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Firm Brochure
(Part 2A of Form ADV)
Item 1. Cover Page
Semper Augustus Investments Group LLC
200 Plaza Drive Suite 240
Highlands Ranch, CO 80129
Phone: (303) 893-1214
Fax: (303) 893-1207
www.semperaugustus.com
csc@semperaugustus.com
This brochure provides information about the qualifications and business
practices of Semper Augustus Investments Group LLC. If you have any
questions about the contents of this brochure, please contact us at: (303)
893-1214, or by email at: csc@semperaugustus.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 Semper Augustus Investments Group LLC is
available on the SEC’s website at www.adviserinfo.sec.gov
March 26, 2025
Semper Augustus Investments Group LLC
Item 2.
Material Changes (2.)
Annual Update
The Material Changes section of this brochure will be updated annually when
material changes occur since the previous release of the Firm Brochure.
Material Changes since the Last Update
None.
Full Brochure Available
Whenever you would like to receive a complete copy of our Firm Brochure,
please contact us by telephone at: (303) 893-1214 or by email at:
csc@semperaugustus.com.
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Item 3.
Table of Contents
Material Changes (2.) ..................................................................................................... i
Annual Update ............................................................................................................ i
Material Changes since the Last Update .................................................................... i
Full Brochure Available ............................................................................................... i
Advisory Business (4.) .................................................................................................. 1
Firm Description ......................................................................................................... 1
Principal Owners ........................................................................................................ 1
Types of Advisory Services ........................................................................................ 1
Tailored Relationships ............................................................................................... 2
Types of Agreements ................................................................................................. 2
Advisory Service Agreement ...................................................................................... 2
Services Offered Through Other Advisors ................................................................. 2
Pooled Investment Vehicles ....................................................................................... 3
Retirement Rollovers – Potential for Conflict of Interest ............................................. 4
Asset Management .................................................................................................... 4
Termination of Agreement ......................................................................................... 5
Fees and Compensation (5.) ........................................................................................ 5
Description ................................................................................................................. 5
Fee Billing .................................................................................................................. 6
Other Fees ................................................................................................................. 6
Expense Ratios .......................................................................................................... 7
Past Due Accounts and Termination of Agreement ................................................... 7
Performance-Based Fees (6.) ....................................................................................... 7
Sharing of Capital Gains ............................................................................................ 7
Types of Clients (7.) ...................................................................................................... 8
Description ................................................................................................................. 8
Account Minimums ..................................................................................................... 8
Methods of Analysis, Investment Strategies and Risk of Loss (8.) .......................... 8
Methods of Analysis ................................................................................................... 8
Investment Strategies ................................................................................................ 8
Equity Investments ..................................................................................................... 9
Fixed Income and Cash Equivalents ........................................................................ 10
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Semper Augustus Investments Group LLC
Short Sales and Options .......................................................................................... 11
Other Clients ............................................................................................................ 12
Primary Research and Other Sources ..................................................................... 12
Risk of Loss ............................................................................................................. 12
Disciplinary Information (9.) ....................................................................................... 14
Legal and Disciplinary .............................................................................................. 14
Other Financial Industry Activities and Affiliations (10.) ......................................... 14
Financial Industry Activities ...................................................................................... 14
Affiliations ................................................................................................................ 14
Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading (11.) ................................................................................................................. 14
Code of Ethics.......................................................................................................... 14
Participation or Interest in Client Transactions ......................................................... 15
Personal Trading...................................................................................................... 15
Brokerage Practices (12.) ........................................................................................... 15
The Custodians and Brokers We Use ...................................................................... 15
Selecting Custodians and Brokerage Firms ............................................................. 16
Your Brokerage and Custody Costs ......................................................................... 18
Products and Services Available to Us from Schwab .............................................. 18
Services That Benefit You. ...................................................................................... 19
Services That May Not Directly Benefit You. ........................................................... 19
Services That Generally Benefit Only Us. ................................................................ 19
Our Interest in Schwab’s Services ........................................................................... 20
Best Execution ......................................................................................................... 20
Research and Other Soft Dollar Benefits ................................................................. 21
Order Aggregation ................................................................................................... 21
Directed Brokerage or Custodian ............................................................................. 22
Review of Accounts (13.) ............................................................................................ 23
Periodic Reviews ..................................................................................................... 23
Review Triggers ....................................................................................................... 23
Regular Reports ....................................................................................................... 23
Client Referrals and Other Compensation (14.) ........................................................ 23
Referrals Out ........................................................................................................... 23
Other Compensation ................................................................................................ 23
TOC 2
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Custody (15.) ............................................................................................................... 24
Do We Have Custody? ............................................................................................ 24
Account Statements ................................................................................................. 25
Performance Reports ............................................................................................... 25
Investment Discretion (16.) ........................................................................................ 25
Discretionary Authority for Trading ........................................................................... 25
Limited Power of Attorney ........................................................................................ 25
Voting Client Securities (17.) ...................................................................................... 26
Proxy Votes ............................................................................................................. 26
Financial Information (18.) .......................................................................................... 26
Financial Condition .................................................................................................. 26
Business Continuity Plan (19.) ................................................................................... 26
General .................................................................................................................... 26
Disasters .................................................................................................................. 26
Alternate Offices ...................................................................................................... 27
Loss of Key Personnel ............................................................................................. 27
Information Security Program (20.) ........................................................................... 27
Information Security ................................................................................................. 27
Privacy Notice .......................................................................................................... 27
TOC 3
Semper Augustus Investments Group LLC
Advisory Business (4.)
Firm Description
Semper Augustus Investments Group LLC, (“Semper Augustus”) was
founded in 1998.
Semper Augustus is an investment management firm. The firm does not sell
annuities, insurance, stocks, bonds, mutual funds, or other commissioned
products. The firm is not affiliated with entities that sell financial products or
securities. No commissions in any form are accepted. No finder’s fees are
accepted. A “Registered Investment Adviser” does not imply a certain level of
skill or training.
Principal Owners
Christopher P. Bloomstran is a 50% stockholder of Semper Augustus. Chad
S Christensen is a 50% stockholder of Semper Augustus.
Types of Advisory Services
Semper Augustus provides investment supervisory services and investment
advisory account services through a management fee based on percentage
of assets under management and through performance fees.
Our typical relationship is with a client that has established an account at a
“qualified custodian” and provided us with a limited power of attorney to
execute security transactions in the account.
We typically buy and sell securities based on our own proprietary analysis
and you will own these individual securities in your account.
In this arrangement, you will receive statements from the “qualified
custodian”, you may have access to certain online information to track your
account and all tax reporting will be provided by the “qualified custodian”.
As disclosed below in further detail, we earn a management fee and in some
cases a performance fee. The qualified custodian earns account based fees,
asset based fees and/or transaction fees which are solely payable by you and
we do not share in those fees.
Although we discuss personal finance matters with clients to assist us in
managing their assets, we do not hold ourselves out as financial planners and
do NOT provide insurance, legal or tax advice.
While we do give continuous advice on the specific client portfolios for which
we have responsibility, it is not always that we have obtained, been granted,
or otherwise have come to know the total or complete nature and amount of a
client’s other assets, insurance, liabilities, tax situation and personal/family
obligations. Clients may impose restrictions on certain securities or types of
securities by written notification.
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From time to time, we may recommend the purchase of limited partnership
interests, where the underlying portfolio is comprised of securities. Since
employees and managers of Semper Augustus may be invested in these
limited partnership interests, an inherent conflict of interest may exist since
they have an interest in those securities and benefit from spreading
operational costs over a larger asset base and we may receive higher fees
from your investment in our affiliated limited partnership.
Tailored Relationships
For individually managed accounts, we spend the commensurate time in
seeking to understand your objectives, risk tolerance and service needs. In
addition, we spend the necessary time to involve you in our thought process
and make you aware of our ongoing investment philosophy.
For individually managed accounts, we strive to obtain relevant peripheral
information from our clients. In some cases, particular, peculiar, or specific
background factors related to a client are not always disclosed to us, despite
our attempt to ascertain them. We prefer not to manage securities portfolios
without an understanding of the client’s background and objectives, although
in some cases we may be doing just that by directive from the client.
