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T A M C A p i T A l M A n A g e M e n T i n C .
C l i e n T B r o C h u r e
This brochure provides information about the qualifications and business practices of TAM
Capital Management Inc.. If you have any questions about the contents of this brochure, please
contact us at (917) 567-3923 or by email at: tsachy.mishal@gmail.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 TAM Capital Management Inc. is also available on the SEC’s
website at www.adviserinfo.sec.gov. TAM Capital Management Inc.’s CRD number is: 155271
63 Crane Rd North
Stamford, CT 06902
(917) 567-3923
tsachy.mishal@gmail.com
Item 2: Material Changes
No material changes to report.
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Item 3: Table of Contents
Table of Contents
Item 2: Material Changes......................................................................................................................................................................... i
Item 3: Table of Contents…………........................................................................................................................................................ ii
Item 4: Advisory Business...................................................................................................................................................................... 1
A. Description of the Advisory Firm..................................................................................................................................................... 1
B. Types of Advisory Services............................................................................................................................................................. ...1
Investment Supervisory Services........................................................................................................................................................... 1
Services Limited to Specific Types of Investments............................................................................................................................. 1
C. Client Tailored Services and Client Imposed Restrictions............................................................................................................ 1
D. Wrap Fee Programs............................................................................................................................................................................ 2
E. Amounts Under Management........................................................................................................................................................... 2
Item 5: Fees and Compensation............................................................................................................................................................. 3
A. Fee Schedule........................................................................................................................................................................................ 3
Investment Supervisory Services Fees.................................................................................................................................................. 3
Performance Based Fees ......................................................................................................................................................................... 3
B. Payment of Fees .................................................................................................................................................................................. 3
Payment of Investment Supervisory Fees ........................................................................................................................................... 3
Payment of Performance Based Fees ................................................................................................................................................... 3
C. Clients Are Responsible For Third Party Fees .............................................................................................................................. 3
D. Prepayment of Fees ........................................................................................................................................................................... 4
E. Outside Compensation For the Sale of Securities to Clients ........................................................................................................ 4
Item 6: Performance-Based Fees and Side-By-Side Management .................................................................................................... 4
Item 7: Types of Clients .......................................................................................................................................................................... 4
Minimum Account Size .......................................................................................................................................................................... 4
Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss ...................................................................... 5
A. Methods of Analysis and Investment Strategies ........................................................................................................................... 5
Methods of Analysis ............................................................................................................................................................................... 5
Fundamental analysis ............................................................................................................................................................................. 5
Technical analysis ................................................................................................................................................................................... 5
Cyclical analysis ...................................................................................................................................................................................... 5
Investment Strategies ............................................................................................................................................................................. 5
B. Material Risks Involved..................................................................................................................................................................... 5
Methods of Analysis .............................................................................................................................................................................. 5
Fundamental analysis ............................................................................................................................................................................ 5
Technical analysis ................................................................................................................................................................................... 5
Cyclical analysis ...................................................................................................................................................................................... 6
Investment Strategies ............................................................................................................................................................................. 6
C. Risks of Specific Securities Utilized................................................................................................................................................. 6
Item 9: Disciplinary Information .......................................................................................................................................................... 6
Item 10: Other Financial Industry Activities and Affiliations .......................................................................................................... 6
A. Registration as a Broker/Dealer or Broker/Dealer Representative ........................................................................................... 6
B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor............ 7
