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PROVIDER FINANCIAL, INC.
FIRM BROCHURE
MARCH 5, 2025
Provider Financial, Inc.
3091 East 98th St., Suite 200
Indianapolis, IN 46280
Phone: (317) 706-0890
Email: robert.malmquist@provider-financial.com
Web Site: www.provider-financial.com
This brochure provides information about the qualifications and business practices of Provider
Financial, Inc. If you have any questions about the contents of this brochure, please contact Robert
Malmquist at (317) 706-0890. The information in this brochure has not been approved or verified
by the United States Securities and Exchange Commission or by any state securities authority.
Provider Financial, Inc. is a registered investment adviser. The registration of an Investment
Adviser does not imply any level of skill or training. The written communications of an Adviser
provide you with information about which you can use to determine whether to hire or retain an
Adviser.
Additional information about Provider Financial, Inc. is available on the SEC’s website
www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD
number. The CRD number for the Advisor is 168964.
2. MATERIAL CHANGES
We do not have any material changes to report since the most recent annual update on February 1,
2024.
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TABLE OF CONTENTS
Item 1. Cover Page .........................................................................................................................1
Item 2. Material Changes ..............................................................................................................2
Item 3. Table of Contents ..............................................................................................................3
Item 4. Advisory Business .............................................................................................................4
Item 5. Fees and Compensation ....................................................................................................5
Item 6. Performance-Based Fees and Side-By-Side Management ............................................8
Item 7. Types of Clients .................................................................................................................8
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss......................................8
Item 9. Disciplinary Information ................................................................................................10
Item 10. Other Financial Industry Activities and Affiliations .................................................10
Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading..........................................................................................................................................11
Item 12. Brokerage Practices ......................................................................................................12
Item 13. Review of Accounts .......................................................................................................13
Item 14. Client Referrals and Other Compensation .................................................................14
Item 15. Custody ..........................................................................................................................14
Item 16. Investment Discretion ...................................................................................................14
Item 17. Voting Client Securities ................................................................................................14
Item 18. Financial Information ...................................................................................................14
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4. ADVISORY BUSINESS
A. OWNERSHIP/ADVISOR HISTORY
Provider Financial, Inc. (“We”) was formed in October 2007 as an Indiana corporation. It was
subsequently registered as an Indiana investment adviser in 2013 and became SEC registered in
2018, We are owned by Robert L. Malmquist. Mr. Malmquist is the president and additional
information about Mr. Malmquist can be found in his supplemental brochure.
B. ADVISORY SERVICES OFFERED
Before we enter into an Adviser-Client relationship, we may offer a complimentary general
consultation to discuss services available, give a prospective client time to review services desired,
and determine whether a relationship might benefit the client. Investment advisory services begin
only after we and the client formalize the relationship with a properly executed agreement. We
offer the following services to our clients:
i.
FINANCIAL PLANNING SERVICES
We create a written financial plan that typically focuses on one or more specific areas such as
financial and cash management, risk management, financial issues relating to divorce or death of
a family member, tax issues, retirement planning, educational funding, goal setting, or other needs
identified by the client or by our review of the client’s financial circumstances. Through discussion
with the client and/or questionnaires, we will collect pertinent data, identify goals, objectives,
financial concerns and potential solutions. We will present the client with a written analysis.
Following the conclusion of the consulting services, we may make recommendations regarding
implementation of the financial strategies discussed.
ii.
PORTFOLIO MANAGEMENT SERVICES
We manage individualized portfolios for our clients on a discretionary basis through our wrap fee
program. We work with each client to formulate an individualized portfolio based upon his/her
objectives, time frame, risk parameters and other investment considerations. We use marketable
securities that can include mutual funds, exchange traded funds, stock and money markets
instruments. Our investment philosophy is to use principles of value, safety and quality to seek
investment options globally. Clients will be given a copy of our Appendix 1, which contains a
description of the service, the fee and any conflicts of interest associated.
C. TAILORED SERVICES
We tailor all of our services to the client’s stated goals, needs and objectives. For our portfolio
management service clients, we allow them to impose restrictions on investment in certain
securities or types of securities. All restrictions must be presented to us in writing.
D. WRAP PROGRAM
We are a portfolio manager for the Provider Financial Inc. Wrap Program. Please see Appendix
1 for details.
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E. CLIENTS ASSETS MANAGED
As of December 31, 2024, we manage approximately $281,000,000 in discretionary assets and $0
in nondiscretionary assets.