The investment assets and security holdings under our responsibility, as well
as the client’s own appraisal of the nature and amount of other assets,
investments, insurance, liabilities, tax situation, plus the nature and extent of
their personal/family obligations may be considered when we create a
portfolio for you.
Securities or products may be available from other brokers or agents besides
us.
See the Review of Accounts section for additional information.
Types of Agreements
The following agreements define the typical client relationships. Agreements
may not be assigned without prior client consent.
Advisory Service Agreement
Most clients designate Semper Augustus as investment manager of assets
held in their accounts with a qualified custodian, such as a broker-dealer.
This means Semper Augustus assumes all investment duties with respect to
the account and has all investment powers, including investment authority.
Services Offered Through Other Advisors
In addition to the direct accounts we offer as discussed above, Semper
Augustus may offer investment supervisory services and investment advisory
account services on a discretionary basis to the clients of other financial
services firms, such as broker-dealers and bank trust departments
(“sponsors”). These sponsors typically offer comprehensive brokerage,
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custodial, and advisory services through a single fee, through a
commissioned fee arrangement, or based on a percentage of assets under
management. In some circumstances, the sponsor may pay Semper
Augustus a portion of their fee in connection with the services provided by
Semper Augustus. In other circumstances, the underlying client may be billed
directly for services provided by Semper Augustus. In other circumstances,
the sponsor and Semper Augustus may charge separate fees for their
respective services.
In these program-type accounts, Semper Augustus may be chosen by the
client to act as an investment adviser through a pre-selection process
administered by the sponsor. The client information compiled through the
pre-selection process enables Semper Augustus to provide individualized
investment services, which it maintains through ongoing contact with the
sponsor and/or the underlying client. Semper Augustus may be available for
direct telephone conversation with these clients at their request, and
periodically, at the discretion of the sponsor. The sponsor’s services
generally may include, in addition to assistance with the selection of the
investment adviser, asset allocation advice, execution of portfolio transactions
(see related discussion in Section 12 regarding directed brokerage
transactions), custodial services, including trade confirmation and periodic
reporting, continuing evaluation of investment performance and consultation
on investment objectives. These programs differ in structure. As such, each
client should evaluate whether a given program or arrangement is suitable for
their needs while considering such factors as account size, trading activity
and investment objectives.
Pooled Investment Vehicles
Semper Augustus Investment Partners LP (“SAI LP”) is a limited partnership
sponsored by Semper Augustus. SAI LP may be more risky than separately
managed accounts. The partnership may invest in more highly concentrated
positions, may engage in short sales, more extensive options trading,
investments in illiquid securities and private investments; which may or may
not be utilized in separate accounts (particularly in smaller accounts). For
further risk disclosures and information, a prospective client must read and
review the appropriate investment documents of SAI LP, although this is
neither an offer of securities of SAI LP nor a solicitation of an offer of
securities of SAI LP.
Investors in SAI LP will receive a confidential private placement memorandum
(PPM) which contains a detailed description of the types of investments
Semper Augustus may cause SAI LP to invest in and the corresponding risks
associated with those investments as well as disclosure regarding fees,
service providers, conflicts of interest, tax considerations, trading and other
related information.
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Retirement Rollovers – Potential for Conflict of Interest
A client or prospective client leaving an employer typically has four options
regarding an existing retirement plan (and may engage in a combination of
these options): (i) leave the money in the former employer’s plan, if permitted,
(ii) roll over the assets to the new employer’s plan, if one is available and
rollovers are permitted, (iii) roll over to an Individual Retirement Account
(“IRA”), or (iv) cash out the account value (which could, depending upon the
client’s age, result in adverse tax consequences). If Semper Augustus
recommends that a client roll over their retirement plan assets into an account
to be managed by Semper Augustus, such a recommendation creates a
conflict of interest if Semper Augustus will earn an advisory fee on the rolled
over assets. No client is under any obligation to rollover retirement plan
assets to an account managed by Semper Augustus. The Chief Compliance
Officer of Semper Augustus remains available to address any questions that
a client or prospective client may have regarding the potential for conflict of
interest presented by such rollover recommendation.
Asset Management
Assets are generally invested in individual securities.
Assets Under Management as of 12/31/2024 were: $693,022,000. These
assets represent discretionary assets.
Stocks and bonds may be purchased or sold through a brokerage account
when appropriate. The brokerage firm charges a fee for stock and bond
trades. Semper Augustus does not receive any compensation, in any form,
from fund companies. Custodians of assets provide services to Semper
Augustus.
Investments may also include: equities (stocks), warrants, corporate debt
securities, commercial paper, certificates of deposit, municipal securities,
investment company securities (variable life insurance, variable annuities,
and mutual fund shares), U. S. government securities, options contracts,
futures contracts, short sales and interests in partnerships.
Initial public offerings (IPOs) generally are not available through Semper
Augustus.
From time to time, we may invest in a mutual fund that charges underlying
management fees. Typically, uninvested cash balances are held in money
market mutual funds and/or cash management programs provided by the
account custodian. In these situations, clients will pay the underlying fees
associated with the mutual fund AND the Semper Augustus management
fees discussed above. This may result in a negative return on assets held in
cash management programs / cash. See the Fees and Compensation
Section.
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Termination of Agreement
A client may terminate any of the aforementioned agreements at any time by
notifying Semper Augustus in writing and paying the fees due on the account
(See Fees and Compensation below on pro-rata fee calculations).
Semper Augustus may terminate any of the aforementioned agreements at
any time by notifying the client in writing.
If the client made an advance payment, Semper Augustus will refund any
unearned portion of the advance payment.
Fees and Compensation (5.)
Description
Semper Augustus bases its fees on a percentage of assets under
management.
Standard fee: 1.25% of Assets per year.
Fees are normally charged on a pro-rata basis and calculated on an
account’s fair market asset value as of the last business day of the quarter.
In certain circumstances, our total fee is negotiable.
Current client relationships may exist where the fees are higher or lower than
the fee schedule above.
No fees are charged in advance and fees may be deducted from the account
or under separate arrangements billed directly to you.
An advisory client will have a period of five (5) business days from the date of
the signing of the investment advisory agreement to unconditionally rescind
the agreement and receive a full refund of all fees.
Semper Augustus, in its sole discretion, may waive its minimum fee and/or
charge a lesser investment advisory fee based upon certain criteria (e.g.,
historical relationship, type of assets, anticipated future earning capacity,
anticipated future additional assets, dollar amounts of assets to be managed,
related accounts, account composition, negotiations with clients, etc.).
New Accounts Started in a Quarter:
New accounts funded during a quarter are billed on a pro-rata basis from the
date of initial deposit.
Accounts Terminated in a Quarter:
The client or the investment manager may terminate an Agreement by written
notice to the other party. At termination, fees will be billed on a pro-rata basis
for the portion of the quarter completed (The portfolio value at the termination
date, adjusted for the number of days during the billing quarter prior to
termination).
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Fee Billing
Investment management fees are billed quarterly based on the fair market
asset value of the account, in arrears, meaning that we invoice you after the
three-month billing period has ended. Payment in full is expected upon
invoice presentation. Fees are usually deducted from a designated client
account to facilitate billing. The client must consent in advance to direct
debiting of their investment account (typically done via the account
application). Unpaid fees are subject to 1.5% compounded monthly rates if
the fee remains unpaid after 30 days.
Other Fees
Custodians may charge transaction fees on purchases or sales of certain
mutual funds and exchange-traded funds. These transaction charges are
usually small and incidental to the purchase or sale of a security. The
selection of the security is more important than the nominal fee that the
custodian charges to buy or sell the security.
