Overview

Total Firm Assets
$146 million
Average High-Net-Worth Client Portfolio Size
$3.1 million
Minimum Account Size
$1,000,000

Fee Structure

Primary Fee Schedule (SEC FORM ADV PART 2A)

MinMaxMarginal Fee Rate
$0 $500,000 1.00%
$500,001 $1,500,000 0.75%
$1,500,001 $2,500,000 0.50%
$2,500,001 and above 0.38%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $8,750 0.88%
$5 million $26,875 0.54%
$10 million $45,625 0.46%
$50 million $195,625 0.39%
$100 million $383,125 0.38%

Clients

High-Net-Worth Share of Firm Assets
89.97%
Number of High-Net-Worth Clients
42
Total Client Accounts
162
Discretionary Accounts
162

Services Offered

Services: Portfolio Management for Individuals, Portfolio Management for Institutional Clients

Regulatory Filings

SEC CRD Number
105634

Additional Brochure: SEC FORM ADV PART 2A (2026-07-08)

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Part 2A of Form ADV: Investment Adviser Brochure Item 1 Cover Page Page 1 This brochure provides information about the qualifications and business practices of Peterson Investment Management, Inc. We strive for effective communication and write this brochure in a narrative format using plain English. We desire full and truthful disclosure of all material facts relating to the business so that prospective and existing clients may understand the advisory relationship. We seek to avoid conflicts of interest with my clients and make full disclosure of all material conflicts of interest that could affect the relationship. 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. You may find additional information about Peterson Investment Management, Inc. on the SEC’s Investment Adviser Public Disclosure (IAPD) webpage. IAPD provides information about current and certain former Investment Adviser Representatives and Investment Adviser firms registered with the SEC and/or state securities regulators. For additional information, go to https://adviserinfo.sec.gov and search on firm name, “PETERSON INVESTMENT MANAGEMENT INC” or firm CRD 105634. If you have any questions about the contents of this brochure, please contact us at: Robb M. Peterson Peterson Investment Management, Inc. 4325 E 24th Ln Spokane WA 99223-5511 509-991-0894 robb@petersoninvestment.com This brochure is dated July 8, 2026 Item 2 Material Changes Page 2 The material changes in this brochure from the last annual updating amendment of Peterson Investment Management, Inc. on March 23, 2026, are described below. Material changes relate to Peterson Investment Management, Inc.’s policies, practices or conflicts of interests. • Peterson Investment Management, Inc. is transitioning to registration with the United States Securities and Exchange Commission from its prior registration at the state level. Item 3 Table of Contents Page 3 Item 1 Cover Page – Page 1 Item 2 Material Changes – Page 2 Item 3 Table of Contents – Page 3 Item 4 Advisory Business – Page 4 Item 5 Fees and Compensation – Page 5 Item 6 Performance-Based Fees and Side-By-Side Management – Page 7 Item 7 Types of Clients – Page 8 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss – Page 9 Item 9 Disciplinary Information – Page 10 Item 10 Other Financial Industry Activities and Affiliations – Page 11 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading – Page 12 Item 12 Brokerage Practices – Page 13 Item 13 Review of Accounts – Page 14 Item 14 Client Referrals and Other Compensation – Page 15 Item 15 Custody – Page 16 Item 16 Investment Discretion – Page 17 Item 17 Voting Client Securities – Page 18 Item 18 Financial Information – Page 19 Notice of Privacy of Consumer Financial Information – Page 20 Item 4 Advisory Business Page 4 A. Firm description, officers, and ownership. a. Peterson Investment Management, Inc. is a domestic corporation of Spokane, Washington and was organized under the laws of the State of Washington on December 24, 1979. The corporation has no subsidiaries. b. Robb M. Peterson holds the corporate offices of President, Secretary and Chief Compliance Officer. c. The corporate stock is owned entirely by Robb M. Peterson. B. Firm services: I require limited power of attorney and use discretion to review portfolios of cash and securities and to establish portfolio objectives for holdings of stocks and bonds based on the client’s objectives, time horizon, risk tolerance and our assessment of market conditions. I will then enter purchase and sell orders for publicly traded securities that will, in my opinion, offer suitable vehicles for the client’s goals. Diversification is used and the portfolio’s holdings are changed based on fundamental and market conditions. The percentage allocation to stocks and bonds, and their equivalents, may be adjusted by the adviser, due to market conditions, or by the client. C. Service customization: I tailor client portfolio management to accommodate required liquidity, safety, income, time horizon, specific companies, or industries to avoid, and consideration of taxes with respect to capital-loss carry forwards, income and capital-gain tax rates. D. Wrap Fee Programs: I do not participate in programs that combine trading commissions and investment management fees. E. Regulatory Assets under Management (RAUM): As of June 26, 2026, RAUM totaled $ 146,121,289. All assets under management were discretionary, meaning that I have the power to act according to my judgment for the account holder’s benefit. Item 5 Fees and Compensation Page 5 A. Advisory Service Compensation: I am compensated by a fee based on assets under management according to the schedule below. Fees are not negotiable and are calculated on portfolio value. Multiple accounts for the same household shall be aggregated to determine the lowest possible fee and that fee shall be apportioned such that all accounts pay the same rate per dollar under management. 