C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests ...................................... 7
D. Selection of Other Advisors or Managers and How This Adviser is Compensated for Those Selections ........................... 7
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................................ 7
A. Code of Ethics ..................................................................................................................................................................................... 7
B. Recommendations Involving Material Financial Interests ........................................................................................................... 7
C. Investing Personal Money in the Same Securities as Clients ....................................................................................................... 7
D. Trading Securities At/Around the Same Time as Clients’ Securities ........................................................................................ 8
Item 12: Brokerage Practices .................................................................................................................................................................. 8
A. Factors Used to Select Custodians and/or Broker/Dealers ........................................................................................................ 8
1. Research and Other Soft-Dollar Benefits ......................................................................................................................................... 8
2. Brokerage for Client Referrals ........................................................................................................................................................... 8
3. Clients Directing Which Broker/Dealer/Custodian to Use ......................................................................................................... 8
B. Aggregating (Block) Trading for Multiple Client Accounts ........................................................................................................ 8
Item 13: Reviews of Accounts ............................................................................................................................................................... 9
A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ........................................................................ 9
B. Factors That Will Trigger a Non-Periodic Review of Client Accounts ...................................................................................... 9
C. Content and Frequency of Regular Reports Provided to Clients ............................................................................................... 9
Item 14: Client Referrals and Other Compensation .......................................................................................................................... 9
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A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes)..9
B. Compensation to Non –Advisory Personnel for Client Referrals ............................................................................................... 9
Item 15: Custody ..................................................................................................................................................................................... 9
Item 16: Investment Discretion ........................................................................................................................................................... 10
Item 17: Voting Client Securities (Proxy Voting) ............................................................................................................................. 10
Item 18: Financial Information ............................................................................................................................................................ 10
A. Balance Sheet .................................................................................................................................................................................... 10
B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients........................ 10
C. Bankruptcy Petitions in Previous Ten Years ............................................................................................................................... 10
Item 19: Requirements For State Registered Advisers .................................................................................................................... 11
A. Principal Executive Officers and Management Persons; Their Formal Education and Business Background ................. 11
B. Other Businesses in Which This Advisory Firm or its Personnel are Engaged and Time Spent on Those (If Any)…….. 11
C. How Performance Based Fees are Calculated and Degree of Risk to Clients ........................................................................ 11
D. Material Disciplinary Disclosures for Management Persons of this Firm .............................................................................. 11
E. Material Relationships That Management Persons Have With Issuers of Securities (If Any) ……………………........... 11
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Item 4: Advisory Business
A. Description of the Advisory Firm
This firm has been in business since December 15, 2010, and the principal owner is
Tsemach Aaron Mishal.
B. Types of Advisory Services
TAM Capital Management Inc. (hereinafter “TAM”) offers the following services to
advisory clients:
Investment Supervisory Services
TAM only advises Qualified Clients. TAM pursues aggressive investment strategies that
include, but are not limited to, utilizing significant leverage, buying and selling options
and other derivative instruments and applying other risky option and trading strategies.
All clients of TAM will be advised only on these strategies. Before entering into a
relationship with clients, TAM always ensures the suitability and appropriateness of its
strategies for each of its clients and explains the risk of loss involved in using those
strategies. TAM will request discretionary authority from clients in order to select
securities and execute transactions without permission from the client prior to each
transaction.
Services Limited to Specific Types of Investments
TAM limits its money management primarily to equities, ETFs, options and other
derivative instruments. TAM may use other securities as well on an opportunistic basis.
C. Client Tailored Services and Client Imposed Restrictions
TAM offers the same suite of services to all of its clients. Before entering into a
relationship with clients, TAM always ensures the suitability and appropriateness of its
strategies for each of its clients and explains the risk of loss involved in using those
strategies. TAM will request discretionary authority from clients in order to select
securities and execute transactions without permission from the client prior to each
transaction.
Clients may not impose restrictions in investing in certain securities or types of securities
in accordance with their values or beliefs.
Clients may adjust their portfolios based on their individualized risk tolerance.
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D. Wrap Fee Programs
TAM does not participate in any wrap fee programs.
E. Amounts Under Management
Date Calculated:
Non-discretionary
Amounts:
TAM has the
following regulatory
assets under
management:
Discretionary
Amounts:
$111,712,000
$0
12/31/2025
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Item 5: Fees and Compensation
A. Fee Schedule
Investment Supervisory Services Fees
2.00% + performance fee
Total Assets Under Management Annual Fee
All Assets Under
Management
These fees are negotiable and the final fee schedule is attached as Exhibit II of the
Investment Advisory Contract. Asset under management fee is paid daily. Performance
based fees are paid quarterly or annually in arrears, and clients may terminate their
contracts with five days’ written notice. Refunds are given on a prorated basis, based on
the number of days remaining in a quarter at the point of termination. Clients may
terminate their contracts without penalty, for full refund, within 5 business days of
signing the advisory contract. Advisory fees are withdrawn directly from the client’s
accounts automatically.