Limited partners in SAI LP may be subject to the following fees as well that
are described in detail in the Confidential Private Placement Memorandum
that limited partners receive:
Incentive Reallocation: At the end of each fiscal quarter, the General Partner
will be allocated an incentive reallocation based on the relative performance
of the SAI LP compared to the performance of the S&P 500 from those limited
partners who are “qualified clients.” The incentive reallocation percentage
equals 20% of the relative performance for the quarter. There will be an
incentive reallocation for any fiscal quarter only to the extent that the actual
increase or decrease in the gross investment performance allocated to a
limited partner’s capital account for such quarter exceeds the hurdle rate, and
any underperformance in prior periods have been eliminated by
outperformance in the current period. Once an incentive reallocation is
assessed, it is not refundable even if the limited partner incurs losses or
relative underperformance thereafter. The General Partner may waive the
incentive reallocation in certain circumstances.
Management Fee: At the end of each calendar month, the General Partner
will be paid by SAI LP a management fee equal to one twelfth of one and
one-quarter percent (1/12 of 1.25%) of the value of each limited partner’s
book capital account. The management fee will be deducted after determining
the profits or losses of SAI LP for each calendar month. Any incentive
reallocation allocated to the General Partner will be in addition to the
management fee. The General Partner, in its discretion, may waive or reduce
the management fee for certain limited partners.
Other Expenses: In addition to the fees charged by the General Partner, SAI
LP is obligated to pay brokerage commissions, custodial fees and other
trading and investment related expenses. In addition, SAI LP also is obligated
to pay its legal, accounting, bookkeeping, auditing, filing, administrative and
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other regular operating expenses and extraordinary expenses which may
occur in the operation of SAI LP’s business.
For further details or definitions, potential limited partners should refer to the
confidential PPM.
Expense Ratios
From time to time, we may invest in a mutual fund that charges underlying
management fees. Typically, uninvested cash balances are held in money
market mutual funds and\or cash management programs provided by the
account custodian. In these situations, clients will pay the underlying fees
associated with the mutual fund and the Semper Augustus management fees
discussed above. This may result in a negative return on those assets.
Clients have the option of purchasing these mutual funds that we recommend
through other brokers or agents not affiliated with us.
Past Due Accounts and Termination of Agreement
Semper Augustus reserves the right to stop work on any account where fees
are more than 30 days overdue. In addition, Semper Augustus reserves the
right to terminate any engagement at its discretion.
Performance-Based Fees (6.)
Sharing of Capital Gains
Our fees generally are not based on a share of the capital gains or capital
appreciation of managed accounts, except in certain client accounts including
SAI LP.
Certain client accounts (including limited partners in SAI LP) may be subject
to a performance fee so they must be “qualified clients” under applicable
federal securities laws and regulations. All clients that will be charged
performance fees must have at least $1,100,000 invested with the Adviser or
have a net worth of more than $2,200,000 at the time of entering into an
investment advisory agreement (excluding the value of their personal
residence).
Performance fees may create an incentive for Semper Augustus to make
investments that involve more risk and are more speculative than would be
the case in the absence of a performance-based fee. Performance fees are
calculated based on unrealized appreciation as well as realized gains in the
clients’ accounts so Semper Augustus may receive increased compensation
based on this method of calculation.
If you do not qualify for a performance based fee, be advised a conflict of
interest may exist whereby Semper Augustus may have an incentive to
allocate investment opportunity to accounts where a performance fee exists.
Semper Augustus had adopted trade allocation policies to address the
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allocation of investment opportunities between investors. Furthermore, certain
accounts have difference risk tolerances which be lead to different investment
holdings and/or concentrations between accounts.
Performance based fees will only be charged in accordance with the
provisions of Rule 205-3 of the Investment Advisors Act of 1940 and/or
applicable state regulations.
Types of Clients (7.)
Description
Semper Augustus generally provides investment advice to individuals, pooled
investment vehicles, pension and profit sharing plans, trusts, estates,
endowments, charitable organizations, corporations and other business
entities.
Client relationships vary in scope and length of service.
Account Minimums
Our minimum account size is $1 million of assets under management, which
equates to an annual fee of $12,500. Our minimum annual fee is $12,500.
We have the discretion to waive the account minimum and minimum annual
fee at any time and have waived the minimum. Exceptions to account
minimums may apply to employees of Semper Augustus and their relatives,
or relatives of existing clients and other criteria outlined in Section 5 Fees and
Compensation.
SAI LP has a minimum investment of $500,000 per investor, but we may
waive this minimum at any time.
Methods of Analysis, Investment Strategies and Risk of Loss
(8.)
Methods of Analysis
Security analysis methods may include fundamental analysis, technical
analysis, and cyclical analysis.
The main sources of information include Bloomberg services, financial
newspapers and magazines, inspections of corporate activities, research
materials prepared by others, corporate rating services, timing services,
annual reports, prospectuses, filings with the Securities and Exchange
Commission, and company press releases.
Investment Strategies
We commit assets under management to securities when we believe they are
inexpensive and reduce exposure to securities when we believe they are
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overvalued. This philosophy leads us to seek a “margin of safety” and to
avoid short-term trading strategies as our core investment philosophy. In
addition, this discipline may require our absence from purchases for extended
periods.
We believe the capital markets are efficient over long periods of time and
inefficient in the short term. Our historical research indicates that over full
market cycles stocks have generated total returns roughly six percentage
points above the rate of inflation, bonds have returned one to two percent
above the rate of inflation and cash yields have returned roughly the
approximate inflation. Thus, we believe stocks are a superior long-term asset
class to other asset classes and should normally be over weighted in
portfolios. We take exception to this principle during periods of fundamental
overvaluation.
Our fundamental research incorporates analysis of the balance sheet, income
statement components, and cash flow of companies. We may interview
management, customers, and suppliers. We make decisions as to the
sustainability of market position or leadership and frequently assess the
quality of the companies in client portfolios. We believe that investment in,
and long-term ownership of, high-quality cash generating companies, which
grow their business franchise at a faster rate than the overall economy,
provide the most rewarding long-term returns on capital employed.
We seek to avoid overpaying for businesses owned in our client portfolios.
Our process incorporates the value of a company relative to earnings, book
value, cash flow, and dividends, as well as the projected growth rates of these
companies. We evaluate businesses as a private investor would do when
buying an entire company, which we believe helps us understand the
underlying value of what we own.
We may occasionally engage in margin transactions where we purchase
stocks for your portfolio with money borrowed from your brokerage account.
This allows you to purchase more stock that you would be able to with your
available cash and allows us to purchase stock without selling other holdings.
Equity Investments
Through fundamental analysis, we strive to invest in companies who can, in
our opinion, grow their sales, cash flows and profits at a faster rate than the
economy. We look for companies that consistently generate free cash flow.
We evaluate the quality and integrity of management, often through one-on-
one interviews with management at their corporate headquarters or in our
office via virtual meetings and telephone calls. We talk to other participants in
the selected industries including suppliers and distributors, customers, and
competitors.
Our investment philosophy is a fundamental, bottom-up approach where we
focus on uncovering individual equity opportunities through risk-adjusted
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investments. However, our approach inherently includes a review of
economic and market conditions as these impact the entire universe of
stocks. We seek to make strategic asset allocations based on our
understanding of client objectives, risk tolerances, and our proprietary view of
the financial markets.
We are generally pleased when the stock of a company we would like to buy
drops significantly in price due to short-term events, if the long-term nature of
the company is sound. We believe these short-term events allow us to build a
long-term position at favorable prices.
Fixed Income and Cash Equivalents
Our fixed income approach encompasses a review of the risk and reward
tradeoff. We evaluate:
• Quality spreads which are also called credit spreads.
• Slope of the yield curve. The yield curve indicates the various yields
that are currently being offered on similar quality bonds of different
maturity.
• Duration. A bond’s sensitivity to interest rates, factoring in when
interest payments are made as well as the final payment. For every
1% change in interest rates, the value of your bond will approximately
change by the duration of that bond.
• Convexity properties in general, the higher the convexity, the less
sensitive the bond price is to interest rate shifts and the lower the
convexity, the more sensitive it is.
•
Inflation and economic factors.
• Absolute yield which is the yield on the bond at the time we buy. For
example 5% yield-to-maturity (combines coupon and future price
movement back to par) is an absolute yield.
• Benchmark characteristics such as how the bond compares in price to
other similar bonds and how liquid (saleable) the bond might be.
