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ADV Part 2A: Firm Brochure
Schwartz & Co.
3707 West Maple Road
Bloomfield Hills, MI 48301
(248) 644-2701
www.GJSCO.com
March 15, 2026
This brochure provides information about the qualifications and business practices of Schwartz & Co (“Adviser”, the
“Firm”, “we”). If you have any questions about the contents of this brochure, please contact us at (248) 644-2701.
The information in this brochure has not been approved or verified by the United States Securities and Exchange
Commission (“SEC”) or by any state securities authority.
Additional information about Schwartz & Co. (CRD# 7294) is also available on the SEC’s website at
www.adviserinfo.sec.gov
Schwartz & Co. is registered as an investment adviser with the SEC. Registration does not imply a certain level of
skill or training.
ITEM 2: MATERIAL CHANGES
The following is a summary of material changes that have been made to our ADV Part 2A Firm Brochure since
our last annual updating amendment, dated March 15, 2025:
•
Item 4: Advisory Business – This section has been updated to include language about the RBC
Unified Portfolio (“RBC UP”) program.
•
Item 4: Advisory Business – This section has been updated to remove The Stag Group from the
discretionary assets as the pooled investment fund has been closed.
•
Item 5: Fees and Compensation – This section has been updated to include language about the RBC
Unified Portfolio (“RBC UP”) program fees.
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ITEM 3: 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 ................................................................................................................................ 8
Item 6: Performance-Based Fee and Side-by-Side Management ............................................................................ 10
Item 7: Types of Clients .......................................................................................................................................... 11
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................................................... 11
Item 9: Disciplinary Information ............................................................................................................................. 12
Item 10: Other Financial Industry Activities and Affiliations ................................................................................. 13
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................ 14
Item 12: Brokerage Practices ................................................................................................................................... 15
Item 13: Review of Accounts .................................................................................................................................. 16
Item 14: Client Referrals and Other Compensation ................................................................................................ 16
Item 15: Custody ..................................................................................................................................................... 16
Item 16: Investment Discretion ............................................................................................................................... 16
Item 17: Voting Client Securities ............................................................................................................................ 17
Item 18: Financial Information ................................................................................................................................ 17
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ITEM 4: ADVISORY BUSINESS
Description of Advisory Firm
Schwartz & Co., founded in 1976 by Gregory J. Schwartz, Sr., is an SEC registered investment adviser and
licensed broker-dealer. Schwartz Holdings, LLC is the 100% owner of Schwartz & Co. Gregory J. Schwartz, Sr.
serves as Chairman of the Board and his five sons, Gregory J. Schwartz, Jr., Walter G. Schwartz, Joseph E.
Schwartz, Edward A. Schwartz, and Peter F. Schwartz serve as officers and principals.
Types of Advisory Services
Schwartz & Co. offers advisory and consulting services to individuals, high net worth individuals, institutional
retirement plans, trusts, estates, charitable organizations, corporations, and other business entities.
Wealth Management Services
Schwartz & Co. provides ongoing advisory services to wealth management clients. Services may be provided on a
discretionary or non-discretionary basis. Individualized client services are determined during initial conversations
and updated over the course of the relationship as needed or requested by the client.
Schwartz & Co. works closely with each client to determine the client’s needs, goals, objectives, time horizons,
risk tolerance and any other relevant information. This information is used in developing an effective investment
strategy suitable for the client.
Prior to engaging Schwartz & Co. to provide advisory services, each client is required to enter into a written
agreement with the Adviser that defines the terms, conditions, scope of services, discretionary/non-discretionary
authority, advisory fees, and other important disclosures. Clients may impose reasonable restrictions on investing
in certain securities, types of securities, or industry sectors. Based upon information provided by the client, and
with the client’s input, we provide the following services:
•
Investment Objectives – Adviser will assist the client in determining investment goals and objectives
along with the broad strategy or strategies to be employed.
• Asset Allocation – Adviser will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation, and tolerance for risk for each client. Adviser will provide
ongoing monitoring of asset allocation to assess appropriateness of current holding mix.
• Portfolio Construction – Adviser will develop a portfolio of investments for the client that is intended to
meet the stated goals and objectives of the client.
Based on the client’s situation and needs, Adviser may also provide initial or ongoing financial planning services
to assist the client in meeting financial goals. Financial planning may address specific client needs such as
retirement planning, tax planning, charitable planning, succession planning, risk management, education funding,
major purchases, business planning and estate planning. These services are individually negotiated with the client
and confirmed in the agreement.
Adviser will monitor the client’s account on an ongoing basis and conduct periodic portfolio reviews with the
client. Adviser will attempt to meet with clients at least annually to discuss the client’s investment needs, goals
and objectives. Adviser will also review the client’s account performance and the continued suitability of
investments. Clients must notify Schwartz & Co. promptly of any material change in financial circumstances or
investment objectives which might affect the manner in which accounts should be invested. Certain types of
investments involve additional degrees of risk and will only be recommended when consistent with the client's
stated investment objectives, risk tolerance, and liquidity needs.