5. FEES AND COMPENSATION
A. FINANCIAL PLANNING
Our financial planning services are provided on an hourly fee basis. The hourly fee for a financial
plan is $350. The hourly fee rate is negotiable. Both the hourly rate and an estimate of the total
project fee (estimated hours multiplied by the agreed to hourly rate) are shown on the executed
Financial Planning Agreement. One half of the estimated Financial Planning fee is due before any
work on the plan (or research project) begins, with the other half due upon presentation of both the
final plan (or research project) and an invoice showing hours expended on the plan or project.
B. PORTFOLIO MANAGEMENT SERVICES
As disclosed above, our portfolio management services are only offered through our wrap-fee
program. The following description can also be found in Appendix 1 to this firm brochure. Fees
for portfolio management services will be based on a percentage of the assets under management.
The fee will be calculated, accrued and due quarterly in advance. The annual fee schedule is:
Custodian Reported
Value of Account
$100,000 to $250,000
$250,001 to $500,000
$500,001 to $750,000
$750,001 to $1,250,000
$1,250,001 to $1,750,000
$1,750,001 to $3,000,000
$3,000,001 to $5,000,000
Over $5,000,000
Management
Fee
2.05%
1.75%
1.60%
1.40%
1.30%
1.15%
1.00%
Negotiable
The fee is negotiable based upon the size of the client’s account(s). The pro-rated first quarter’s
management fee will be calculated on the Account’s initial value as reported by its custodian.
Thereafter, the periodic fee will be based upon the previous quarter-end Account as reported by
the client's custodian.
In a wrap account, clients pay a single annual advisory fee for advisory services and execution of
transactions. Clients do not pay brokerage commissions, markups or transaction charges for
execution of transactions in addition to the advisory fee. However, please see the following
disclosures regarding the conflicts of interest associated with a wrap-fee program.
Conflict of Interest Disclosure
Although clients do not pay a transaction charge for transactions in a SWM account, clients must
be aware that we pay LPL transaction charges for those transactions. The transaction charges paid
by us vary based on the type of transaction (e.g., mutual fund, equity or ETF) and for mutual funds
based on whether or not the mutual fund pays 12b-1 fees and/or recordkeeping fees to
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LPL. Transaction charges paid by us for equities and ETFs are $7. For mutual funds, the
transaction charges range from $0 to $26.50 depending on whether they pay a recordkeeping
and/or revenue sharing fee to LPL (Full Participating Fund versus Non-Participating Fund).
Because we pay the transaction charges in SWM accounts, there is a conflict of interest in cases
where the mutual fund is offered at both $0 and $26.50. Clients must understand that the cost to
us of transaction charges can be a factor that our considers when deciding which securities to select
and how frequently to place transactions in an SWM account. We attempt to mitigate this conflict
of interest by placing the clients’ interest ahead of our own through our fiduciary duty and by
implementing policies and procedures designed to address the conflict.
Other Types of Fees and Charges
Program accounts will incur additional fees and charges from parties other than us as noted below.
These fees and charges are in addition to the advisory fee paid to us. We do not share in any portion
of these third-party fees.
LPL, as the custodian and broker-dealer providing brokerage and execution services on program
accounts, will impose certain fees and charges. LPL notifies clients of these charges at account
opening and makes available a list of these fees and charges on its website at www.lpl.com. LPL
will deduct these fees and charges directly from the client’s program account.
There are other fees and charges that are imposed by other third parties that apply to investments
in program accounts. Some of these fees and charges are described below.
If a client’s assets are invested in mutual funds or other pooled investment products, clients
must be aware that there will be two layers of advisory fees and expenses for those assets.
Client will pay an advisory fee to the fund manager and other expenses as a shareholder of the
fund. Client will also pay us the advisory fee with respect to those assets. Most of the mutual
funds available in the program can be purchased directly. Therefore, clients could generally
avoid the second layer of fees by not using our management services and by making their own
investment decisions.
Certain mutual funds impose fees and charges such as contingent deferred sales charges, early
redemption fees and charges for frequent trading. These charges can apply if client transfers
into or purchases such a fund with the applicable charges in a program account.
Although only no-load and load-waived mutual funds can be purchased in a program account,
client must understand that some mutual funds pay asset-based sales charges or service fees
(e.g., 12b-1 fees) to the custodian with respect to account holdings.