We seek to provide a steady and non-interrupted income stream and believe
risk capital should typically be employed in non-fixed income asset classes.
Depending on the taxability of your portfolio and other considerations, we
typically invest in U.S. government and agency securities, highly rated
corporate securities, commercial paper, highly rated municipal securities and
mortgage-backed securities.
Most fixed income securities we purchase on behalf of clients are held to
maturity. However, decisions to alter asset allocations or the characteristics
of the fixed income portion of a portfolio may necessitate a sale of these
securities. Thus, liquidity of the security is a key consideration when
purchasing fixed income obligations.
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Our investment approach may involve investing in cash and cash equivalent
vehicles. An individual client’s allocation to cash and cash equivalents
depends on his or her individual circumstances. However, as a defensive
strategy and to ensure adequate cash is available to invest in equities and
other securities, cash may be a significant investment for an individual client
and may continue to be a significant investment for a considerable period of
time. Since cash and cash equivalents may have a low expected return, an
individual client portfolio may experience low or negative net returns as a
result of management fees and/or fees related to cash and cash equivalent
management fees.
Short Sales and Options
Short sales of equity securities are only made within SAI LP. We borrow
shares of a stock for SAI LP from someone who owns the stock on a promise
to replace the shares on a future date. Those borrowed shares are then sold.
At a future date, we buy the same stock and return the shares to the original
owner. We engage in short selling based on our determination that the stock
will go down in price after we have borrowed the shares. If we are correct
and the stock price has gone down since the shares were purchased from the
original owner, the client account realizes the profit. See the SAI LP PPM for
further information.
Options are only used as an investment strategy for our high net worth clients
and sophisticated investors as well as SAI LP. An option is a contract that
gives the buyer the right, but not the obligation, to buy or sell an asset (such
as a share of stock) at a specific price on or before a certain date. An option,
just like a stock or bond, is a security. An option is also a derivative, because
it derives its value from an underlying asset.
The two types of options are calls and puts:
• A call gives us the right to buy an asset at a certain price within a
specific period of time. We will buy a call if we have determined that
the stock will increase substantially before the option expires. We will
sell a call if we have determined that a stock is expensive and would
like to sell the stock at the strike plus options premium received
(“covered call”).
• A put gives us the right to sell an asset at a certain price within a
specific period of time. We will buy a put if we have determined that
the price of the stock will fall before the option expires. We will sell a
put if we have determined that the price of the stock is favorable and
would like to purchase the stock at the strike price less options
premium received (“naked put”).
We will use options to speculate on the possibility of sharp price swings. We
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will also use options to "hedge" a purchase of the underlying security; in other
words, we will use an option purchase to limit the potential upside and
downside of a security we have purchased for your portfolio.
We use "covered calls", in which we sell an option on a security you own. In
this strategy, you receive a fee for making the option available, and the
person purchasing the option has the right to buy the security from you at an
agreed-upon price known as the strike price.
We use “naked puts” to acquire a security. In this strategy, you will receive a
fee for making the option available and the person purchasing the option has
the right to sell the security to you at an agreed upon price known as the
strike price.
Other Clients
While managing accounts and managing the overall trading costs related to
the management of a client account, Semper Augustus performs investment
advisory services for various other clients. Semper Augustus agrees to act in
a manner consistent with its fiduciary obligation to deal fairly with all clients
when taking investment actions. However, Semper Augustus may give
advice and take action in the performance of its duties with respect to any of
its other clients that may differ from the timing or nature of action taken with
respect to a particular individual account. Semper Augustus shall not be
under any obligation to purchase or sell for the account any security that
Semper Augustus, its officers, or employees may purchase or sell for its or
their own accounts or purchase or sell or recommend for purchase or sale for
the account of another client if, in the sole discretion of Semper Augustus,
such action is not practical or desirable for the account of client.
Generally, different client portfolios and investment pools have differing risk
parameters and investment objectives and therefore the underlying
investments among portfolios may differ.
Primary Research and Other Sources
Research is conducted by our firm and may be obtained from any or all of the
following sources: vendors and providers of analytical models and valuation
models, broker-generated research, and traditional business and other
publications. We obtain and review financial information directly from the
companies and meet with or directly contact corporate management,
customers, and suppliers.
Risk of Loss
All investment programs have certain risks that are borne by the investor.
Our investment approach seeks to address risks we perceive. All clients may
face the following investment risks:
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• Concentrated Investments: We concentrate our equity investments in
generally fewer than 30 investments. Some of the positions are much
larger in size than others, subjecting greater exposure to loss. While
we strive to keep quality high and the price paid low, concentration can
expose the portfolio to less correlation to the broad stock market and at
times can move adversely to market prices.
•
Interest-rate Risk: Fluctuations in interest rates may 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: The price of a security, bond, or mutual fund may drop in
reaction to tangible and intangible events and conditions. This type of
risk is caused by external factors independent of a security’s particular
underlying circumstances. For example, political, economic and social
conditions may trigger market events.
•
Inflation Risk: When any type of inflation is present, a dollar today will
not buy as much as 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.
• Business Risk: These risks are associated with a particular industry or
a particular company within an industry. For example, integrated oil-
drilling companies depend on finding oil and then refining it, a lengthy
process, before they can generate a profit. They carry a higher risk of
profitability than an electric company, which generates its income from
a steady stream of customers who buy electricity no matter what the
economic environment is like.
• 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.
• Financial Risk: Excessive borrowing to finance a business’ operations
increases the risk of profitability, because the company must meet the
terms of its obligations in good times and bad. During periods of
financial stress, the inability to meet loan obligations may result in
bankruptcy and/or a declining market value.
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Disciplinary Information (9.)
Legal and Disciplinary
The firm and its supervised persons have not been involved in legal or
disciplinary events related to past or present investment clients.
Other Financial Industry Activities and Affiliations (10.)
Financial Industry Activities
Semper Augustus is registered as a Registered Investment Adviser with the
United States Securities and Exchange Commission (SEC).
Affiliations
Semper Augustus is not affiliated with or owned by any broker-dealer or
outside organization.
Semper Augustus operates a limited partnership, SAI LP, that seeks to
generate long-term capital appreciation by investing in equities and related
securities. This disclosure is neither an offer of securities in SAI LP nor
solicitation of an offer of securities of SAI LP. If SAI LP is offered to you, we
are required to provide you with the confidential PPM.
There is a natural conflict of interest that exists between SAI LP and other
clients. Whereas SAI LP has certain performance based fees that do not
exist in other arrangements, a conflict exists as to where to place limited
investment opportunities. As a long-term investor that generally avoids IPO’s
we believe the risk associated with this conflict is significantly diminished.
Furthermore, we have adopted allocation policies for partial fills (See
Brokerage Practice section) that further reduce this inherent conflict.
Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading (11.)
Code of Ethics
The employees of Semper Augustus have committed to a Code of Ethics that
is available for review by clients and prospective clients upon request. The
firm will provide a copy of the Code of Ethics to any client or prospective client
upon request. Principals with the Chartered Financial Analyst (CFA)
designation are required to adhere to the CFA Institute Code of Ethics and
Standards of Professional Conduct. Christopher P. Bloomstran is a CFA
charterholder. Employee transactions may create conflicts of interest with
clients; however, employees may not trade ahead of clients.
As these situations represent a conflict of interest, we have established the
following additional restrictions in order to ensure its fiduciary responsibilities:
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1. No officer or employee of our firm may prefer his or her own interest to
that of an advisory client.
2. We maintain records of securities holdings and transactions for our
firm and anyone associated with this advisory practice with access to
advisory recommendations. These holdings are reviewed on a regular
basis by the firm’s Chief Compliance Officer.
3. All of our principals and employees must act in accordance with all
applicable Federal and State regulations governing registered
investment advisory practice.
4. Any individual not in observance of the above may be subject to
disciplinary action, including termination.
Participation or Interest in Client Transactions
Semper Augustus and its employees may buy or sell securities that are also
held by clients. Employees may not trade their own securities ahead of client
trades. Employees are required to comply with the provisions of the Semper
Augustus Policies and Procedures. Employees who own a partial interest in
SAI LP participate in transactions by virtue of being partial owners of SAI LP.
