Schauer Investment Management, Inc.

Schauer Investment Management, Inc. Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Schauer Investment Management, Inc.. If you have any questions about the contents of this brochure, please contact us at (818) 727- 9960 or by email at: craig@cschauercpa.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Schauer Investment Management, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. Schauer Investment Management, Inc.’s CRD number is: 283119. 17024 Lassen St. Northridge, CA, 91325 (818) 727-9960 craig@cschauercpa.com Schauer Investment Management, Inc. is a registered investment adviser. Registration does not imply a certain level of skill or training. Version Date: 06/17/2026 i  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of Schauer Investment Management, Inc. on 03/23/2026 are described below. Material changes relate to Schauer Investment Management, Inc. policies, practices or conflicts of interests only. • Schauer Investment Management, Inc. is transitioning to registration with the United States Securities and Exchange Commission from its prior registration at the state level. • Schauer Investment Management, Inc. updated its Assets Under Management (Item 4). • Schauer Investment Management, Inc. updated its Investment Discretion Disclosure (Item 16). i  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ........................................................................................................................................ i Item 3: Table of Contents ....................................................................................................................................... ii Item 4: Advisory Business ......................................................................................................................................1 A. Description of the Advisory Firm ................................................................................................................1 B. Types of Advisory Services ...........................................................................................................................1 C. Client Tailored Services and Client Imposed Restrictions ........................................................................2 D. Wrap Fee Programs ........................................................................................................................................2 E. Assets Under Management ............................................................................................................................2 Item 5: Fees and Compensation .............................................................................................................................2 A. Fee Schedule ....................................................................................................................................................2 B. Payment of Fees ...............................................................................................................................................3 C. Client Responsibility For Third Party Fees .................................................................................................3 D. Prepayment of Fees ........................................................................................................................................4 E. Outside Compensation For the Sale of Securities to Clients .....................................................................4 Item 6: Performance-Based Fees and Side-By-Side Management ....................................................................4 Item 7: Types of Clients ..........................................................................................................................................4 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ............................................................5 A. Methods of Analysis and Investment Strategies ..................................................................................5 B. Material Risks Involved ...........................................................................................................................5 C. Risks of Specific Securities Utilized ........................................................................................................6 Item 9: Disciplinary Information ...........................................................................................................................7 A. Criminal or Civil Actions .........................................................................................................................7 B. Administrative Proceedings ....................................................................................................................7 C. Self-regulatory Organization (SRO) Proceedings .................................................................................7 Item 10: Other Financial Industry Activities and Affiliations ...........................................................................7 A. Registration as a Broker/Dealer or Broker/Dealer Representative ..................................................7 Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity B. Trading Advisor ..................................................................................................................................................8 ii  Registration Relationships Material to this Advisory Business and Possible Conflicts of C. Interests .................................................................................................................................................................8 D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ..............................................................................................................................................................8 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................8 A. Code of Ethics ............................................................................................................................................8 B. Recommendations Involving Material Financial Interests .................................................................9 C. Investing Personal Money in the Same Securities as Clients ..............................................................9 D. Trading Securities At/Around the Same Time as Clients’ Securities ...............................................9 Item 12: Brokerage Practices ..................................................................................................................................9 A. Factors Used to Select Custodians and/or Broker/Dealers ...............................................................9 1. Research and Other Soft Dollar Benefits .......................................................................................... 10 2. Brokerage for Client Referrals ........................................................................................................... 10 3. Clients Directing Which Broker/Dealer/Custodian to Use .......................................................... 10 B. Aggregating (Block) Trading for Multiple Client Accounts ............................................................. 10 Item 13: Review of Accounts ................................................................................................................................ 11 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews .............................. 11 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts............................................ 11 C. Content and Frequency of Regular Reports Provided to Clients ..................................................... 11 Item 14: Client Referrals and Other Compensation .......................................................................................... 11 Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales A. Awards or Other Prizes) ................................................................................................................................... 11 B. Compensation to Non – Advisory Personnel for Client Referrals ................................................... 