If client holds a variable annuity as part of an account, there are mortality, expense and
administrative charges, fees for additional riders on the contract and charges for excessive
transfers within a calendar year imposed by the variable annuity sponsor.
Further information regarding fees assessed by a mutual fund, or variable annuity is available in
the appropriate prospectus, which is available upon request from us or from the product sponsor
directly.
Other Important Considerations
The advisory fee is an ongoing wrap fee for investment advisory services, the execution of
transactions and other administrative and custodial services. The advisory fee will cost the
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client more than purchasing the program services separately, for example, paying an advisory
fee plus commissions for each transaction in the account. Factors that bear upon the cost of
the account in relation to the cost of the same services purchased separately include the type
and size of the account, historical and or expected size or number of trades for the account, and
number and range of supplementary advisory and client-related services provided to the client.
The advisory fee will cost the client more than if assets were held in a traditional brokerage
account. In a brokerage account, a client is charged a commission for each transaction, and the
representative has no duty to provide ongoing advice with respect to the account. If the client
plans to follow a buy and hold strategy for the account or does not wish to purchase ongoing
investment advice or management services, the client should consider opening a brokerage
account rather than a program account.
When we recommend the program to the client, we receive compensation as a result of the
client’s participation in the program. This compensation includes the advisory fee and will also
include other compensation, such as bonuses, awards or other things of value offered by LPL
to us or our associated persons. The amount of this compensation will be more or less than
what we would receive if the client participated in other LPL programs, programs of other
investment advisors or paid separately for investment advice, brokerage and other client
services. Therefore, we will have a financial incentive to recommend a program account over
other programs and services.
The investment products available to be purchased in the program can be purchased by clients
outside of a program account, through broker-dealers or other investment firms not affiliated
with us.
Termination of Portfolio Management Services
A client may terminate the Investment Management Agreement for any reason at any time and,
within the first five (5) business days after signing the contract, without any cost or penalty.
Thereafter, the contract may be terminated at any time by giving ten (10) days written notice. To
cancel the Agreement, the client must notify firm in writing at to Provider Financial, Inc., 3091
East 98th St., Suite 200, Indianapolis, IN 46280 and return any materials received to that date.
Because we charge in advance, any client that terminates their contract within a quarter will receive
a prorated refund of fees that is based on the amount of time elapsed during the termination quarter.
For example, if a client cancels on 45 days in to a 90-day quarter, the client will receive a refund
of 50% of the fees. (45 days divided by 90 days equal 50 percent.) Please note the prorated refund
may be adjusted for additional deposits and withdrawals to the advisory account within the
termination quarter.
C. OTHER SECURITIES COMPENSATION
Our owner, Robert L. Malmquist, is also licensed as a registered representative of LPL Financial
Corporation (“LPL”), a full-service broker/dealer and member FINRA/SIPC. As a registered
representative, Mr. Malmquist can affect securities transactions and he receives separate
compensation for effecting any securities transactions. Mr. Malmquist spends the majority of his
time involved these activities.
This presents a conflict of interest when the client elects to implement Mr. Malmquist’s
recommendations and selects him to execute those transactions. In this case, Mr. Malmquist
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receives both fees as advisor representative and commissions as registered representative or
insurance agents. As a registered representative, he receives compensation from the sale of mutual
funds, 12(b)-1 distribution fees, variable annuity sales commissions or trail commissions. The
12(b)-1 distribution fees, sales charges and other fee arrangements will be disclosed upon the
client’s request and are typically described in the applicable fund and/or annuity prospectus. Any
fees or other compensation received by Mr. Malmquist in his separate capacity as registered
representative will be received to the extent permitted by applicable law.
Because of these compensation arrangements, a conflict of interest exists in connection with Mr.
Malmquist recommending particular investments for a client’s account. Clients have sole
discretion whether to implement any or all of Mr. Malmquist’s recommendations. In addition,
clients are free to select any broker/dealer they wish to implement recommendations.
D. TERMINATION OF SERVICES
A client may terminate their agreement with us for any reason within the first five (5) business
days after signing the agreement and receive 100% refund of any prepaid fees without any cost or
penalty. Thereafter, the contract may be terminated at any time by giving ten (10) days written
notice to us at Provider Financial, Inc., 3091 East 98th St., Suite 200, Indianapolis, IN 46280. Upon
written notice of termination, the client will receive a prorated refund of any prepaid fees based
upon a percentage of work completed and the client agrees to pay us for any expended time which
exceeds the prepaid amount. For example, if a client cancels on 45 days in to a 90-day quarter, the
client will receive a refund of 50% of the fees. (45 days divided by 90 days equal 50 percent.)