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Institutional Investment Advisory Services
Schwartz & Co. provides ongoing advisory services to foundations and endowments. Our investment approach is
designed to meet the client’s legal responsibilities and fiduciary standards of care. An initial data gathering
process is completed in an effort to determine the client’s needs, goals, objectives, time horizons, risk tolerance
and any other relevant information. Based upon information provided by the client, and with the client’s input, we
will provide one or more of the following services:
assist in the preparation of an investment policy statement
investment selection and performance
fiduciary compliance
•
• portfolio design
•
•
With the client’s approval, the recommended investment policy statement will be implemented and monitored to
help achieve the client’s investment objectives and goals. The services to be offered will be determined by the
client and will be specifically outlined in the advisory agreement.
Retirement Plan Advisory and Consulting Services
Schwartz & Co. provides ongoing advisory and consulting services to retirement plans pursuant to The Employee
Retirement Income Security Act of 1974 (“ERISA”). Services include both fiduciary and non-fiduciary services
to the Plan Sponsor and the participants of the Plan. Services may be provided on a non-discretionary basis
(ERISA 3(21) Fiduciary) or on a discretionary basis (ERISA 3(38) Fiduciary). Advisory services are negotiated
based on the needs of the Plan and are included in the terms of the advisory agreement. Schwartz & Co.’s
retirement plan services may include, but are not limited to, the following services:
a. Fiduciary Advisory Services
When providing advisory services to retirement plans covered under ERISA, we acknowledge our status as a
fiduciary under Section 3(21) and we will act solely in the interests of plan participants and beneficiaries with
the degree of diligence, care, and skill that a prudent person rendering similar services would exercise under
similar circumstances. Schwartz & Co. provides the following fiduciary advisory services:
•
•
•
Investment Policy Statement. Adviser will assist in the preparation or review of an investment policy
statement (“IPS”) for the Plan based upon consultation with the client.
Investment Recommendations. Adviser will recommend, for consideration and selection by the client,
specific investments to be held by the Plan or, in the case of a participant-directed defined contribution
plan, to be made available as investment options under the Plan. Adviser may also recommend investment
replacements if an existing investment is determined to no longer be a suitable option.
Investment Monitoring. Adviser will perform ongoing monitoring of investment options in relation to the
criteria provided by the client.
•
• Performance Reporting. Adviser will prepare periodic reports reviewing the performance of all Plan
Investment options, as well as comparing the performance thereof to benchmarks with the client. The
information used to generate the reports will be derived from information such as statements provided by
the client, investment providers and/or third parties.
Investment Education. Adviser will provide education for plan sponsor and plan participants regarding
asset classes and types of investments available to the plan.
• Participant Education. Adviser will provide participant education services tailored to the specific needs
of the organization. Adviser will assist plan participants in the enrollment process and answer questions
during group meetings and one-on-one consultations.
• Discretionary Advisory Services (ERISA 3(38) Fiduciary)
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b. Non-Fiduciary Consulting Services
In addition to the fiduciary services described above, Schwartz & Co. offers the following non-fiduciary
services solely in a capacity that is not considered a fiduciary under ERISA or any other applicable law.
Retirement plan clients may select one or more of the following services:
• Benchmarking. Adviser will benchmark investment performance of plan assets vs. similar investment
alternatives.
• Plan Due Diligence. Adviser will assist plan sponsors in evaluating plan service providers and third-party
administrators, including reviewing fees and plan expenses.
We may also consult with the plan sponsor in the areas of plan design, administration, and provider due diligence,
request for proposals, fee negotiations, enrollment packages, and fiduciary responsibilities. The services to be
offered will be determined by the client and will be specifically outlined in the advisory agreement.
Retirement Accounts – Fiduciary Acknowledgement and Rollover Considerations
When we provide investment advice to you regarding your retirement plan account or individual retirement
account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or
the Internal Revenue Code, as applicable, which are laws governing retirement accounts. Regarding any potential
for conflicts of interest, we operate under a special rule that requires us to act in your best interest and not put our
interests ahead of yours.
Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
A recommendation to roll over your assets from a retirement plan to an account managed by Schwartz & Co.
creates a conflict of interest, as we will earn advisory fees as a result of the rollover. There is no obligation for you
to roll over your retirement account to an account managed by Schwartz & Co.
Financial Planning & Consulting Services
Schwartz & Co. provides a variety of financial planning and consulting services to clients on a one-time or
ongoing basis. Financial planning services will typically involve preparing a financial plan or providing a general
financial consultation based upon an analysis of the client’s current financial situation, goals, and objectives.
Depending on the client needs, planning or consulting services may include: identification of financial problems,
cash flow and budget analysis, tax planning, social security planning, risk exposure review, education funding,
retirement planning, charitable planning, special needs planning, business management, buy-out negotiations,
review of client’s benefits package, and life insurance and disability insurance planning. These services may also
include other areas that are specific to the client. Schwartz & Co. reserves the right to decline to provide advice
about issues and topics outside its area of expertise. At the client's request, we may provide recommendations as
to other sources of professional advice to address such matters. All services to be provided will be clearly defined
in the Financial Planning or Consulting Agreement. Financial plans provided to clients usually include general
recommendations for a course of action to be taken by the client. Financial planning recommendations can pose a
conflict between the interests of the Adviser and the interests of the client. Clients are not obligated to implement
any recommendations made by the Adviser.