Performance Based Fees
Qualified investors will be charged an annual 2.00% fee on assets under management
and a performance based fee of 25% of net profits. The performance fee is payable
quarterly or annually in arrears.
B. Payment of Fees
Payment of Investment Supervisory Fees
Advisory fees are withdrawn directly from the client’s accounts automatically. Asset
under management fee is paid daily. Performance based fees are paid quarterly or
annually in arrears.
Payment of Performance Based Fees
Performance Based fees are withdrawn directly from the client’s accounts automatically.
The performance fee is payable quarterly or annually in arrears.
C. Clients Are Responsible For Third Party Fees
Clients are responsible for the payment of all third party fees (i.e. custodian fees, mutual
fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and
expenses charged by TAM. Please see Item 12 of this brochure regarding
broker/custodian.
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D. Prepayment of Fees
TAM collects fees in arrears. Fees that are collected in advance will be refunded based
on the prorated amount of work completed at the point of termination and the total days
during the billing period. Fees will be deposited back into client’s account with fourteen
days.
D. Outside Compensation For the Sale of Securities to Clients
Neither TAM nor its supervised persons accept any compensation for the sale of
securities or other investment products, including asset-based sales charges or services
fees from the sale of mutual funds.
Item 6: Performance-Based Fees and Side-By-Side
Management
TAM manages accounts that are not billed on performance based fees as well as
accounts that are billed on a share of capital gains on or capital appreciation of the assets
of a client. Managing both kinds of accounts at the same time presents a conflict of
interest because TAM or its supervised person’s have an incentive to favor accounts for
which TAM and its supervised persons receive a performance-based fee. TAM addresses
the conflicts by ensuring that clients who have performance based accounts do not
receive preferential treatment. TAM provides best execution practices and upholds its
fiduciary duty for all clients.
Clients that are paying a performance based fee should be aware that investment
advisors have an incentive to invest in riskier investments when paid a performance
based fee due to the higher risk/higher reward attributes.
Item 7: Types of Clients
TAM generally provides management supervisory services to the following Types of
Clients:
High-Net-Worth Individuals
Banks and Thrift Institutions
Investment Companies
Pension and Profit Sharing Plans
Trusts, Estates, or Charitable Organizations
Corporations or Business Entities
Minimum Account Size
There is no account minimum.
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Item 8: Methods of Analysis, Investment Strategies, and
Risk of Investment Loss
A. Methods of Analysis and Investment Strategies
Methods of Analysis
TAM’s methods of analysis include fundamental analysis, technical analysis, and
cyclical analysis.
Fundamental analysis involves the analysis of financial statements, the general financial
health of companies, and/or the analysis of management or competitive advantages.
Technical analysis involves the analysis of past market data; primarily sentiment and
reversion to the mean analysis.
Cyclical analysis involved the analysis of business cycles to find favorable conditions
for buying and/or selling a security.
Investment Strategies
TAM uses long term trading, short term trading, short sales, margin transactions,
options writing (including covered options, uncovered options, or spreading strategies).
TAM pursues aggressive investment strategies that include, but are not limited to,
utilizing significant leverage, buying and selling options and other derivative
instruments and applying other risky option and trading strategies.
Investing in securities involves a risk of loss that you, as a client, should be prepared
to bear.
B. Material Risks Involved
Methods of Analysis
Fundamental analysis concentrates on factors that determine a company’s value and
expected future earnings. This strategy would normally encourage equity purchases in
stocks that are undervalued or priced below their perceived value. The risk assumed is
that the market will fail to reach expectations of perceived value.
Technical analysis attempts to predict a future stock price or direction based on market
sentiment and reversion to the mean. The assumption is that the market follows
discernible patterns and if these patterns can be identified then a prediction can be
made. The risk is that markets do not always follow patterns and relying solely on this
method may not work long term.
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Cyclical analysis assumes that the markets react in cyclical patterns which, once
identified, can be leveraged to provide performance. The risks with this strategy are
two-fold : 1) the markets do not always repeat cyclical patterns and 2) if too many
investors begin to implement this strategy, it changes the very cycles they are trying to
take advantage of.