Please note the prorated refund may be adjusted for additional deposits and withdrawals to the
advisory account within the termination quarter.
6. PERFORMANCE-BASED FEES AND SIDE BY SIDE MANAGEMENT
We do not charge any performance-based fees (fees based on a share of capital gains on or capital
appreciation of the assets of a client).
7. TYPES OF CLIENTS
Our services are offered to individuals and high net worth individuals. We do not require a
minimum account size prior to becoming a client.
8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
A. METHODS OF ANALYSIS AND INVESTMENT STRATEGIES
When we manage a client’s portfolio, we use the following types of analysis:
Fundamental analysis is a technique that attempts to determine a security’s value by focusing on
underlying factors that affect a company's actual business and its future prospects. The analysis is
performed on historical and present data. On a broader scope, one can perform fundamental
analysis on industries or the economy as a whole. The term refers to the analysis of the economic
well-being of a financial entity as opposed to only its price movements. The risk associated with
fundamental analysis is that despite that appearance that a security is undervalued, it may not rise
in value as predicted.
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Technical Analysis is a method of evaluating securities by analyzing statistics generated by market
activity, such as past prices and volume. Technical analysts do not attempt to measure a security's
intrinsic value, but instead use charts and other tools to identify patterns that can suggest future
activity. The risk associated with technical analysis is that there is no broad consensus among
technical traders on the best method of identifying future price movements.
Tactical Asset Allocation is an active management portfolio strategy that rebalances the percentage
of assets held in various categories in order to take advantage of market pricing anomalies or strong
market sectors. This strategy is designed to allow portfolio managers to create extra value by
taking advantage of certain situations in the marketplace. It is as a moderately active strategy
because portfolio managers return to the portfolio's original strategic asset mix when desired short-
term profits are achieved.
Our analysis of securities and advice relating thereto may be based upon information obtained
from financial newspapers and magazines, research materials prepared by others, corporate ratings
services, and annual reports, prospectuses and filings made with the Securities and Exchange
Commission. We also utilize computer models for performance analysis, asset allocation and risk
management.
B. RECOMMENDED SECURITIES AND INVESTMENT RISKS
We may use several types of securities in our clients’ accounts. These securities may include, but
are not limited to, the following: Exchange Traded Funds; Mutual Funds; Stocks; and Money
Market Funds and Cash.
All investments bear different types and degrees of risk and investing in securities involves risk
of loss that clients should be prepared to bear. While we use investment strategies that are
designed to provide appropriate investment diversification, some investments have significantly
greater risks than others. Obtaining higher rates of return on investments entails accepting higher
levels of risk. Recommended investment strategies seek to balance risks and rewards to achieve
investment objectives. A client needs to ask questions about risks he/she does not understand we
would be pleased to discuss them.
We strive to render our best judgment on behalf of our clients. Still, we cannot assure or guarantee
clients that investments will be profitable or assure that no losses will occur in an investment
portfolio. Past performance is an important consideration with respect to any investment or
investment adviser but is not a reliable predictor of future performance. We continuously strive
to provide outstanding long-term investment performance, but many economic and market
variables beyond our control can affect the performance of an investment portfolio.
An investment could lose money over short or even long periods. A client should expect his/her
account value and returns to fluctuate within a wide range, like the fluctuations of the overall stock
and bond markets. A client’s account performance could be hurt by:
Stock market risk: The chance that stock prices overall will decline. Stock markets tend
to move in cycles, with periods of rising stock prices and periods of falling stock prices.
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Interest rate risk: The chance that bond prices overall will decline because of rising
interest rates.
Manager risk: The chance that the proportions allocated to the various securities will
cause the client’s account to underperform relevant to benchmarks or other accounts with
a similar investment objective.
International investing risk: Investing in the securities of non-U.S. companies involves
special risks not typically associated with investing in U.S. companies. Foreign securities
tend to be more volatile and less liquid than investments in U.S. securities, and may lose
value because of adverse political, social or economic developments overseas or due to
changes in the exchange rates between foreign currencies and the U.S. dollar. In addition,
foreign investments are subject to settlement practices, as well as regulatory and financial
reporting standards, that differ from those of the U.S.