Personal Trading
The Chief Compliance Officer of Semper Augustus is Chad S Christensen.
He reviews all employee trades each quarter. His trades are reviewed by
Christopher P. Bloomstran. The personal trading reviews and preclearance
of trades ensure that the personal trading of employees does not affect the
markets, and that clients of the firm receive preferential treatment. Since
most employee trades are small equity trades, the trades do not affect the
securities markets.
SAI has adopted written policies and procedures to detect and prevent insider
trading. This includes policies relating to possession and use of material,
non-public information.
Brokerage Practices (12.)
The Custodians and Brokers We Use
Semper Augustus does not maintain physical custody of your assets;
although we may be deemed to have custody of your assets if you give us
authority to withdraw assets from your account (see Item 15 – Custody,
below).
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Your assets must be maintained in an account at a “qualified custodian,”
generally a broker-dealer or bank.
We recommend that our clients use Schwab, a registered broker-dealer,
member SIPC, as the qualified custodian. We are independently owned and
operated and are not affiliated with Schwab.
We believe that our relationship with Charles Schwab & Co. (Schwab) is
materially important to us in the short-term operations of our business.
Although we believe the services provided by Schwab are widely available
from other broker-dealers, a material change in our relationship with Schwab
would require a change of a number of our operational procedures in the
short-term with significant time and expense to us. We believe our
relationship with Schwab to be beneficial to both organizations.
Schwab will hold your assets in a brokerage account and buy and sell
securities when we instruct them to. While we recommend that you use
Schwab as custodian/broker, you will decide whether to do so and if you use
Schwab you will open your account with Schwab by entering into an account
agreement directly with them. We do not open the account for you, although
we may assist you in doing so. Conflicts of interest associated with this
arrangement are described below as well as in Item 14 (Client referrals and
other compensation). You should consider these conflicts of interest when
selecting your custodian.
In addition to Schwab, we have established relationships at Janney, U.S.
Bank (Private Client Services), Inspira Financial, Interactive Brokers, Argent
Institutional Trust, Paducah Bank and Trust, JP Morgan Chase and Whittier
Trust and we have clients that have chosen to use these firms. You are not
required to open accounts with any firm we may recommend, and you
generally may open account with a custodian or broker of your choosing.
Even though your account is maintained at a custodian or broker-dealer, we
may still use other brokers to execute trades for your account as described
below.
In certain cases, we may utilize a broker that is different from the custodian of
your assets.
Selecting Custodians and Brokerage Firms
We seek to use a custodian/broker who will hold your assets and execute
transactions on terms that are, overall, most advantageous when compared
to other available providers and their services.
Broker selection is important to clients since all security transactions incur
costs and potential lost opportunities. The next several paragraphs include
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an overview of our relationship with brokers, the trade-offs we evaluate and
important disclosures for you.
We consider a wide range of factors, including, among others:
• Combination of transaction execution services and asset custody
services
• Capability to execute, clear, and settle trades (buy and sell securities
for your account)
• Capability to facilitate transfers and payments to and from accounts
(wire transfers, check requests, bill payment, etc.)
• Breadth of available investment products (stocks, bonds, mutual funds,
exchange-traded funds [ETFs], etc.)
• Availability of investment research and tools that assist us in making
investment decisions
• Quality of services
• Competitiveness of the price of those services (commission rates, margin
interest rates, other fees, etc.) and willingness to negotiate the prices
• Reputation, financial strength, security and stability
• Prior service to us and our other clients
• Availability of other products and services that benefit us, as discussed
below
Placement of brokerage business is a function of our being satisfied that we
are getting one, or a combination of, the various services listed above that we
believe to be helpful and important to our responsibility to all of our clients.
We do not receive fees or commissions from any of these arrangements,
although certain services are provided to Semper Augustus (see below).
Another factor used to determine a custodian of assets is a client desire or
legal requirement that a corporate trustee be utilized. Fees charged by
trustees, the legal location of a trustee and the “philosophy” of the trustee
may be considered by a client. Fees are typically charged by corporate
trustees directly to the clients. These fees are not determined by us, although
we seek to negotiate favorable rates on behalf of clients with certain
institutions. We have negotiated rates with U.S. Bank Private Client Services.
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Your Brokerage and Custody Costs
For our clients’ accounts that Schwab maintains, Schwab generally does not
charge you separately for custody services but is compensated by charging
you commissions or other fees on trades and / or receiving payment for order
flow that it executes or that settle into your Schwab account. Schwab is also
compensated by earning interest on the uninvested cash in your account in
Schwab’s Cash Features Program.
In addition to commissions, Schwab charges you a flat dollar amount as a
“prime broker” or “trade away” fee for each trade that we have executed by a
different broker-dealer but where the securities bought or the funds from the
securities sold are deposited (settled) into your Schwab account. These fees
are in addition to the commissions or other compensation you pay the
executing broker-dealer. Because of this, in order to minimize your trading
costs, we have Schwab execute most trades for accounts held at Schwab.
We are not required to select the broker or dealer that charges the lowest
transaction cost, even if that broker provides execution quality comparable to
other brokers or dealers. For accounts held at Schwab, although we are not
required to execute all trades through Schwab, we have determined that
having Schwab execute most trades is consistent with our duty to seek “best
execution” of your trades. Best execution means the most favorable terms for
a transaction based on relevant factors, including those listed above. See
Selecting Custodians and Brokerage Firms section. By using another broker
or dealer you may pay lower transaction costs.
For accounts not held at Schwab, we typically utilize third-party brokers to
execute trades and settle into your account. In these trades, the commission
is determined based on the factors outlined in the “Best Execution” section
below.
Products and Services Available to Us from Schwab
Schwab Advisor Services™ is Schwab’s business serving independent
investment advisory firms like us. They provide us and our clients with access
to its institutional brokerage services— trading, custody, reporting, and
related services—many of which are not typically available to Schwab retail
customers. However, certain retail investors may be able to get institutional
brokerage services from Schwab without going through us. Schwab also
makes available various support services. Some of those services help us
manage or administer our clients’ accounts, while others help us manage and
grow our business. Schwab’s support services generally are available on an
unsolicited basis (we don’t have to request them) and at no charge to us.
Following is a more detailed description of Schwab’s support services:
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Services That Benefit You.
Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of
client assets. The investment products available through Schwab include
some to which we might not otherwise have access or that would require a
significantly higher minimum initial investment by our clients. Schwab’s
services described in this paragraph generally benefit you and your account.
Services That May Not Directly Benefit You.
Schwab also makes available to us other products and services that benefit
us but may not directly benefit you or your account. These products and
services assist us in managing and administering our clients’ accounts. They
include investment research, both Schwab’s own and that of third parties. We
may use this research to service all or a substantial number of our clients’
accounts, including accounts not maintained at Schwab. In addition to
investment research, Schwab also makes available software and other
technology that:
• Provide access to client account data (such as duplicate trade confirmations
and account statements)
• Facilitate trade execution and allocate aggregated trade orders for multiple
client accounts
• Provide pricing and other market data
• Facilitate payment of our fees from our clients’ accounts
• Assist with back-office functions, recordkeeping, and client reporting
Services That Generally Benefit Only Us.
Schwab also offers other services intended to help us manage and further
develop our business enterprise. These services include:
• Educational conferences and events
• Consulting on technology, compliance, legal, and business needs
• Publications and conferences on practice management and business
succession
• Access to employee benefits providers, human capital consultants, and
insurance providers
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• Marketing consulting and support
Schwab may provide some of these services itself. In other cases, it will
arrange for third-party vendors to provide the services to us. Schwab may
also discount or waive its fees for some of these services or pay all or a part
of a third party’s fees. Schwab may also provide us with other benefits, such
as occasional business entertainment of our personnel. If we did not have
substantial accounts with Schwab, we would be required to pay for these
services from our own resources.
We utilize the majority of services offered to us by Schwab. We believe this
improves our firm’s investment and administrative capabilities and our ability
to meet your needs.