501(c)(3) charitable organizations receive a 30% discount from the schedule below. Amount under Supervision First $500,000 Next $1,000,000 Next $1,000,000 Over $2,500,000 Annual Fee 1.000% 0.750% 0.500% 0.375% Examples of Annual Fee Calculation: Example Calculation Annual Fee % Portfolio Value Client #1 $500,000 Client #2 $1,000,000 $ Annual Fee $5,000 $8,750 1.000% 0.875% $500,000 x 0.01 ($500,000 x 0.01) + ($500,000 x 0.0075) Client #3 $500,000 $1,500,000 $2,000,000 $3,750 $11,250 $15,000 0.750% 0.750% 0.750% ($500,000 x 0.01) + ($1,000,000 x 0.0075) + ($500,000 x 0.005) B. Fee Payment: Fees are paid quarterly, in advance, and deducted from the client’s account. New clients, who commence management during a quarter, will have their management fee prorated based on the quarter’s remaining term and that fee will be paid in arrears with the following quarter’s fee billing. As per WAC 460-24A-106, “In all instances, the Adviser will send the client a written invoice, including the fee, the formula used to calculate the fee, the fee calculation itself, the time period covered by the fee, and, if applicable, the amount of assets under management on which the fee was based and the name of the custodian(s) on your fee invoice. The Adviser will send these to the client concurrent with the request for payment or payment of the Adviser’s advisory fees. We urge the client to compare this information with the fees listed in the account statement.” C. Example of quarterly fee billing for a current client: Client has a portfolio worth $500,000 on December 31. On January 2, I bill the client’s portfolio custodian one quarter of the $5,000 annual fee for the first quarter. The custodian deducts $1,250 from the portfolio’s money market fund and journals it to Peterson Investment Management, Inc. Example of quarterly billing for a new client: Client commences management with a portfolio worth $450,000 on November 30. There is no fee billed in advance because the client commenced management during a quarter. On December 31, the portfolio is worth $500,000. I bill a fee in arrears of $382.19 for the 31-day period from November 30 to December 31. The fee is calculated as: $450,000 (portfolio value) x 0.01 (annual rate) x (31/365) (fraction of year). Additionally, I bill a fee in advance of $1,250.00 for the first quarter fee. The fee is calculated as $500,000 (portfolio value) x 0.01 (annual rate) x 0.25 (reducing annual rate to one quarter). D. Other Fees or Expenses Paid: a. Portfolio Management Interface License: Peterson Investment Management, Inc. pays for the portfolio management software license to connect to Charles Schwab & Co., Inc. Clients are free to select the custodian of their choice, but we reserve the right to charge their portfolio for the cost of the interface license for a custodian other than Charles Schwab & Co. b. Commissions: The custodian for the client’s portfolio of securities may receive payment from the client’s portfolio for transactions. Purchases and sales of stocks may incur commissions according to the custodian’s fee schedule. The commission rate is influenced by many factors, including portfolio size, total assets that the client has with the custodian, quantity of shares purchased, client’s election to receive portfolio statements and trade confirmations via electronic delivery and promotional rates for new accounts. c. Markups and Markdowns: The custodian will increase the purchase price or reduce the sales price of a security transaction when the custodian is buying for its own account as a principal, rather than acting as an agent for buyer or seller. The markup or markdown is in lieu of a commission. d. Transaction Fees: The custodian may charge an extra fee or higher commission for transactions on foreign exchanges. e. Foreign Tax: The custodian may be required to withhold foreign tax on dividend payments by f. foreign companies. Fund Management Fees: investments made in mutual funds, exchange traded funds and any other type of managed investment may incur management fees in addition to those levied by Peterson Investment Management, Inc. E. Fee Billing and Advisory Contract Termination: As covered in Item 5.B., management fees must be paid in advance. Should a client terminate advisory services, we will issue a prorated refund for the prepaid period not utilized. The refund calculation is made by taking the fee paid and multiplying by the fraction of the remaining days in the billing quarter. As per WAC 460-24A-145, clients are given five business days to terminate the agreement without penalty if they do not receive SEC Form ADV Part 2A-B within 48 hours of signing the agreement. Example of prorated refund: Based on a client’s March 31 portfolio value of $500,000, I billed a client’s custodian a $1,250 fee for the second quarter from Aril 1 to June 30. The custodian debits the $1,250 fee from the portfolio’s money-market fund and journals to Peterson Investment Management, Inc. On May 17, the client notifies Peterson Investment Management, Inc. that services are terminated. The client is due a refund for the 