Investment Strategies
Long term trading is designed to capture market rates of both return and risk. Frequent
trading, when done, can affect investment performance, particularly through increased
brokerage and other transaction costs and taxes.
Short term trading, short sales, margin transactions, and options writing generally hold
greater risk and clients should be aware that there is a chance of material risk of loss
using any of those strategies.
Investing in securities involves a risk of loss that you, as a client, should be prepared
to bear.
C. Risks of Specific Securities Utilized
TAM pursues aggressive investment strategies that include, but are not limited to,
utilizing significant leverage, buying and selling options and other derivative
instruments and applying other risky option and trading strategies.
Past performance is not a guarantee of future returns. Investing in securities involves
a risk of loss that you, as a client, should be prepared to bear.
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to a client’s or prospective
client’s evaluation of this advisory business or the integrity of our management.
Item 10: Other Financial Industry Activities and
Affiliations
A. Registration as a Broker/Dealer or Broker/Dealer Representative
Neither TAM nor its representatives are registered as a broker/dealer or as
representatives of a broker/dealer.
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B. Registration as a Futures Commission Merchant, Commodity Pool
Operator, or a Commodity Trading Advisor
Neither TAM nor its representatives are registered as a FCM, CPO, or CTA.
C. Registration Relationships Material to this Advisory Business and
Possible Conflicts of Interests
Neither TAM nor its representatives have any material relationships to this advisory
business that would present a possible conflict of interest.
D. Selection of Other Advisors or Managers and How This Adviser is
Compensated for Those Selections
TAM does not utilize nor select other advisors or third party managers. All assets are
managed by TAM management.
Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
A. Code of Ethics
We have a written Code of Ethics that covers the following areas: Prohibited Purchases
and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions,
Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality,
Service on a Board of Directors, Compliance Procedures, Compliance with Laws and
Regulations, Procedures and Reporting, Certification of Compliance, Reporting
Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual
Review, and Sanctions. Clients may request a copy of our Code of Ethics from
management.
B. Recommendations Involving Material Financial Interests
TAM does not recommend that clients buy or sell any security in which a related person
to TAM has a material financial interest.
C. Investing Personal Money in the Same Securities as Clients
From time to time, representatives of TAM may buy or sell securities for themselves that
they also recommend to clients. TAM will always document any transactions that could
be construed as conflicts of interest and will always transact client business before their
own when similar securities are being bought or sold.
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D. Trading Securities At/Around the Same Time as Clients’ Securities
From time to time, representatives of TAM may buy or sell securities for themselves at
or around the same time as clients. TAM will trade client’s non-mutual funds and non-
ETF securities before or together with their own.
Item 12: Brokerage Practices
A. Factors Used to Select Custodians and/or Broker/Dealers
The Custodian, Interactive Brokers LLC, was chosen based on their relatively low
transaction fees and access to mutual funds and ETFs. TAM will never charge a
premium or commission on transactions, beyond the actual cost imposed by Custodian.
1. Research and Other Soft-Dollar Benefits
TAM receives no research, product, or service other than execution from a broker-dealer
or third-party in connection with client securities transactions (“soft dollar benefits”).
2. Brokerage for Client Referrals
TAM receives no referrals from a broker-dealer or third party in exchange for using that
broker-dealer or third party.
3. Clients Directing Which Broker/Dealer/Custodian to Use
TAM will not allow clients to direct TAM to use a specific broker-dealer to execute
transactions. Clients must use TAM recommended custodian (broker-dealer). Not all
investment advisers require their clients to direct brokerage. By requiring clients to use
our specific custodian, TAM may be unable to achieve most favorable execution of client
transactions and this may cost clients money over using a lower-cost custodian.
B. Aggregating (Block) Trading for Multiple Client Accounts
TAM maintains the ability to block trade purchases across accounts. While block trading
may benefit clients by purchasing larger blocks in groups, we do not feel that the clients
are at a disadvantage due to the best execution practices of our custodian.
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Item 13: Reviews of Accounts
A. Frequency and Nature of Periodic Reviews and Who Makes Those
Reviews
Client accounts are reviewed at least quarterly only by Tsemach Aaron Mishal,
President. Tsemach Aaron Mishal is the chief advisor and is instructed to review clients’
accounts with regards to their investment policies and risk tolerance levels. All accounts
at TAM are assigned to this reviewer.