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RBC Unified Portfolio (“RBC UP”) – third-party discretion
RBC UP is a unified managed account (“UMA”) program through which accounts are managed by RBC Capital
Markets (“RBC”) as overlay manager or an unaffiliated third-party overlay manager, Envestnet Asset
Management, Inc. (“Envestnet”). The overlay manager manages the account on a discretionary basis through
investments in mutual funds, ETPs, and/or in accordance with one or more model portfolios, provided by Model
Providers or RBC, all in a single account, according to the client’s investment strategy.
Schwartz & Co. will work with the client to determine the client’s goals, objectives, risk profile, and any other
relevant information. The Adviser will recommend an appropriate investment strategy based on the information
provided. The investment strategy may be invested in a Model Portfolio or an investment allocation that assigns a
percentage of the account's overall value to cash, Mutual funds, ETFs and/or Model Portfolios. The investment
allocation may be modified by notifying Schwartz & Co. of the changes. By selecting the RBC UP program and
signing the Advisory Master Services Agreement, the overlay manager will have discretion to determine the
securities to be bought or sold within the client’s account. Client accounts are reviewed regularly by the overlay
manager and rebalanced on a discretionary basis to ensure the client’s account does not deviate from the selected
investment strategy.
The Adviser will monitor the client’s account on an ongoing basis and conduct periodic reviews with the client.
The Adviser will attempt to meet with the client at least annually to discuss the client’s investment needs, goals
and objectives. The Adviser will also review the performance of the account to ensure continued suitability of the
investment strategy. Clients must notify Schwartz & Co. promptly of any material changes in financial
circumstances or investment objectives which might affect the manner in which the account should be invested.
In determining whether to participate in RBC UP, clients should be aware that RBC UP is a wrap fee program
sponsored by RBC, where custody and brokerage fees are included in the total advisory fee charged to the client.
The overall cost to the client may be higher or lower than what the client might incur by separately purchasing the
types of securities available in the program.
For additional information about the RBC UP Program, please review the ADV Part 2A Wrap Fee Program
Brochure and the Advisory Master Services Agreement provided by RBC.
Specific Types of Investments
Schwartz & Co. generally provides investment advice on the following types of investments: equity securities,
corporate debt securities, municipal securities, United States government securities, exchange traded funds
(ETFs), certificates of deposits, interests in real estate partnerships and investment company securities such as
mutual fund shares, variable annuities, and variable life insurance. We have access to a full array of investment
vehicles and our investment recommendations are not limited to any specific product or service.
Tailored Advisory Services & Restrictions
Advisory services are tailored to the individual needs of the client. Client goals and objectives are clarified in
meetings and via correspondence and are used to determine the course of action for each individual client. The
goals and objectives for each client are documented in client files, either in hard copy or in electronic files. Clients
may impose restrictions on investing in certain securities or types of securities. This must be done in writing and
signed by the client and the investment adviser representative working with the client.
Each client is advised that it remains his/her responsibility to promptly notify Schwartz & Co. when there is any
change in his/her financial situation and/or financial objectives for the purpose of reviewing, evaluating, or
revising previous recommendations and/or services.
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Wrap Fee Programs
Schwartz & Co. does not participate in any wrap fee programs.
Assets Under Management
As of December 31, 2025, Schwartz & Co. had $10,489,459,567 in assets under management, of which
$180,596,727 was managed on a discretionary basis and $10,308,862,840 was managed on a non-discretionary
basis.
ITEM 5: FEES AND COMPENSATION
Fees for Advisory Services
Schwartz & Co. offers advisory services under various fee arrangements. The extent of advisory services offered,
fee schedules, and billing arrangements have been modified over the years. As such, some existing clients have
contracts in place with older fee arrangements and differing billing arrangements. Under certain circumstances
Schwartz & Co. may approve a billing methodology that differs from those described below, such as when third-
party managed accounts are used, when third-party administrators are used for retirement plans, or upon request
from the client. The specific manner in which fees are charged by the Adviser is established in a client’s written
agreement with the Adviser.
Wealth Management & Institutional Advisory Fees
Fees for wealth management and institutional advisory services are based on an annual percentage of assets under
management. Fees are negotiable and may vary on a client-by-client basis depending on the amount of assets
under management, the nature and complexity of the client’s situation, the extent of services to be provided, and
the complexity of the portfolio and investment strategy. The maximum annual fee for such services is 1.5% or
150 basis points. Schwartz & Co. reserves the right to negotiate fees and may charge a lower fee than the
maximum fee described herein. The client’s specific fee will be included in the Agreement between Schwartz &
Co. and the client.
Fees are calculated based on the market value of the assets under management and billed quarterly or monthly, in
arrears, in accordance with the terms of the Agreement. The initial advisory fee will be prorated from the date of
engagement through the end of the quarter or month.
Clients may elect to be billed directly for fees or to authorize the Adviser to directly debit fees from their account.
Generally, clients elect to have fees deducted directly from their account, pursuant to the client’s written
authorization. If the client elects to be billed directly, Schwartz & Co. will send a billing invoice to the client and
the client agrees to remit payment to Schwartz & Co. within 30 days of receipt of the invoice.