Our Interest in Schwab’s Services
The availability of these services from Schwab benefits us because we do not
have to produce or purchase them. We do not have to pay for Schwab’s
services. These services are not contingent upon us committing any specific
amount of business to Schwab in trading commissions or assets in custody.
The fact that we receive these benefits from Schwab is an incentive for us to
recommend the use of Schwab rather than making such a decision based on
your interest in receiving the best value in custody services and the most
favorable execution of your transactions. This is a potential conflict of interest.
We believe, however, that our recommendation of Schwab as custodian and
broker is in the best interest of our clients. Our recommendation is primarily
supported by the scope, quality, and price of Schwab’s services (see
“Selecting Broker and Custodians”) and not Schwab’s services that benefit
only us.
Best Execution
We evaluate the reasonableness of the overall brokerage commissions paid
by our clients. We exercise discretion in seeking the best execution available.
We consider certain qualitative considerations and therefore do not consider it
an obligation to get the “cheapest” execution. Thus, commissions paid for
certain security transactions executed by us may be more than other broker-
dealers. We may determine, in good faith, the amount of commission with
respect to the brokerage, execution, research and other services furnished by
such broker-dealer, viewed in terms of either that particular transaction or our
overall responsibility with respect to the accounts we manage is reasonable.
We do not receive any portion of the trading fees, however “soft dollars” may
be received as noted below.
Where discretionary authority exists, our firm will normally determine:
securities to be bought or sold; amount of securities to be bought or sold;
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whether transactions should be combined (blocked) with those of other
clients; broker or dealer to be used; and commission rates paid.
Security transactions incur costs that include the stated commission fees, the
difference between the bid price and the ask price, and other “frictional costs”.
Our trading process is designed to ensure these costs are minimized and
balance against the benefits of using a particular broker.
Semper Augustus believes that its overriding obligation is to obtain best
execution without jeopardizing its business relationships, and in any case, its
policy and practice is to act in the best interest of its clients.
Certain clients may be affiliated and/or employed by broker-dealers with
whom we transact business. In dealing with these broker-dealers, we will
trade on the same basis as we do with any other broker-dealer.
Research and Other Soft Dollar Benefits
The research services furnished by a specific broker for commissions from a
specific account may be used in servicing all of our clients. Moreover, it is
possible that certain research services might not be useful to the specific
account paying the brokerage commission.
Research provided by a brokerage firm, may include: written analysis of
industries and companies; direct and indirect contact with investment
analysts; daily stock, bond and money market information; economic and
general business facts/forecasts. Some of these services may be
electronically generated from various research and statistical databases or in
the form of periodical reports either generated by the brokerage firm or
subscription-type services provided by third parties. We benefit from these
services because we do not have to produce or pay for the research,
products or services.
Order Aggregation
Most trades we make for our clients are aggregated for trading. This is called
“block trading”. We may place an aggregate purchase or sale order for a
single security with a broker-dealer when we determine that it is consistent
with the best interests of our clients to do so. Orders are allocated pursuant
to firm policies intended to assume a fair and reasonable allocation among
clients.
To the extent that an aggregated order is filled at different prices during a
trading day at a respective broker, each participating account will receive the
same average price and pay the same average commission for the
transactions. Certain brokers charge a minimum fee per trade. As such,
transactions in an individual account may be subject to this minimum
transaction fee regardless of the number of shares purchased or the number
of partial fills completed until an order is fully executed and filled.
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Partial Fills:
Should an aggregated order be partially filled during a trading day,
participating accounts will be allocated pro-rata based upon each client’s
percentage of the entire order at a respective broker. If the pro-rata allocation
would result in inordinately small numbers of shares being allocated, priority
will normally be given to the completion of smaller orders. Numerous
accounts ending up with small (odd lot) positions are neither practical nor
desirable.
Since we work with a variety of custodians, inherently we utilize multiple
brokers in executing trade orders. In order to reduce the overall costs of
trading (wherein we are bidding against our own orders), we typically will
place one trade with one broker at a time and rotate the trades until each
block trade is complete. As a result of this rotating strategy and purchases
throughout a given trading day, differing prices may occur between brokers
and a given broker may not execute the full balance of their trades. As such,
a client may receive a different price from another set of clients and/or may
not participate in the execution of trade (thereby either not receiving securities
or not selling the securities). While we strive to minimize the impact of these
differences and unfilled executions, differences do occur.
We may also set a client target allocation and sell positions to reduce to the
stated percentage. Additionally, since our employees and owners of Semper
Augustus have investments in common investment pools, conditions occur
wherein these pooled investment vehicles are subject to the same differences
as individual client accounts. Since Semper Augustus employees and
owners are fractional owners of these pools on a pro-rata basis, these
differences are not considered violations of our Code of Ethics.
Directed Brokerage or Custodian
If you direct us to use a specific broker or custodian, you should be aware
that: (1) higher commission rates may be incurred due to our inability to
negotiate; (2) volume discounts obtained when clients’ transactions are
“blocked” with those of other clients may not be available; (3) execution of all
trades by one broker or custodian, at the client’s direction, could result in
failure to receive the best execution of some transactions; and (4) you may be
subject to custodian fees.
You may direct us to utilize a specific brokerage firm or custodian by
providing instructions to use. In this case, we may or may not receive
research or other services (via soft dollars) as a result of your instruction.
Further, the broker-dealer or custodian you have selected must allow us to
trade in your account or we will be unable to manage the account.
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Review of Accounts (13.)
Periodic Reviews
A long-term relationship with an investment-management firm ensures that
your financial condition is monitored on a regular and personal basis. We
meet with clients upon request. Periodically, at our discretion, we may
discuss the portfolios or market conditions with clients.
As we work with you we improve our understanding of your needs,
expectations, objectives and goals, thereby enabling us to improve the
creation of a portfolio for you. This personalized service provides a
comprehensive investment portfolio.
Clients may meet with Chad S Christensen, Chief Compliance Officer, and/or
Christopher P. Bloomstran, President and Chief Investment Officer or one of
our staff members. Meetings may occur in person, by phone, virtual meeting
or conference call.
Review Triggers
Other conditions that may trigger a review are changes in the tax laws, new
investment information, and changes in a client's own situation. We request
clients notify us if there is a change in their financial situation.
Regular Reports
Account reviewers are principals of Semper Augustus. We consider the
client's current security positions and the likelihood that the performance of
each security will contribute to the investment objectives of the client.
Separate account clients should receive a quarterly report furnished by the
custodian. Upon request, we will provide a portfolio holdings report to clients.
Clients may request more frequent reporting by their custodian.
SAI LP limited partners receive a quarterly report furnished by Liccar Fund
Services, an independent CPA firm, that acts as the independent
representative for the limited partners.
Client Referrals and Other Compensation (14.)
Referrals Out
Semper Augustus does not accept referral fees or any form of remuneration
from other professionals when a prospect or client is referred to them. We
may pay these individuals during our normal course of business for goods
and services provided to Semper Augustus.
Other Compensation
Semper Augustus may benefit by receiving new client referrals from broker-
dealers who earn commission on trades for accounts of existing clients, and,
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as a result, a conflict may arise between Semper Augustus’ interest in such
referrals and its obligations to seek the best execution of client trades.
We receive an economic benefit from Schwab in the form of the support
products and services it makes available to us and other independent
investment advisers whose clients maintain their accounts at Schwab. You do
not pay more for assets maintained at Schwab as a result of these
arrangements. However, we benefit from this arrangement because the cost
of these services would otherwise be borne directly by us. You should
consider these conflicts of interest when selecting a custodian. These
products and services, how they benefit us, and the related conflicts of
interest are described above (see Item 12 – Brokerage Practices). The
availability to us of Schwab’s products and services is not based on us giving
particular investment advice, such as buying particular securities for our
clients.
Custody (15.)
Do We Have Custody?
