are intended to comply with Rule
206(4)-6 of the Advisers Act. The Firm seeks to always vote proxies in the best interest of
shareholders. While often the proxy vote will follow management’s recommendations, there are
situations that occur that will result in the Firm’s vote being in opposition to existing management,
either in whole or in part. At its core, the Firm’s policy is to encourage corporate actions that will
enhance shareholder value, and this may be with either a short-term or long-term perspective,
depending on the particular circumstance.
As a global investment firm, the Firm holds shares of foreign companies as ADRs as well as locally
registered shares. The voting rules in foreign markets can be restrictive for trading securities
around a particular shareholder vote, and the Firm will at times prefer to maintain liquidity in the
shares versus exercising the proxy vote. These situations will be vetted on a case-by-case basis.
At times the client might retain the right to vote proxies. In those instances, the custodian sends
the proxies directly to the client or other arrangements can be made.
The Firm is responsible for establishing formal proxy voting policies and procedures, and for
maintaining records for proxy voting. Those records will be made available to clients at their
request.
Item 18 – Financial Information
Registered investment advisers are required in this Brochure to provide clients with certain
financial information or disclosures about the Firm’s financial condition. NGA and VBGA have no
financial commitments that impair the Firm’s ability to meet contractual and fiduciary
commitments to clients and have not been subject of a bankruptcy proceeding.
11
Appendix
Naples Global Advisors, LLC
And its affiliate, Vero Beach Global Advisors (together the “Firm”)
Privacy Policy
The Firm’s privacy policy details the standards and procedures in respect to handling the personal
financial information of its clients, prospective clients, and employees.
Clients’ privacy is very important to the Firm. The employees of the Firm seek to maintain the
confidentiality and security of all clients’ personal information. Because of the nature of the
investment management business, it is customary for the Firm to be in possession of certain non-
public personal information.
By policy, the Firm does not sell or make available to marketers any of clients’ information. Client
information may be made available to third-party providers of technology services as necessary
to obtain investment management performance data and reporting. Additionally, as required by
judicial mandate or existing law, the Firm may disclose personal information to government
agencies or law enforcement officials as requested.
12