Retirement Plan Services
Fees for the fiduciary and non-fiduciary services provided to the plan are based on an annual percentage of assets
under management. Flat dollar compensation arrangements are utilized in selected instances. Fees are negotiable
and vary based on the nature and scope of services provided, the level of fiduciary responsibility assumed, the
complexity and size of the plan, and other unique characteristics of the engagement. The maximum annual fee for
such services is 1.0% or 100 basis points. Fees are determined at the time of engagement and are specifically
outlined in the client’s service agreement.
Fees are calculated based on the total fair market value of plan assets under management and billed quarterly or
monthly, in arrears, in accordance with the terms of the service Agreement. Fees for the initial quarter or month
will be prorated based on the number of days services are provided to the plan. Schwartz & Co. believes its fees
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are fair and reasonable based on the services provided to plan sponsor. Fees charged by other advisers may be
higher or lower than those charged by Schwartz & Co. for similar services.
The plan may be subject to other fees and charges imposed by account custodians, third party administrators, and
recordkeepers. These fees are separate and distinct from advisory fees charged by Schwartz & Co. The plan
custodian or third- party administrator should send account statements to the plan sponsor at least quarterly, which
show all fees charged to plan accounts.
Clients may elect to be billed directly for fees or to authorize the Adviser to directly debit fees from plan assets.
Generally, clients elect to have fees deducted directly from the plan, pursuant to the client’s written authorization.
If the client elects to be billed directly, Schwartz & Co. will send a billing invoice to the plan sponsor and the plan
sponsor agrees to remit payment to Schwartz & Co. within 30 days of receipt of the invoice.
Financial Planning & Consulting Services
Fees for financial planning and consulting services may be charged at an hourly or at a fixed fee rate. Fees are
determined at the time of engagement and are specifically outlined in the client’s Agreement.
RBC Unified Portfolio (“RBC UP”)
The RBC UP Program Fee is comprised of the following fee components: 1) fee for services provided by
Schwartz & Co., 2) Program Sponsor fee payable to RBC, 3) fee for Model Providers, and 4) fee for overlay
manager. The Program fee structure may vary depending on the Program and services selected.
The Program Fee is calculated as a percentage of assets under management, including securities, cash, money
market funds, RBC Insured Deposits balances, and the full value of any assets purchased on margin. Program
Fees are calculated on a quarterly basis, in advance, based on the market value of the billable assets as of the last
business day of the preceding calendar quarter. Program Fees will be prorated for any partial billing period based
on the number of days services were provided.
The quarterly Program fee will be deducted directly from the account by RBC, the custodian, unless the client
elects to be billed directly or have the fees deducted from another account held by RBC, provided the account is
not a retirement account. RBC will retain its fees (which will include advisory fees, program sponsor fees and/or
custodial fees), the overlay manager’s fee, and the Model Provider’s fee, and the remaining portion will be paid to
Schwartz & Co. The client must authorize RBC to deduct the Program fees from the client’s account.
For additional information about the RBC UP Program fees, please review the ADV Part 2A Wrap Fee Program
Brochure and the Advisory Master Services Agreement provided by RBC.
Other Types of Fees & Expenses
Clients may incur certain fees and expenses charged by the custodian such as custodial fees, transfer taxes, wire
transfer fees, or electronic fund fees. Please refer to Item 12 – Brokerage Practices for additional information.
All fees paid to Schwartz & Co. for investment advisory services are separate and distinct from the fees and
expenses charged by mutual funds to their shareholders. These fees and expenses are described in each fund’s
prospectus. These fees will generally include management fees, other fund expenses, and possibly a distribution
fee. Clients should review the fees charged by the mutual funds and the fees charged by Schwartz & Co. for
investment advisory services to fully understand the total fees to be paid by the client.
Exchange-Traded Funds (ETFs) incur a separate management fee, typically referred to as the “expense ratio.” The
expense ratio is an annual percentage of the fund’s assets which is assessed by the fund directly. This
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management fee is in addition to the ongoing advisory fee assessed by Schwartz & Co. Details regarding these
fees can be found in the ETF’s prospectus.
Prepaid Fees, Refunds, Termination
Clients may terminate their contract by providing written notice as outlined in the Agreement. Upon termination
of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due
and payable. Adviser will prorate the fee to the effective date of termination and debit any earned portion from the
client’s account or bill the client, depending on the terms of the Agreement. The effective date of termination will
be set according to the terms of the advisory agreement and/or any special instructions from the client.
Other Compensation
Several investment adviser representatives (IAR) are also registered representatives of Schwartz & Co., an SEC
registered broker-dealer and member of FINRA. In their separate capacity as a registered representative, the IAR
will receive commission-based compensation in connection with the purchase and sale of securities, including
12b-1 fees for the sale of investment company products. Commissions generated by such securities transactions
do not offset regular advisory fees. This practice presents a conflict of interest because the IAR has an incentive to
recommend securities transactions for the purpose of generating commissions rather than based solely on the
Client’s needs. IARs will only recommend securities transactions that they believe are suitable and in the best
interest of the client. Clients are under no obligation to implement any recommendation provided by the IAR and
may seek similar services elsewhere. Neither the Adviser nor the IAR will earn ongoing investment advisory fees
in connection with any products or services implemented in the IAR’s separate capacity as a registered
representative.