11 Item 15: Custody .................................................................................................................................................... 12 Item 16: Investment Discretion ............................................................................................................................ 12 Item 17: Voting Client Securities ......................................................................................................................... 12 Item 18: Financial Information ............................................................................................................................. 13 A. Balance Sheet ........................................................................................................................................... 13 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients .................................................................................................................................................................. 13 C. Bankruptcy Petitions in Previous Ten Years ....................................................................................... 13 iii  Item 4: Advisory Business A. Description of the Advisory Firm Schauer Investment Management, Inc. (hereinafter “SI”) is a Corporation organized in the State of California. The firm was formed in February 2016, and the principal owner is Craig Schauer. B. Types of Advisory Services Portfolio Management Services SI offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. SI creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring SI evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. SI will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. SI seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of SI’s economic, investment or other financial interests. To meet its fiduciary obligations, SI attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, SI’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is SI’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Services Limited to Specific Types of Investments SI generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), equities and non-U.S. securities, although SI primarily  recommends equities to a majority of its clients. SI may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions SI offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent SI from properly servicing the client account, or if the restrictions would require SI to deviate from its standard suite of services, SI reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. SI does not participate in any wrap fee programs. E. Assets Under Management SI has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 119,744,010.00 $ 0.00 March 2026 Item 5: Fees and Compensation Lower fees for comparable services may be available from other sources. A. Fee Schedule Asset-Based Fees for Portfolio Management Total Assets Under Management Annual Fee $0 - $1,000,000 1.50% $1,000,001 - And Up 1.00% These fees are generally negotiable and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Clients may terminate the agreement without penalty for a full refund of SI's fees within five business days of signing the Investment Advisory 2  Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 30 days' written notice. SI uses an average of the quarterly balance in the client's account throughout the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. Performance-Based Fees for Portfolio Management Qualified clients will pay an annual fee of 1.00% of assets under management along with a 15.00% performance fee based on capital appreciation. If the portfolio rises in value at least an 8-percent return for the calendar year, then the client will pay 15% on that increase in value, but if the portfolio drops in value, then the client will not incur a new performance fee until the portfolio reaches the last highest value, adjusted for withdrawals and deposits, which is generally known as a “high water mark”. These fees are generally negotiable and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. This service may be canceled with 30 days’ notice. Clients must pay the prorated performance-based fees for the billing period in which they terminate the Investment Advisory Contract up to and including the day of termination. B. Payment of Fees Payment of Asset-Based Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis, or may be invoiced and billed directly to the client on a quarterly basis. Clients may select the method in which they are billed. Fees are paid in arrears. Payment of Performance-Based Portfolio Management Fees Performance-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis, or may be invoiced and billed directly to the client on a quarterly basis. Clients may select the method in which they are billed. Fees are paid in arrears. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by SI. Please see Item 12 of this brochure regarding broker-dealer/custodian. 3  D. Prepayment of Fees SI collects its fees in arrears. It does not collect fees in advance. E. Outside Compensation For the Sale of Securities to Clients Neither SI nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management SI manages accounts that are billed on performance-based fees (a share of capital gains on or capital appreciation of the assets of a client) and may as well manage accounts that are not billed on performance-based fees. Managing both kinds of accounts at the same time presents a conflict of interest because SI and/or its supervised persons have an incentive to favor accounts for which SI receives a performance-based fee. SI addresses the conflicts by ensuring that clients are not systematically advantaged or disadvantaged due to the presence or absence of performance- based fees. SI seeks best execution and upholds its fiduciary duty for all clients. Clients paying a performance-based fee should be aware that investment advisers have an incentive to invest in riskier investments when paid a performance-based fee due to the higher risk/higher reward attributes. Item 7: Types of Clients SI generally provides advisory services to the following types of clients: ❖ Individuals ❖ High-Net-Worth Individuals ❖ Pension and Profit Sharing Plans ❖ Pooled Investment Vehicles Minimum Account Size There is no account minimum for any of SI’s services. 4  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis SI’s methods of analysis include fundamental analysis. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Investment Strategies SI uses long term trading, margin transactions and options trading (including covered options, uncovered options, or spreading strategies). Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Investment Strategies SI's use of margin transactions and options trading generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those strategies. Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Margin transactions use leverage that is borrowed from a brokerage firm as collateral. When losses occur, the value of the margin account may fall below the brokerage firm’s threshold thereby triggering a margin call. This may force the account holder to either allocate more funds to the account or sell assets on a shorter time frame than desired. 5  Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized SI's use of margin transactions and options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Real Estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real 6  estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option transactions also involve risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither SI nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. 