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)
| Min | Max | Marginal 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 Assets | Annual Fees | Average 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)
View Document Text
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.