Schwartz & Co. is affiliated with Schwartz Benefit Services, LLC, an insurance agency under common ownership
that provides life and health insurance products and fixed annuities to clients. Certain IARs of Schwartz & Co. are
licensed as insurance agents with Schwartz Benefit Services, LLC. These IARs may also be licensed with
Schwartz & Co. broker-dealer to offer variable insurance products. In their separate capacity as an insurance
agent, the IAR will receive commissions from the various insurance companies whose products are sold.
Commissions generated by insurance sales do not offset regular advisory fees. This presents a conflict of interest
because there is an incentive to recommend insurance products for the purpose of generating commissions, rather
than the client's needs. IARs will only recommend insurance products that they believe are suitable and in the best
interest of the client. Clients are not obligated to purchase any insurance products or implement any
recommendation provided by the IAR and may seek similar services elsewhere. Neither the Adviser nor the IAR
will earn ongoing investment advisory fees in connection with any products or services implemented in the IAR’s
separate capacity as an insurance agent.
In limited situations, Schwartz & Co. may be hired as the broker of record for a variable annuity that was
purchased by a client through a different registered representative at a different broker-dealer. This advisory
service is separate and distinct from the initial transaction to purchase the annuity. Schwartz & Co. may charge an
advisory fee for this service. Schwartz & Co. addresses this conflict through disclosure and does not charge
advisory fees on assets that the IAR, acting in their capacity as a registered representative, receives ongoing
brokerage compensation. Clients are under no obligation to implement any recommendation provided by the
Adviser or the IAR.
Please see Item 10 – Other Financial Industry Activities and Affiliations for more information.
ITEM 6: PERFORMANCE-BASED FEE AND SIDE-BY-SIDE MANAGEMENT
Performance-based fees are fees calculated based on a share of capital gains or capital appreciation of the assets of
a client. Schwartz & Co. does not charge performance-based fees with respect to any advisory services offered.
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ITEM 7: TYPES OF CLIENTS
Schwartz & Co. generally provides advisory and consulting services to individuals, high net worth individuals,
institutional retirement plans, trusts, estates, charitable organizations, corporations, and other business entities.
We do not stipulate any minimum requirements to become a client of Schwartz & Co.
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
Methods of Analysis and Investment Strategies
Schwartz & Co. employs analytical tools and investment strategies to assist in formulating our investment advice
to clients. The methods of analysis utilized by Schwartz & Co. include: 1) Fundamental Analysis – which
measures the intrinsic value of an investment as determined by economic, financial and other quantitative and
qualitative factors, and 2) Cyclical Analysis – which involves finding cycles and patterns in the market.
The primary sources for these analytics include: Financial publications, Morningstar, research materials prepared
by third-parties, annual reports, prospectuses, presentations, newsletters, and commentary from investment
managers at fund companies, and filings with the Securities and Exchange Commission
We utilize the above analytics and apply our firm’s investment strategies of diversity, long-term and short-term
purchasing, and consider investor criteria of time horizon, need for short-term liquidity, and risk tolerance to
determine what investments are best suited to the individual investor. These strategies come with risk:
Long-term purchases: Long-term purchases are made with the intent of holding on to the security for a minimum
of 12 months. Such purchases may be made when securities are believed to be undervalued and anticipated to
appreciate over time. The inherent risk involved with long-term purchases is the possibility of our projection
being incorrect and experiencing a decrease in the value of the security before deciding to sell. Another risk is the
possibility of missing out on short-term gains.
Short-term purchases: Short-term purchases are made with the intent of selling the security within the next 12
months. The idea is to take advantage of projected increases in a security’s value that will ultimately result in a
profit. An obvious risk of short-term purchases is the potential for loss should the projected increase in value not
materialize. Another risk or disadvantage of short-term purchases is increased transaction related expenses due to
increased trading.
Diversification: Diversification is a means to minimize investment risk by allocating assets into various areas of
the market, such as large cap, mid cap, or small cap. If applied incorrectly, investors could find they are invested
in differently titled mutual funds, for example, but those mutual funds could hold similar holdings, hence not
providing them true diversification in the market.
It is Schwartz & Co.’s philosophy to be long-term invested. While changes in funds can and will occur, our
investment strategy is primarily focused on a long-term approach. Tax considerations may or may not factor into
changes in a portfolio (i.e. harvesting losses). Our overall strategy includes focusing on good performing
investment vehicles that are cost effective compared to the benchmark for that given asset class. We focus on an
overall diversified approach, to minimize client risk by allocating assets and not overlapping the various areas of
the market.
Risk of Loss
Our advisers exercise great care to make sure that the client is aware of the specific risk of each distinctive
investment strategy that will be used. Investing in securities involves risk of loss which the client should be
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prepared to bear. While Schwartz & Co. uses investment strategies that are designed to reduce risk through
diversification, some investments have significantly greater risks than others. Obtaining higher rates of return on
investments entails accepting a higher level of risk. Our investment strategies seek to balance risk and reward to
achieve a client’s investment objectives.
Schwartz & Co. does not represent, guarantee, or imply that its services or methods of analysis can or will predict
future results, successfully identify market tops or bottoms, or shield clients from losses due to market corrections
or declines. Past performance is in no way an indication of future performance.
While our investment approach always keeps the risk of loss in mind, clients should understand that they may
face the following investment risks:
•
Interest Rate Risk – The chance that bond prices overall will decline because of rising interest rates.