Under applicable government regulations, we are deemed to have custody of
your assets if, for example, you authorize us to instruct the qualified custodian
to deduct our advisory fees directly from your account or if you grant us
authority to move your money to another person’s account. The qualified
custodian maintains actual custody of your assets. You will receive account
statements directly from the qualified custodian at least quarterly. They will be
sent to the email or postal mailing address you provided to the qualified
custodian. You should carefully review those statements promptly when you
receive them. We also urge you to compare the qualified custodian’s account
statements to the periodic statements received from us. If there is a
discrepancy, please contact us AND the custodian.
With the exception of SAI LP, we do not act as a physical custodian of client
assets. The client maintains asset control.
Semper Augustus places trades for clients under a limited power of attorney.
For SAI LP, Semper Augustus is the general partner. In accordance with the
Limited Partnership Agreement, Semper Augustus is delegated numerous
and broad powers to operate the Partnership. As a result of the powers
delegated to it, Semper Augustus is considered to have custodial powers over
the assets held in SAI LP.
In order to mitigate the risk of Semper Augustus having custodial powers,
assets are held by a qualified custodian and withdrawals are subject to the
procedures of this qualified custodian. An independent accountant has been
engaged by SAI LP to perform a compilation of the financials on a monthly
basis. Furthermore, an annual audit is performed on SAI LP by an
independent auditor that is registered with the Public Company Accounting
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Oversight Board (PCAOB). Audited financial statements for SAI LP are
distributed to the Limited Partners within 120 days of year-end.
Liccar Fund Services, an independent CPA Firm, serves as the independent
representative for the limited partners of SAI LP.
Furthermore, Semper Augustus is subject to a “surprise cash exam” for
accounts deemed to have custody, which includes SAI LP. Semper Augustus
has engaged Ashland Partners and Company LLP, an independent CPA firm,
to conduct the surprise cash exam.
Account Statements
All assets are held at qualified custodians, which means the custodians
provide account statements directly to clients at their address of record at
least quarterly. Please carefully review these statements. Contact the
custodian of your account AND us if you have questions.
Performance Reports
Clients are urged to compare the account statements received directly from
their custodians to the performance report statements provided by Semper
Augustus.
Investment Discretion (16.)
Discretionary Authority for Trading
Semper Augustus accepts discretionary authority to manage securities
accounts on behalf of clients. Discretion means: Semper Augustus has the
authority to determine, without obtaining specific client consent, the securities
to be bought or sold, and the amount of the securities to be bought or sold.
We obtain this discretion through our Investment Advisory Agreement with
you.
In addition, the client approves the custodian to be used. Semper Augustus
does not receive any portion of the transaction fees or commissions paid by
the client to the custodian on certain trades. See “Research and Other Soft
Dollar Benefits” above for benefits we do receive.
Limited Power of Attorney
A limited power of attorney is a trading authorization for this purpose. You
sign a limited power of attorney so that we may execute trades in your
account. This limited power of attorney authorization is a part of the account
application with the custodian and/or is created through your Investment
Advisory Agreement executed with Semper Augustus.
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Voting Client Securities (17.)
Proxy Votes
Unless the client designates otherwise, Semper Augustus votes proxies for
securities over which it maintains discretionary authority consistent with its
proxy voting policy.
Semper Augustus has adopted proxy voting procedures. Under these
guidelines, Semper Augustus votes as recommended by company
management for most routine matters. (The only noted exceptions relate to
electing directors during proxy contests, changing the size of the board,
setting age limits for board members). Additionally, Semper Augustus will
generally vote against company stock option plan grants, other dilutive
actions, and any related share increase authorizations. For non-routine
proxy proposals, votes are cast in the best economic interest of each client,
as interpreted by Semper Augustus. Clients may direct how their shares are
voted in a proxy solicitation by providing advance notice to us.
Clients may obtain information on how Semper Augustus voted their
securities upon request. The detailed Proxy Voting Procedure is also
available upon request.
Financial Information (18.)
Financial Condition
Semper Augustus does not have any financial impairment that will preclude
the firm from meeting contractual commitments to clients.
A balance sheet is not required to be provided because Semper Augustus
does not require prepayment of fees of more than $1,200 per client, and six
months or more in advance.
Business Continuity Plan (19.)
General
Semper Augustus has a Business Continuity Plan in place that provides
detailed steps to mitigate and recover from the loss of office space,
communications, services or key people.
Disasters
The Business Continuity Plan covers natural disasters such as snow storms,
tornadoes, and flooding. The Plan covers man-made disasters such as loss
of electrical power, loss of water pressure, fire and others. The Plan also
addresses pandemic impacts on our business. Electronic files are backed up
and archived offsite.
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Alternate Offices
Alternate offices are identified to support ongoing operations in the event the
main office is unavailable. It is our intention to contact all clients within five
days of a disaster that dictates moving our office to an alternate location.
Loss of Key Personnel
Semper Augustus has identified alternative personnel which may be needed
to support Semper Augustus in the event of Chad S Christensen and/or
Christopher P. Bloomstran become seriously disabled or die.
Information Security Program (20.)
Information Security
Semper Augustus maintains an information security program to reduce the
risk that your personal and confidential information may be breached.
Privacy Notice
Semper Augustus is committed to maintaining the confidentiality, integrity and
security of the personal information that is entrusted to us.
The categories of nonpublic information that we collect from you may include
information about your personal finances, information about your health to the
extent that it is needed for the financial planning process, information about
transactions between you and third parties, and information from consumer
reporting agencies, e.g., credit reports. We use this information to help you
meet your personal financial goals.
With your permission, we disclose limited information to attorneys,
accountants, and mortgage lenders with whom you have established a
relationship. You may opt out from our sharing information with these
nonaffiliated third parties by notifying us at any time by telephone, mail, fax,
email, or in person. With your permission, we share a limited amount of
information about you with your brokerage firm in order to execute securities
transactions on your behalf.
We maintain a secure office to ensure that your information is not placed at
unreasonable risk. We employ a firewall barrier, secure data encryption
techniques and authentication procedures in our computer environment.
We do not provide your personal information to mailing list vendors or
solicitors. We require strict confidentiality in our agreements with unaffiliated
third parties that require access to your personal information, including
financial service companies, consultants, and auditors. Federal and state
securities regulators may review our company records and your personal
records as permitted by law.
Personally identifiable information about you will be maintained while you are
a client, and for the required period thereafter that records are required to be
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Semper Augustus Investments Group LLC
maintained by federal and state securities laws. After that time, information
may be destroyed.
We will notify you in advance if our privacy policy is expected to change. We
are required by law to deliver a Privacy Notice to you annually, in writing.
28
Semper Augustus Investments Group LLC
Part 2B of Form ADV: Brochure Supplement
Christopher P. Bloomstran
Semper Augustus Investments Group LLC
8000 Maryland Avenue, Suite 1165
St. Louis, MO 63105
Phone: (314) 322-2784
Fax: (303) 893-1207
www.semperaugustus.com
cpb@semperaugustus.com
This brochure supplement provides information about Christopher P. Bloomstran
that supplements the Semper Augustus Investments Group LLC brochure. You
should have received a copy of that brochure. Please contact Chad S Christensen
at (303) 893-1214 (csc@semperaugustus.com) if you did not receive Semper
Augustus Investments Group LLC’s brochure or if you have any questions about
the contents of this supplement.
Additional information about Semper Augustus Investments Group LLC is
available on the SEC’s website at www.adviserinfo.sec.gov. You can search this
site by a unique identifying number, known as a CRD number. The CRD number
for Christopher P. Bloomstran is 3154454.
March 26, 2025
1
Semper Augustus Investments Group LLC
Christopher P. Bloomstran, CFA
Item 2. Educational Background:
• Year of birth: 1968
•
Institutions:
o Bachelor of Science in Business Administration with an
emphasis in Finance from the University of Colorado (1991)
o Chartered Financial Analyst (1994)
• Business Experience:
o UMB Investment Advisors, St. Louis, Missouri, (1992-1998);
Vice President and Portfolio Manager
o Scout Funds, Kansas City, Missouri, (1995-1998): Scout
Balanced Fund Portfolio Manager
o Semper Augustus Investments Group LLC (1998 to present).