Liquidity risk: One common risk associated with private placements and REITs is a
relative lack of liquidity due to the highly customized nature of the investment. Moreover,
the full extent of returns is often not realized until maturity. Because of this, these products
tend to be more of a buy-and-hold investment decision rather than a means of getting in
and out of a position with speed and efficiency.
Credit risk: This is the risk that an issuer of a bond could suffer an adverse change in
financial condition that results in a payment default, security downgrade, or inability to
meet a financial obligation.
Inflation Risk: This is the risk that inflation will undermine the performance of your
investment and/or the future purchasing power of your assets.
9. DISCIPLINARY INFORMATION
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events within the past 10-years that would be material to your evaluation of the
Adviser or the integrity of its management. We have no information applicable to this Item
because we have not been the subject of any administrative, civil, criminal or regulatory
proceedings.
10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
A. BROKER DEALER AFFILIATION
Our owner, Mr. Malmquist, is a registered representative of LPL Financial, LLC. Please see Item
5.C for additional details.
B. FUTURES/COMMODITIES FIRM AFFILIATION
We are not affiliated with a futures or commodities broker.
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C. OTHER INDUSTRY AFFILIATIONS
Mr. Malmquist is a licensed independent insurance agent (Life and Health Licensed). As such, he
is able to affect insurance transactions and receives separate compensation for effecting any
insurance transactions. With the ability to work as a client’s insurance agent and investment
adviser representative, this is a conflict of interest because each service pays a separate fee or
commission. However, Mr. Malmquist attempts to mitigate any conflicts of interest to the best of
his ability by placing the client’s interests ahead of his own and through the implementation of
policies and procedures that address the conflict. Also, clients are never obligated to purchase
recommended insurance products through Mr. Malmquist.
D. SELECTION AND MONITORING OF THIRD-PARTY INVESTMENT ADVISERS
We do not selection and monitor third party investment advisers.
11. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND
PERSONAL TRADING
A. DESCRIPTION
Our Code of Ethics establishes ideals for ethical conduct upon fundamental principles of openness,
integrity, honesty, and trust. We will provide a copy of our Code of Ethics to any client or
prospective client upon request.
Our Code of Ethics covers all supervised persons, and it describes its high standard of business
conduct, and fiduciary duty to our clients. The Code of Ethics Includes provisions relating to the
confidentiality of client information, a prohibition on insider trading, a prohibition of rumor
mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and
business entertainment items, and personal securities trading procedures, among other things. All
of our supervised persons must acknowledge the terms of the Code of Ethics annually, or as
amended.
B. MATERIAL INTEREST IN SECURITIES
We do not have a material financial interest in any securities.
C. INVESTING IN OR RECOMMENDING THE SAME SECURITIES
On occasion, our owner and investment adviser representatives may buy or sell for their own
accounts securities that are the same as, similar to, or different than those that they recommend to
their clients for purchase or sale. Differences will arise due to variations in personal goals,
investment horizons, risk tolerance, and the timing of purchases and sales. We attempt to mitigate
the conflict of interest to the best of our ability through the enactment of our code of ethics, trading
policies, and its fiduciary responsibilities. Nonetheless, we generally attempt to place client
transactions ahead of proprietary trades. Our associates are aware of their fiduciary duty to our
clients and the prohibitions against the use of any insider information. Records of all associates'
proprietary trading activities will be kept, available to regulators to review on the premises.
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12. BROKERAGE PRACTICES
A. RECOMMENDATION CRITERIA
For client accounts that we manage, we will seek broker-dealers and custodians who offer
competitive commission costs together with reliable services. A client’s choice of another broker-
dealer is acceptable if proven feasible. We recognize our fiduciary responsibility in negotiating
brokerage commissions, assuring best execution practices and assuring adequate investment
availability/inventory on behalf of our clients. However, we do not retain discretionary authority
to select the broker-dealer used for transaction, or to set commission rates. We do not receive
compensation with respect to execution of these trades. In some instances, a client may incur a
ticket charge for the sale or purchase of securities. We will ensure all broker-dealers and custodians
are properly registered in the state of where the client resides prior to making the recommendation.
i. RESEARCH AND SOFT DOLLARS
“Soft dollars” are defined as a form of payment investment firms can use to pay for goods and
services such as news subscriptions or research. When an investment firm gives its business to a
particular brokerage firm, the brokerage firm in return can agree to use some of its revenue to pay
for these types of services. In order to stem the potential conflicts of interest that may arise from
“soft dollar” arrangements, we pursue a policy of not entering into any such arrangements, either
orally or in writing.