Fluctuations in interest rates can cause investment prices to fluctuate. For example, when interest rates
rise, yields on existing bonds become less attractive, causing their market values to decline.
• Market Risk – Stock and bond markets can decline in reaction to tangible or intangible events and
•
conditions. This type of risk is caused by external factors independent of a security’s particular underlying
circumstances.
Inflation Risk – When any type of inflation is present, a dollar will be worth more today than a dollar next
year, because purchasing power is eroding at the rate of inflation.
• Currency Risk – Overseas investments are subject to fluctuations in the value of the dollar against the
currency of the investment’s originating country. This is also referred to as exchange rate risk.
• Reinvestment Risk – This is the risk that future proceeds from investments may have to be reinvested at a
potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities.
• Manager Risk – The investment strategies, research, analysis and the determination of a portfolio’s
securities by Schwartz & Co. or the third-party asset manager will not always be successful. The risk of
loss due to allocations in the various assets can cause the client’s account to underperform relative to
benchmarks or other accounts with a similar investment objective.
• Business Risk – This risk is associated with a particular industry or company within an industry.
• Liquidity Risk – Liquidity is the ability to readily convert an investment into cash. Generally, assets are
more liquid if many traders are interested in a standardized product. For example, Treasury Bills are
highly liquid, while real estate properties are not.
• Concentration Risk – Client accounts will be diversified to varying degrees based on the strategy or
model portfolio selected for their portfolio. To the extent a client invests a significant portion of their
assets in a single underlying fund or asset class, it will be particularly sensitive to the risk associated with
concentration.
• Cybersecurity Risk – Failures or breaches of the electronic systems of Schwartz & Co., our services
providers, securities market participants, or the issuers of securities can cause significant losses for
investors. Unintentional cyber events, such as the inadvertent release of confidential information, could
also adversely impact investor accounts. Any cyber event could result in the loss or theft of investor data
or cause investors financial loss and expense.
ITEM 9: DISCIPLINARY INFORMATION
As a registered investment adviser, we have no legal or disciplinary events to disclose. There are no convictions
of theft, fraud, bribery, perjury, forgery, counterfeiting, extortion, or violations of law. As an adviser we will
disclose any legal or disciplinary events that are material to a client’s evaluation of our advisers or management
personnel, as well as any inabilities to meet contractual commitments to clients.
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ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Other Financial Industry Activities
Broker-Dealer/Registered Representatives
In addition to being a registered investment adviser with the SEC, Schwartz & Co. is also a registered broker-
dealer and member of FINRA. Most IARs are also registered representatives of Schwartz & Co. In their separate
capacity as a registered representative, the IAR will receive commission-based compensation in connection with
the purchase and sale of securities, including 12b-1 fees for the sale of investment company products.
Commissions generated by such securities transactions do not offset regular advisory fees. This practice presents
a conflict of interest because the IAR has an incentive to recommend securities transactions for the purpose of
generating commissions rather than based solely on the Client’s needs. Schwartz & Co. addresses this conflict
through disclosure and does not charge advisory fees on any assets where the IAR, acting in their capacity as a
registered representative, receives commission-based compensation. IARs will only recommend securities
transactions that they believe are suitable and in the best interest of the client. Clients are under no obligation to
implement any recommendation provided by the IAR and may seek similar services elsewhere. Neither the
Adviser nor the IAR will earn ongoing investment advisory fees in connection with any products or services
implemented in the IAR’s separate capacity as a registered representative.
Other Financial Industry Affiliations
Insurance Agency/Insurance Agents
Schwartz & Co. is affiliated with Schwartz Benefit Services, LLC, an insurance agency under common ownership
that provides life and health insurance products and fixed annuities to clients. Certain IARs of Schwartz & Co. are
licensed as insurance agents with Schwartz Benefit Services, LLC. These IARs may also be insurance licensed
with Schwartz & Co. broker-dealer to offer variable insurance products. In their separate capacity as an insurance
agent, the IAR will receive commissions from the various insurance companies whose products are sold.
Commissions generated by insurance sales do not offset regular advisory fees. This presents a conflict of interest
because there is an incentive to recommend insurance products for the purpose of generating commissions, rather
than the client's needs. IARs will only recommend insurance products that they believe are suitable and in the best
interest of the client. Clients are not obligated to purchase any insurance products or implement any
recommendation provided by the IAR and may seek similar services elsewhere. Neither the Adviser nor the IAR
will earn ongoing investment advisory fees in connection with any products or services implemented in the IAR’s
separate capacity as an insurance agent.
Mi BANK (MiCommunity Bancorp, Inc.)
Mi BANK is a full-service community bank located within the same office building as Schwartz & Co.
MiCommunity Bancorp, Inc. is a holding company for Mi BANK. Certain principals and IARs of Schwartz & Co.
have investment interests in MiCommunity Bancorp, Inc. Two of these individuals are organizers and founding
members and currently serve on the Board of Directors for MiCommunity Bancorp, Inc. and Mi BANK.
Several owners/principals of Schwartz & Co. also have investment interests in the following limited liability
companies, which own interests in senior housing rental facilities: Baldwin House Holdings, LLC (Baldwin SFG
Investors, LLC), SFG Spring Lake, LLC (AH Spring Lake/Southgate Investors, LLC), SFG Southgate, LLC (AH
Spring Lake / Southgate Investors, LLC), and SFG Grand Rapids, LLC (AH Grand Rapids Investors, LLC).