44 days of prepaid service from May 17 to June 30. Because the quarter contains 90 days, the client receives a refund of $611, which is calculated as $1,250 x (44/90). F. Other Compensation: Peterson Investment Management, Inc. and its employees do not receive compensation for the purchase or sale of securities or any other investment products. Item 6 Performance-Based Fees and Side-By-Side Management Page 7 Peterson Investment Management, Inc. and its employees do not accept performance-based fees – that is, fees based on a share of capital gains on or capital appreciation of the assets of a client’s portfolio. Item 7 Types of Clients Page 8 Peterson Investment Management, Inc. provides investment advisory services to the following account types: A. Individuals: a. Community Property accounts b. Custodial accounts c. Designated Beneficiary Plans accounts d. Estate accounts e. f. Individual accounts Individual Retirement Accounts i. Contributory IRAs ii. Inherited IRAs iii. Rollover IRAs iv. Roth IRAs v. SEP-IRAs vi. Spousal IRAs Joint Tenant accounts g. h. Trust accounts i. Generation Skipping Trusts ii. Irrevocable Living Trusts iii. Revocable Living Trusts iv. Survivor Trusts v. Testamentary Trusts B. Businesses: Corporate Peterson Investment Management, Inc. requires $1,000,000 in managed assets for new clients. The minimum may be met at the household level with multiple accounts. The adviser may, at its discretion, waive the new client minimum for those referred by existing clients. There is no minimum for maintaining accounts. Adviser reserves the right to reject prospective clients whom the adviser believes have unreasonable risk or return expectations or appear unlikely to reach and maintain financial security. The adviser’s ability to accept new clients also depends on the complexity of onboarding a prospective client and whether the time to onboard a new client would adversely affect the adviser’s existing client and firm responsibilities. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Page 9 A. Methods of analysis and investment strategies: I am an investor and thus think and behave differently from many other investment advisers that buy securities based on fads or speculation. I do not emphasize market-timing schemes but recognize that there are periods of volatility when the market is mispriced. There is no persuasive evidence that investors can time the market profitably since the market moves in ways that concentrate a significant portion of certain cycles' up performance in a short period of time. Numerous studies convincingly prove that to capture the best return, you must be and remain invested. I do not know what the market will do, but I do know that because stocks are risky, they have, over the long term, returned the greatest returns-- greater than bonds, money markets or gold. Keeping in mind that investing in securities involves risk of loss that clients should be prepared to bear, the best way to capture these risk-based returns is to be a long-term investor. I am skeptical of Wall Street’s ability to forecast company earnings. We use simple measures of valuation, which have demonstrated over time to be reliable indicators of undervalued securities. We concentrate on large, successful companies with a preference for persistent earnings growth. Management and markets served are important in arriving at conclusions on this critical point. I am interested in developing themes that may be driving forces in the economy. These trends may be related to demography, productivity enhancement derived from capital spending or changing consumer-spending patterns. Portfolios are balanced with select fixed-income holdings to tailor the account to meet the liquidity, safety, and income requirements of each individual client. B. Material risks involved with methods of analysis and investment strategies, reported alphabetically: a. Accounting Risk, the risk that the reported financial condition of a company is incorrectly stated. b. Interest Rate Risk, the risk that interest rates will change. Rising rates will cause existing bond prices to fall and may cause stock prices to decline also, as rising bond yields compete with stocks. c. Currency Risk, the risk that foreign exchange rates change and those securities we have invested in change in price because the currency that they are denominated in is rising or falling compared to other currencies. d. Commodity Risk, the risk that a company’s share price will rise or fall with the market price for its production. e. Disaster Risk, the risk of natural or man-made disasters affecting operations of companies that we have invested in. f. Equity Risk, the risk that security prices and /or the implied volatility will change. g. Management Risk, the risk that the share price of a company we have purchased stock in declines due to poor management or loss of management. h. Timing Risk, the risk that account assets will not be properly invested to participate in periods of market appreciation or properly sheltered during periods of market depreciation. C. Material risks involved with primary securities: I primarily invest in common stocks, which are subject to the risks listed in Item 8 B. Item 9 Disciplinary Information Page 10 There are no legal or disciplinary events to report for Peterson Investment Management, Inc. or for management persons. Item 10 Other Financial Industry Activities and Affiliations Page 11 Robb M. Peterson is also registered