7  B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither SI nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Craig James Schauer is the manager of Sage Investments, LP, a private fund. SI will recommend investments in this private fund to those clients for which investment in the fund is suitable. This presents a conflict of interest in that SI or its related persons may receive more compensation from investment in the fund than from other investments. Nevertheless, SI acts in the best interest of the client consistent with its fiduciary duties and clients are not required invest in the private fund if they do not wish to do so. Craig James Schauer is an accountant. In this capacity, neither Mr. Schauer nor a related accounting firm has signatory authority for client accounts. From time to time, may offer clients advice or products from those activities and clients should be aware that these services may involve a conflict of interest. SI always acts in the best interest of the client and clients are in no way required to utilize the services of any representative of SI in connection with such individual’s activities outside of SI. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections SI does not utilize nor select third-party investment advisers. All assets are managed by SI management. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics SI has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual 8  Review, and Sanctions. SI's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests Craig James Schauer is the manager of Sage Investments, LP, a private fund. SI will recommend investments in this private fund to those clients for which investment in the fund is suitable. This presents a conflict of interest in that SI or its related persons may receive more compensation from investment in the fund than from other investments. Nevertheless, SI acts in the best interest of the client consistent with its fiduciary duties and clients are not required invest in the private fund if they do not wish to do so. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of SI may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of SI to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. SI will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of SI may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of SI to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, SI will never engage in trading that operates to the client’s disadvantage if representatives of SI buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers the market expertise and research access provided by Custodians/broker-dealers will be recommended based on SI’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and SI may also the broker- consider dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources 9  provided by the brokers that may aid in SI's research efforts. SI will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. SI recommends Schwab Institutional, a division of Charles Schwab & Co., Inc. 1. Research and Other Soft Dollar Benefits While SI has no formal soft dollars program in which soft dollars are used to pay for third party services, SI may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). SI may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and SI does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. SI benefits by not having to produce or pay for the research, products or services, and SI will have an incentive to recommend a broker- dealer based on receiving research or services. Clients should be aware that SI’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals SI receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use SI may permit clients to direct it to execute transactions through a specified broker- dealer. If a client directs brokerage, then the client will be required to acknowledge in writing that the client’s direction with respect to the use of brokers supersedes any authority granted to SI to select brokers; this direction may result in higher commissions, which may result in a disparity between free and directed accounts; the client may be unable to participate in block trades (unless SI is able to engage in “step outs”); and trades for the client and other directed accounts may be executed after trades for free accounts, which may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Not all investment advisers allow their clients to direct brokerage. B. Aggregating (Block) Trading for Multiple Client Accounts If SI buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, 10  or more efficient execution. In such case, SI would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. SI would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for SI's advisory services provided on an ongoing basis are reviewed at least quarterly by Craig Schauer, President, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at SI are assigned to this reviewer. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client of SI's advisory services provided on an ongoing basis will receive a monthly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. SI will also provide at least quarterly a separate written statement to the client upon their request. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) SI does not receive any economic benefit, directly or indirectly from any third party for advice rendered to SI's clients. B. Compensation to Non – Advisory Personnel for Client Referrals SI does not directly or indirectly compensate any person who is not advisory personnel for client referrals. 11  Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, SI will be deemed to have limited custody of client's assets. Because client fees will be withdrawn directly from client accounts, SI will: (A) Possess written authorization from the client to deduct advisory fees from an account held by a qualified custodian. (B) Send the qualified custodian written notice of the amount of the fee to be deducted from the client’s account and verify that the qualified custodian sends invoices to the client. (C) Send the client a written invoice itemizing the fee upon or prior to fee deduction, including the formula used to calculate the fee, the time period covered by the fee and the amount of assets under management on which the fee was based. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Clients are urged to compare the account statements they received from custodian with those they received from SI. Item 16: Investment Discretion SI provides discretionary investment advisory services to clients. The Investment Advisory Contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, SI generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. SI will also have discretionary authority to determine the broker dealer to be used for a purchase or sale of securities for a client's account. Item 17: Voting Client Securities SI acknowledges its fiduciary obligation to vote proxies on behalf of those clients that have delegated to it, or for which it is deemed to have, proxy voting authority. SI will vote proxies on behalf of a client solely in the best interest of the relevant client and has established general guidelines for voting proxies. SI may also abstain from voting if, based on factors such as expense or difficulty of exercise, it determines that a client’s interests are better served by abstaining. Further, because proxy proposals and individual company facts and circumstances may vary, SI may vote in a manner that is contrary to the general guidelines if it believes that doing so would be in a client’s best interest to do so. If a proxy proposal presents a conflict of interest between SI and a client, then SI will disclose the conflict of interest to the client prior to the proxy vote and, if participating in the vote, will vote in accordance with the client's wishes. 12  Clients may obtain a complete copy of the proxy voting policies and procedures by contacting SI in writing and requesting such information. Each client may also request, by contacting SI in writing, information concerning the manner in which proxy votes have been cast with respect to portfolio securities held by the relevant client during the prior annual period. Item 18: Financial Information A. Balance Sheet SI neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither SI nor its management has any financial condition that is likely to reasonably impair SI’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years SI has not been the subject of a bankruptcy petition in the last ten years. 13