Clients should be aware that the ability to receive additional compensation by our Firm and its management
persons or employees creates conflicts of interest that impair the objectivity of the Firm and these individuals
when making advisory recommendations. Our Firm endeavors at all times to put the interest of its clients first as
part of our fiduciary duty as a registered investment adviser; we take the following steps, among others, to address
this conflict:
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• we disclose to clients the existence of all material conflicts of interest, including the potential for the Firm
and our employees to earn compensation from advisory clients in addition to the Firm’s advisory fees;
• we disclose to clients that they have the right to decide whether to purchase recommended investment
products from our employees;
• we collect, maintain and document accurate, complete and relevant client background information,
•
including the client’s financial goals, objectives, and risk tolerance;
the Firm conducts regular reviews of each client advisory account to verify that all recommendations
made to a client are in the best interest of the client’s needs and circumstances;
• we require that our employees seek prior approval of any outside employment activity so that we may
ensure that any conflicts of interests in such activities are properly addressed;
• we periodically monitor these outside employment activities to verify that any conflicts of interest
continue to be properly addressed by the Firm; and
• we educate our employees regarding the responsibilities of a fiduciary, including the need for having a
reasonable basis for the investment advice provided to clients.
Investment Adviser Recommendations
Our firm does not recommend or select other investment advisers for our clients; thus, we do not receive
compensation from other advisers.
ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING
Code of Ethics
Schwartz & Co. has adopted a code of ethics pursuant to rule 204A-1 under the Investment Advisers Act of 1940
as amended (The “Adviser Act”) pursuant to Section 406 of the Sarbanes-Oxley Act of 2002.
The “Code of Ethics” states:
1. The officers and owners of the company will 1) foster a corporate culture of ethical conduct and high
integrity, 2) promote that full, accurate, and timely documentation be provided to investors, 3) not
knowingly misrepresent facts about the company to auditors or regulators of the industry.
2. All personnel at Schwartz & Co. will 1) have the highest degree of honesty, integrity and professionalism,
2) adhere to the code of ethics, 3) always hold client interests as first priority, 4) not knowingly
misrepresent facts, 5) provide fair and accurate disclosures, 6) comply with the rules of the industry, 7)
strive to improve their competence, 8) safeguard personal client information, 9) not accept extravagant
gifts or entertainment, 10) avoid conflicts of interest.
A copy of the code of ethics will be provided to any client or prospective client upon request.
Client Transactions and Personal Trading
Registered representatives of our firm do affect securities transactions for clients, for commissions. This occurs in
instances where we are not serving in an advisory role. Such transactions are conducted in adherence with the
applicable prospectuses which are given to investors.
As a firm, we recommend investment products such as: (1) publicly registered mutual funds; and (2) private
placement investment units, which invest in senior housing, where principals of Schwartz & Co. have an
ownership interest in the LLC’s that offer the private placement investment units. We recommend these
investments to broker-dealer clients and individual advisory clients. We do not recommend these investments to
institutional/retirement plan broker-dealer clients or institutional/retirement plan advisory clients. Should an
advisory client wish to invest in these products, such transactions will be conducted in adherence with the
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applicable offering memorandum. Owners and employees of the firm do have a financial interest in the
investment products listed above.
Our investment professionals occasionally buy and sell the same securities that they recommend to clients, which
most commonly are mutual fund shares. Such transactions take place in adherence with the applicable
prospectuses and under the trading rules and guidelines as set forth by the regulatory agencies.
ITEM 12: BROKERAGE PRACTICES
Schwartz & Co., as a dual registered investment adviser and broker-dealer, has the ability to offer brokerage
services to our investment advisory clients. We do not require our clients to utilize our brokerage services. We
disclose our affiliation in advance of the client agreement and give clients the option to utilize another broker-
dealer to execute transactions. As a normal course of business, retail advisory clients choose to utilize the
brokerage of the firm, however, retirement clients mainly utilize outside brokerage.
We have a fiduciary duty to execute securities transactions in such a manner that the client’s total cost or proceeds
in each transaction is the most favorable under the circumstances. Our firm, under the broker-dealer, has partnered
with RBC Capital Markets, LLC, for trade execution. We acquire from RBC Capital Markets, LLC regular and
rigorous reviews of their trading execution platforms to monitor that they execute transactions as favorably for
our clients as possible. Favorable determination of a trade does not necessarily mean the lowest possible
commission cost, but whether the transaction represents the best qualitative execution (i.e. the best price,
fulfillment of the order, and speed in executing the trade).
If a client wishes for us to select or refer a broker-dealer that is not our own, we have a fiduciary duty to select a
broker-dealer to execute a particular trade which will provide “best execution” for the client. By directing
brokerage away from our firm, we may be unable to achieve the most favorable execution of client transactions
and that this practice may cost clients more money.
Should a client insist we utilize a specific broker-dealer for their purpose, we work with the requested broker-
dealer and perform due diligence on the transactions executed. In client directed brokerage accounts the client
may pay higher brokerage commissions because we may not be able to aggregate orders to reduce transaction
costs, or the client may receive less favorable pricing.