as an Investment Adviser Representative with Karel Capital, Inc., a Spokane, Washington Registered Investment Adviser. This registration is pursuant to an agreement between Peterson Investment Management, Inc. and Karel Capital, Inc. and is related to business continuity and succession for both firms. The dual registration allows Mr. Peterson to provide advisory services in support of Karel Capital, Inc. clients. Until such time that these support services are needed, Mr. Peterson does not provide any time serving Karel Capital, Inc. clients, and is not compensated for advisory services on behalf of Karel Capital, Inc. This arrangement has the possibility of conflicts of interest in that Mr. Peterson’s services may be required to assist clients of both firms simultaneously regarding trading. If the same security is traded for clients of both firms, the orders will be executed as a block order and allocated at an identical price across each firm’s client accounts. There are no other financial industry activities and affiliations to report for Peterson Investment Management, Inc. or for management persons. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Page 12 A. Peterson Investment Management, Inc. Code of Ethics: The client’s best interest is supreme: a. Custodian recommendations – When requested, we shall furnish prospective clients with three custodian recommendations. Please see Item 12.A. b. Custodian compensation – We shall not receive direct compensation from custodians for directing client trading to the custodian and shall minimize indirect compensation. Please see items 5.C.a and 14.A. c. Favoritism – There shall be no preference given to any client with respect to allocation of trades. When possible, client orders shall be aggregated and executed as one order, with the execution calculated at an average price that is allocated to all clients. d. Recordkeeping of Access Persons - i. Access persons must submit holdings reports within ten days of hire. ii. CCO must review reports of security holdings of all access persons upon submission. iii. Access persons must submit securities transaction reports on a quarterly basis. iv. Transaction reports are not required on: securities held in accounts over which access persons have no influence or control, automatic investment plans, mutual funds, or Unit Investment Trust (UIT) transactions. e. Trading – The client’s outcome is paramount to the interests of Peterson Investment Management, Inc. and its employees, family, friends, and associates. i. There shall be no “front running,” purchases and sales of securities for client portfolios shall be either aggregated with orders for the firm and employee accounts or shall precede order entry for firm and employee accounts. ii. There shall be no trading on “insider information.” Information received shall be researched to confirm whether it is considered material non-public information if there is consideration to trade in the shares of subject company. B. Financial Interest Conflicts of Interest: See 11.A.d C. See 11.A.d D. See 11.A.d Item 12 Brokerage Practices Page 13 A. Factors considered in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation: We seek to recommend a custodian who will hold your assets and execute transactions on terms that are, overall, most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others: • Combination of transaction execution services and asset custody services. • Capability to buy and sell securities for your account. • Capability to facilitate deposits, transfers, and withdrawals. • Breadth of available investment products. • Quality of services. • Competitiveness of commission costs and other account fees. • Reputation and financial strength. • Prior service to us and our clients. 1. Research and other soft dollar benefits – In connection with accounts custodied at Charles Schwab & Co., Inc., we receive numerous benefits, listed below in point v. We do not consider these benefits a conflict of interest because our clients’ institutional commission schedule is identical to Schwab’s retail commission schedule. i. These are typical services provided by a custodian to an adviser. When we use client brokerage commissions to obtain research or other products or services, we receive a benefit because we do not have to produce or pay for the research, products, or services. ii. There is a possible conflict of interest in that we may have an incentive to select or recommend a broker-dealer based on our interest in receiving the research or other products or services, rather than on our clients’ interest in receiving most favorable execution. iii. We have not caused our clients to pay commissions higher than those charged by other broker-dealers in return for soft dollar benefits. iv. We use soft dollar benefits to service all our clients’ accounts. v. Within our last fiscal year, we benefited with our relationship with Charles Schwab & Co. by receiving the following: 1. Publications and webinars on practice management, including compliance, industry changes, technology. 2. Free online access to: a. Continuing education courses to fulfill annual CE requirements. b. Research from Morningstar and Charles Schwab & Co., Inc. c. iRebal, a proprietary trading tool. We did not previously have a trading tool outside of our portfolio management software and will commence using iRebal in 2026. vi. In the last fiscal year, we did not direct client transactions to a particular broker- dealer in return for soft dollar benefits. 