President and Chief Investment Officer
Item 3. Disciplinary Information:
• Christopher P. Bloomstran has no history of any disciplinary events.
Item 4. Other Business Activities:
• CFA Society of St. Louis, St. Louis, Missouri: Member (1994 to Present); Vice
President (2005 to 2006); President (2006-2007); Immediate Past President
(2007-2009); Board of Directors (2002 to 2021).
Item 5. Additional Compensation:
• Christopher P. Bloomstran does not receive any additional compensation
from third parties for providing investment advice to its clients and does not
compensate anyone for client referrals.
Item 6. Supervision:
• Christopher P. Bloomstran and all Semper Augustus Investment Team
professionals are supervised by policies and procedures relating to the
provision of investment advice. These policies include preauthorization of all
marketing materials, permanently recording all trading activity, reconciling
accounts to custodians’ records, and monitoring personal trading activities.
For additional information regarding Semper Augustus’ supervisory activities,
please call Chad S Christensen, Chief Compliance Officer, at 303-893-1214.
2
Semper Augustus Investments Group LLC
Education and Business Standards
Semper Augustus requires that client advisers in its employ have a bachelor's
degree and requires adherence to a stated ethical policy. Our standards require that
all individuals participating in the investment research process and client interaction
process possess a high degree of ethical standards and general business
experience as it relates to investment management and client needs.
Professional Certifications
Employees have earned certifications and credentials that are required to be
explained in further detail.
Chartered Financial Analyst (CFA): CFA charterholders are licensed by the CFA
Institute to use the CFA designation. CFA designation requirements:
• Hold a bachelor's degree from an accredited institution or have equivalent
education or work experience.
• Successful completion of all three exam levels of the CFA Program.
• Have 48 months of acceptable professional work experience in the
investment decision-making process.
• Fulfill society requirements, which vary by society. Unless you are upgrading
from affiliate membership, all societies require two sponsor statements as
part of each application; these are submitted online by your sponsors.
• Agree to adhere to and sign the Member's Agreement, a Professional
Conduct Statement, and any additional documentation requested by the CFA
Institute.
3
Semper Augustus Investments Group LLC
Part 2B of Form ADV: Brochure Supplement
Chad S Christensen
Semper Augustus Investments Group LLC
200 Plaza Drive Suite 240
Highlands Ranch, CO 80129
Phone: (303) 893-1214
Fax: (303) 893-1207
www.semperaugustus.com
csc@semperaugustus.com
This brochure supplement provides information about Chad S Christensen that
supplements the Semper Augustus Investments Group LLC brochure. You should
have received a copy of that brochure. Please contact Chad S Christensen if you
did not receive Semper Augustus Investments Group LLC’s brochure or if you have
any questions about the contents of this supplement.
Additional information about Semper Augustus Investments Group LLC is
available on the SEC’s website at www.adviserinfo.sec.gov. You can search this
site by a unique identifying number, known as a CRD number. The CRD number
for Chad S Christensen is 2866795.
March 26, 2025
1
Semper Augustus Investments Group LLC
Chad S Christensen, CPA, CPA-PFS
Item 2. Educational Background:
• Year of birth: 1970
•
Institutions:
o Bachelor of Science in Business Administration with an
emphasis in Accounting and Finance from the University of
Colorado (1992)
o Certified Public Accountant (1993)
o Certified Public Accountant/Personal Financial Specialist (2001)
• Business Experience:
o KPMG Peat Marwick LLP, Dallas, Texas (1992-1994); staff
auditor
o Ernst and Young LLP, Denver, Colorado (1994-1996); senior
auditor
o ALPS Mutual Funds Services, Inc., Denver, Colorado (1996-
1998); Fund Controller (1996-1998); Vice President and Director
of Mutual Funds Operations (1998)
o Westcore Funds, Denver, Colorado (1997-1998); Assistant
Treasurer
o Stonebridge Growth Fund, Inc., Denver, Colorado (1997-1998);
Vice-President. Stonebridge Aggressive Growth Fund, Inc.,
Denver, Colorado (1997-1998); Vice-President
o Semper Augustus Investments Group LLC (1998 to present);
Partner, Vice-President and Secretary
Item 3. Disciplinary Information:
• Chad S Christensen has no history of disciplinary events.
Item 4. Other Business Activities:
• Ronald McDonald House Charities of Denver, Inc., Denver, Colorado (2002 to
2007 and 2014 to 2015); Treasurer (2002 to 2005); President (2006); Past-
President and Secretary (2007); Member of the Board of Directors (2002 to
2007; 2014 to 2015). McDonald’s Charitable Investment Program, Oak Brook,
Illinois (2004-2006).
Item 5. Additional Compensation:
• Chad S Christensen does not receive any additional compensation from third
parties for providing investment advice to its clients and does not compensate
anyone for client referrals.
Item 6. Supervision:
• Chad S Christensen and all Semper Augustus Investment Team
professionals are supervised by policies and procedures relating to the
provision of investment advice. These policies include preauthorization of all
marketing materials, permanently recording all trading activity, reconciling
2
Semper Augustus Investments Group LLC
accounts to custodians’ records, and monitoring personal trading activities.
For additional information regarding Semper Augustus’ supervisory activities,
please call Chad S Christensen, Chief Compliance Officer, at 303-893-1214.
Education and Business Standards
Semper Augustus requires that client advisers in its employ have a bachelor's
degree and requires adherence to a stated ethical policy. Our standards require that
all individuals participating in the investment research process and client interaction
process possess a high degree of ethical standards and general business
experience as it relates to investment management and client needs.
Professional Certifications
Employees have earned certifications and credentials that are required to be
explained in further detail.
Certified Public Accountant (CPA): Certified Public Accountants are regulated by
respective state regulatory body. There are four parts (the four "E's") to obtaining a
Colorado Certified Public Accountant Certificate:
• First, you must meet the education requirements to qualify to take the
Uniform CPA Examination.
• Second, you must successfully pass the Uniform CPA Examination.
• Third, you must take and successfully pass the AICPA Ethics examination or
its equivalent.
• Fourth, you must have one year of experience in public accounting, under
the direct supervision of an actively licensed Certified Public Accountant, or
experience that the Board deems to be equivalent. The experience must be
gained 5 years before or after passing the Uniform CPA Examination.
Certified Public Accountant/Personal Financial Specialist (CPA/PFS) is a designation
granted by the American Institute of Public Accountants (AICPA). The Personal
Financial Specialist (PFS) program allows CPAs to demonstrate their knowledge and
expertise in personal financial planning. Whether a CPA specializes in personal
financial planning with their clients or interacts with other financial planning
professionals, the PFS credential adds credibility. PFS credential holders have a
specific experience, education and examination requirement that sets them apart
from other CPAs and financial planners.
• Obtain the CPA License
• A PFS candidate must hold a valid and unrevoked CPA license issued by a
legally constituted state authority.
• The CPA license establishes the ethical and professional foundation for the
PFS Credential. No other comprehensive financial planning credential
requires this level of professionalism as their foundation. Every PFS
credential holder has successfully completed the rigorous CPA Exam, has
met the strict education and experience requirements, and with membership
in the AICPA, has agreed to the AICPA Code of Professional Conduct.
• Complete Comprehensive PFP Education
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Semper Augustus Investments Group LLC
o A PFS Candidate must earn a minimum of 80 hours of personal
financial planning education within the five year period preceding the
date of the PFS application. The AICPA offers PFP education
opportunities that qualify.
o The education must be in the 9 areas that make up the PFS Body of
Knowledge, found in the PFS Credential Application Kit. Alternative
sources include a combination of professional CPE, approved
courses at an accredited university or college, or presenting and
authoring on financial planning subjects.
• Attain a Specified Level of PFP Experience
o The PFS Candidate must have 2 years of full-time business or
teaching experience (or 3,000 hours equivalent) in personal financial
planning within the five year period preceding the date of the PFS
application.
o The education must be in the 9 areas that make up the PFS Body of
Knowledge, found in the PFS Credential Application Kit. Note that up
to 1,000 hours of tax compliance experience can count toward the
total experience requirement.
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Semper Augustus Investments Group LLC