Brokerage for Client Referrals
Schwartz & Co. does not select or recommend clients to other broker-dealers to receive referrals.
Research and Other Soft Dollar Benefits
Schwartz & Co. does not participate in the practice of obtaining brokerage and research services through client
commissions, called “Soft Dollar Arrangements.” We follow good faith practices and charge commissions based
solely on the costs and circumstances surrounding the effected trades. All direct brokerage and research costs of
the company are paid by the broker-dealer.
Our firm will periodically attend a product provider educational conference or event, (which includes hospitality),
or receive sponsorship for a marketing event. This can cause a conflict in the capacity to influence advice to our
clients due to incentives. To mitigate this possibility, our firm keeps these activities to a minimum and requires all
events and sponsorships to be approved and monitored by principals of the firm.
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ITEM 13: REVIEW OF ACCOUNTS
Our firm reviews client accounts on a regular basis. Client account reviews can be on a monthly, quarterly, semi-
annual, or annual basis as determined to be most appropriate to the client’s situation. Reviews of accounts are
conducted by one of the five principals, with an annual review performed by the compliance department. Principal
level reviews concentrate on determining if the investment adviser representative has applied, accurately, the
correct analytics and strategies to the account to come up with the best investment recommendation for that
particular client. Compliance reviews focus on verifying that all investment adviser representatives are following
regulation as required by the industry and company policy.
Occasionally a triggering factor will prompt a review. This includes customer requests, impromptu meetings,
customer complaints, unusual client situations, or when a principal deems it necessary.
Clients receive a written report pertaining to their individual investment portfolio from the Adviser. These reports
list all assets of the client, their current values, comparable asset values and any current recommendations. The
reports are received by clients on the review cycle determined most appropriate for their situation. These reports
are discussed with the client either in person or by telephone. The purpose of the report is to ensure the client
understands the position of their accounts, the strategies employed, the transactions executed and to see the
investment performance of the plan. It also allows us to maintain communication with our clients and provides a
platform for clients to ask questions and fully understand what is happening with their funds.
Clients also receive a brokerage statement, listing assets with their current values, held in custody by RBC Capital
Markets, LLC or other individual investment companies. We strongly encourage clients to carefully review and
compare all statements that they receive regarding their accounts.
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION
We pay referral fees to independent solicitors for the referral of their clients to our Firm in accordance with Rule
206 (4)-3 under the Advisers Act (“Rule 206 (4)-3”). Such referral fee represents a share of our investment
advisory fee charged to referred clients. This arrangement will not result in higher costs to you, the referred client.
In this regard, we maintain Solicitors Agreements in compliance with Rule 206 (4)-3 and applicable state and
federal laws. Applicable clients referred by solicitors with which we have Solicitor Agreements will be given
written disclosure describing the terms and fee arrangements between our Firm and Solicitor(s). The solicitor is
not authorized to, and has agreed not to, provide clients any investment advice on behalf of Schwartz & Co.
ITEM 15: CUSTODY
Schwartz & Co. does not have physical custody of client funds or securities. These funds are held by qualified
custodians. Clients will receive account statements from our correspondent, RBC Capital Markets, LLC or
directly from the investment companies at least quarterly, or monthly if there is activity on the account. We
strongly encourage clients to carefully review and compare all statements that they receive.
Exceptions to the above include four private placement investments. As such we follow the provisions of the
custody rule and have the financial statements audited by a PCAOB registered auditor. Unaudited financial
statements are provided to the fund’s investors on a quarterly basis with the audited statements sent out annually.
ITEM 16: INVESTMENT DISCRETION
Schwartz & Co. currently accepts discretionary authority to manage securities accounts on behalf of clients. The
number of discretionary accounts our firm holds is minimal and is only put in place upon request from the client.
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If a client wishes to give us discretionary authority on their account, we require that such authority be established
in writing through the advisory agreement and a signed document granting discretionary power to the Adviser.
Clients can place limitations on this discretion, and it must be done so in writing or included with the agreement.
Limitations customarily requested are monetary limits per trade, discretion on certain investments in the portfolio,
or limits on the actions an investment adviser representative can perform. Should the client wish to modify or
remove discretionary authority the agreement may be updated at any time. Although we may have discretionary
authority on an account, our office procedures require personnel to contact the client prior to the execution of any
trade(s).
ITEM 17: VOTING CLIENT SECURITIES
Our Firm does not vote proxies on behalf of clients. Proxies should be received by clients directly from the
qualified custodians who hold the related security. Should the Firm choose to exercise voting authority in the
future, policies and procedures with respect to Rule 206(4)-6 under the Advisers Act will be implemented. Clients
can contact the Firm should any questions arise relating to the proxies.
ITEM 18: FINANCIAL INFORMATION
The balance sheet of Schwartz & Co. has been prepared in accordance with the Generally Accepted Accounting
Principles and audited by a PCAOB registered auditor on an annual basis. Our financial statements are prepared
on the calendar year ending 12/31. A copy of the audited balance sheet is available upon written or verbal request.
A copy of the balance sheet is not required with this filing as our Firm does not solicit prepaid fees.
As of this filing there are no financial conditions that exist that are reasonably likely to impair the Adviser’s
ability to meet contractual obligations to clients. The Firm has not been the subject of a bankruptcy petition at any
time in the past 10 years.
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