2. Brokerage for client referrals: Peterson Investment Management, Inc. does not consider, in selecting or recommending broker-dealers, whether it, or a related person, receives client referrals. 3. Directed Brokerage: Peterson Investment Management, Inc. does not recommend, request, or require that a client direct us to execute transactions through a specified broker-dealer. We may permit a client to direct brokerage but would have to evaluate the costs to the client and assess the likelihood of a favorable execution. We presently do not direct transactions away from our client portfolio custodians because the client’s portfolio would incur an additional trade expense. A discussion of order aggregation appears under 11.A.c-d. Item 13 Review of Accounts Page 14 A. Periodic account review: Client portfolios are reviewed by Robb M. Peterson. a. Daily transaction review and reconciliation: Each business day, Robb M. Peterson reviews all portfolio activity for the prior business day. Typical transactions include deposits, withdrawals, interest and dividend payments, and purchases and sales. Transactions are posted to client portfolios and the portfolio positions are reconciled against custodian records to ensure their data integrity. We may act on significant changes in money-market balances or current asset allocation versus targeted asset allocation. b. Daily investment and market review: Robb M. Peterson monitors daily prices for various market indices and all client holdings, as well as financial news. c. Weekly review of portfolio money-market balances and asset allocation. Robb M. Peterson reviews portfolio money fund balances and asset allocation versus target values. d. Quarterly portfolio review: Robb M. Peterson generates and reviews all client reporting. B. Non-periodic account review: Client portfolios are reviewed on a non-periodic basis when there are: a. Significant changes in the value of investments held or in overall market conditions. b. Significant changes in the client’s objectives. c. Client request for review. C. Client reporting: In addition to the client receiving reports of transactions made and monthly account statements, Peterson Investment Management, Inc. furnishes a quarterly newsletter and portfolio reports as of the last day of each quarter. The reports are typically mailed to clients within 15 days of quarter end. The reports include the following: a. Billing Statement b. Realized Gains and Losses c. Expense Report d. Performance Analysis e. Portfolio Statement Item 14 Client Referrals and Other Compensation Page 15 A. Economic benefits received from non-clients for servicing our clients: a. Employees of Peterson Investment Management, Inc. have benefited from paid meals while conducting business with agents of Charles Schwab & Co., Inc. and have attended business forums at the invitation and expense of Charles Schwab & Co., Inc. b. Employees of Peterson Investment Management, Inc. have benefited from paid meals, overnight lodging and travel reimbursement while attending meetings and conferences at the invitation and expense of First Trust. c. Employees of Peterson Investment Management, Inc. have benefited from an annual gift of Garrett Popcorn Shops popcorn from Chicago Clearing Corporation because adviser’s clients use the services of Chicago Clearing Corporation for class action claim submission and management. B. Client referrals: Peterson Investment Management, Inc. does not compensate any person or company for client referrals. Item 15 Custody Page 16 Under government regulations, Peterson Investment Management, Inc. is deemed to have custody of your assets if, for example, you authorize us to instruct your account custodian to deduct our advisory fees directly from your account, or if you grant us authority to move your money to another person’s account. Your custodian maintains actual custody of your assets. You will receive account statements directly from your account custodian at least quarterly. Depending on your account preferences, you will either receive the statement via United States Postal Service, or you will receive an email notifying you that you may login into your custodian account and view and download the statement. You should promptly review your statement(s). Upon production of your custodian’s accounts statement(s), I receive an email alerting me that I may download your statement(s) for archiving. This is our assurance that your custodian is mailing a statement to you or notifying you via email that your statement is available. Please inform me if you are not receiving the statement or the notification of statement availability. I also urge you to compare your custodian statement(s) to the quarterly reports you receive from us. Item 16 Investment Discretion Page 17 Peterson Investment Management, Inc. accepts and requires discretionary authority to manage securities accounts on behalf of clients. Please see Item 4.C for a discussion of customization of service and limitations that clients may place on my authority. Before we can commence investment management, we require the following items: A. Peterson Investment Management, Inc. Investment Advisory Agreement B. Peterson Investment Management, Inc. Investment Policy Statement C. Custodian Limited Power of Attorney Item 17 Voting Client Securities Page 18 Peterson Investment Management, Inc. has proxy voting responsibility for all clients at