However, we receive support services and/or products from LPL Financial, many of which assist
us to better monitor and services program accounts maintained at LPL Financial; however, some
of the services and products benefit us and not the client accounts. These support services and/or
products can be received without cost, at a discount, and/or at a negotiated rate, and can include
but not limited to the following:
investment-related research
pricing information and market data
software and other technology that provides access to client account data
compliance and/or practice management-related publications
consulting services
attendance at conferences, meetings and other education and/or social events
marketing support
computer hardware and/or software
other products and services used by us in furtherance of our investment advisory
business operations
LPL Financial can provide these services and products directly or can arrange for third-party
vendors to provide the services or products to us. In the case of third-party vendors, LPL Financial
can pay for some or all of the third-party’s fees.
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These support services are provided to us based on the overall relationship between our firm and
LPL Financial. It is not the result of soft dollar arrangements or any other express arrangements
with LPL Financial that involves the execution of client transactions as a condition to the receipt
of these services. We will continue to receive these services regardless of the volume of client
transactions executed with LPL Financial. Clients do not pay more for services as a result of the
arrangement. However, because we receive these benefits from LPL Financial, there is a potential
conflict of interest. The receipt of these products and services presents a financial incentive for us
to recommend that our clients use LPL Financials’ custodial platform rather than another
custodian’s platform.
ii. BROKERAGE FOR CLIENT REFERRALS
We do not receive client referrals or any other Incentive from any custodian or any third party.
iii. DIRECTED BROKERAGE
We do not allow client to direct us to a specific broker-dealer to execute securities transactions for
their accounts. However, we do not retain discretionary authority to select the broker-dealer used
for transaction, or to set commission rates.
B. TRADE AGGREGATION
We will aggregate orders with respect to the same security purchased for different clients. When
orders are aggregated, each participating account receives the average share price for the
transaction and bears a proportionate share of all transaction costs, based upon each account’s
participation in the transaction, subject to our discretion depending on factual or market conditions.
Clients participating in block trading can include proprietary or related accounts. Such accounts
are treated as client accounts and are neither given preferential nor inferior treatment versus other
client accounts. Allocations of orders among client accounts must be made in a fair and equitable
manner.
13. REVIEW OF ACCOUNTS
A. PERIODIC REVIEWS
Our owner, Robert Malmquist, reviews the positions on a continuous basis. Mr. Malmquist will
also meet (either in person or by telephone) with a client on a quarterly, semi-annual or annual
basis as requested by the client.
B. OTHER REVIEWS
Additional reviews are conducted periodically depending on market conditions, economic or
political events, or by changes in a client’s financial situation (such as retirement, termination of
employment, physical move or inheritance).
C. REPORTS
The client will receive at least a quarterly statement(s) and yearly performance report(s) from the
account’s custodian. We urge you to carefully review such statements.
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14. CLIENT REFERRALS AND OTHER COMPENSATION
A. OTHER COMPENSATION
We do not receive extra compensation or any other economic benefit for providing investment
advice or other advisory services to clients.
B. CLIENT REFERRALS
We do not pay for client referrals or use solicitors.
15. CUSTODY
All client funds, securities and accounts are held at third-party custodians. We do not take
possession of a client’s securities.
16. INVESTMENT DISCRETION
We offer discretionary portfolio management services. All discretionary Portfolio Management
clients sign an investment management agreement that contains a limited power of attorney
granting us discretionary power over the account. In discretionary accounts, we will be allowed to
place trades, buy or sell securities of any type and in amounts it deems to be appropriate for the
account, without first obtaining the client’s consent to each trade. Directions will be given to the
account custodian to complete the transaction.
17. VOTING CLIENT SECURITIES
We will not be responsible for responding to proxies that are solicited with respect to securities
held in clients' accounts under our Portfolio Management Services. Proxy solicitation materials
will be forwarded to clients directly from the custodian for response and voting. In the event a
client has a question about a proxy solicitation, the client should contact his/her investment adviser
representative.
18. FINANCIAL INFORMATION
A. BALANCE SHEET
We do not require or solicit prepayment of more than $1200 in fees per client, six months or more
in advance. Therefore, we are not required to provide a balance sheet.
B. FINANCIAL CONDITION
Registered investment advisers are required in this Item to provide you with certain financial
information or disclosures about our financial condition. We have no financial commitment that
impairs its ability to service our clients.
C. BANKRUPTCY
We have not been the subject of a bankruptcy proceeding.
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