their election. Proxies are delivered to Peterson Investment Management, Inc. and voted by Robb Peterson in the manner, that in his judgment, best serves the client’s interests. Regarding voting for corporate officers and directors, Peterson Investment Management, Inc., absent any information that might be damaging to the current corporate management’s reputation, or failing Peterson Investment Management, Inc.’s express knowledge concerning any action that reasonably may be considered as resulting in fraud or malfeasance, will generally vote to elect the nominated officers and directors. The same reservation applies to nominations of accountants and other pro forma matters. Regarding issues of compensation of officers and directors, re-capitalization’s, share increases or matters relating to awards of stock options and other related share incentive programs, Peterson Investment Management, Inc. officers will generally vote proxies in accordance with management’s recommendations. Regarding individual shareholder resolutions, Peterson Investment Management, Inc. officers will vote proxies using their best judgment concerning the potential effect of such resolutions on their client’s best interest. In the event that a conflict of interest arises, wherein Peterson Investment Management, Inc. has a direct beneficial or financial interest concerning a proponent of a proxy resolution, or an interest of a commercial nature with a corporation issuing a proxy that Peterson Investment Management, Inc. has the responsibility to vote, such potential conflict of interest will be specifically revealed to the client, and approval of the intended proxy vote will be secured before any vote, or other election takes place. Records of such communications will be maintained. Records of proxy voting by Peterson Investment Management, Inc. will be kept and be available for client inspection at the office of Peterson Investment Management, Inc. for the prescribed six-year holding period. Please contact me should you wish to review voting records. Item 18 Financial Information Page 19 A. Peterson Investment Management, Inc. is not required to provide an audited balance sheet because it does not require or solicit prepayment of more than $1,200 in advisory fees per client, six months or more in advance. B. There is no financial condition that is reasonably likely to impair the ability of Peterson Investment Management, Inc. to meet contractual commitments to clients. C. Peterson Investment Management, Inc. has not been the subject of a bankruptcy petition at any time. Notice of Privacy of Consumer Financial Information Page 20 Congress passed the Gramm-Leach-Bliley Act in November 1999, with its main goal being the dismantling of the Glass-Steagall Act, allowing banks, brokers, and insurers to merge. The G-L-B Act also included a provision protecting consumers from privacy violations. This part of the G-L-B Act required seven federal agencies, including the Securities and Exchange Commission, to promulgate rules enforcing the statute. On June 22, 2000, the SEC released Regulation S-P, a rule intended to protect the privacy of nonpublic financial information about individuals. Regulation S-P requires federally regulated Registered Investment Advisers, among others, to adopt privacy policies governing their collection and use of nonpublic personal information about individuals, to inform certain individuals of their privacy policies, and to offer those individuals the opportunity to “opt out” of certain types of information sharing. Peterson Investment Management, Inc. (‘we”) is mandated to deliver this privacy notice to new clients and to render an annual offer of our privacy notice during the continuation of our relationship. Additionally, you are entitled to a revised privacy notice if we change our information disclosure practices. Maintaining your privacy is important to us. You have a right to know what information is being collected about you and how that information will be used. I collect nonpublic personal information about you but only possess that which you have provided to us. Sources include client contracts, questionnaires, brokerage account applications and from ongoing confidential discussions and from review and collection of personal financial documents that you may provide to me to aid you in acting as your financial adviser. I do not disclose your nonpublic personal information to anyone, except as permitted by law. Under the law, the information I collect is provided to companies that perform support services on my or your behalf as necessary to affect, administer, or process a transaction, or for maintaining and servicing your account. I will, at your request, share information with your other professional advisors, such as an attorney or CPA. I maintain physical, administrative, and technical safeguards to protect your nonpublic personal information. I restrict access to your nonpublic personal information about you to those employees who need to know that information to provide services to you. Discarded paper and electronic records are destroyed. The computer network is secured and restricted to employee access only. The office is secured when employees are not present. You do not need to contact me because of this notice. It is meant to inform you of how we safeguard your nonpublic personal information. Please call with any questions or concerns.

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