B. Factors That Will Trigger a Non-Periodic Review of Client Accounts
Reviews may be triggered by material market, economic or political events, or by
changes in client's financial situations (such as retirement, termination of employment,
physical move, or inheritance).
C. Content and Frequency of Regular Reports Provided to Clients
Each client will receive at least quaterly a written report detailing the client’s account
which will come from the custodian.
Item 14: Client Referrals and Other Compensation
A. Economic Benefits Provided by Third Parties for Advice Rendered to
Clients (Includes Sales Awards or Other Prizes)
TAM does not receive any economic benefit, directly or indirectly from any third party
for advice rendered to TAM clients.
B. Compensation to Non –Advisory Personnel for Client Referrals
TAM does not directly or indirectly compensate any person who is not advisory
personnel for client referrals.
Item 15: Custody
TAM does not take custody of client accounts at any time. Custody of client’s accounts is
held primarily at Interactive Brokers LLC. Clients will receive account statements from
the custodian and should carefully review those statements.
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Item 16: Investment Discretion
TAM will request discretionary authority from clients in order to select securities and
execute transactions without permission from the client prior to each transaction.
Item 17: Voting Client Securities (Proxy Voting)
TAM will accept voting authority for client securities in certain cases. When TAM does
accept voting authority for client securities, it will always seek to vote in the best
interests of its clients. TAM does not maintain preapproved voting guidelines but relies
on the portfolio manager to determine the appropriate course of action in voting client
securities that is in the best interest of the client. Clients may direct TAM on how to vote
client securities by communicating their wishes in writing or electronically to TAM.
When voting client proxies the portfolio manager will always hold the interests of the
clients above its own interests. Clients of TAM may obtain the voting record of TAM on
client securities by contacting TAM at phone number or e-mail address listed on the
cover page of this brochure. Clients may obtain a copy of TAM’s proxy voting policies
and procedures upon request.
Item 18: Financial Information
A. Balance Sheet
TAM does not require nor solicit prepayment of more than $500 in fees per client, six
months or more in advance and therefore does not need to include a balance sheet with
this brochure.
B. Financial Conditions Reasonably Likely to Impair Ability to Meet
Contractual Commitments to Clients
Neither TAM nor its management have any financial conditions that are likely to
reasonably impair our ability to meet contractual commitments to clients.
C. Bankruptcy Petitions in Previous Ten Years
TAM has not been the subject of a bankruptcy petition in the last ten years.
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Item 19: Requirements For State Registered Advisers
A. Principal Executive Officers and Management Persons; Their Formal
Education and Business Background
TAM currently has only one management person and only one executive officer;
Tsemach Aaron Mishal. Tsemach Aaron Mishal’s education and business background
can be found on the Supplemental ADV Part 2B form.
B. Other Businesses in Which This Advisory Firm or its Personnel are
Engaged and Time Spent on Those (If Any)
Tsemach Aaron Mishal’s other business activities can be found on the Supplemental
ADV Part 2B form.
C. How Performance Based Fees are Calculated and Degree of Risk to
Clients
TAM accepts performance based fees, fees based on a share of capital gains on or capital
appreciation of the assets of a client. TAM also manages accounts that are billed on a
share of capital gains on or capital appreciation of the assets of a client. Managing both
kinds of accounts at the same time presents a conflict of interest because TAM or its
supervised person’s have an incentive to favor accounts for which TAM and its
supervised persons receive a performance-based fee. TAM addresses the conflicts by
ensuring that clients who have performance based accounts do not receive preferential
treatment. TAM provides best execution practices and upholds its fiduciary duty for all
clients.
Clients that are paying a performance based fee should be aware that investment
advisors have an incentive to invest in riskier investments when paid a performance
based fee due to the higher risk/higher reward attributes.
D. Material Disciplinary Disclosures for Management Persons of this
Firm
No management person at TAM has been involved in an arbitration claim or been found
liable in a civil, self-regulatory organization, or administrative proceeding that is
material to the client’s evaluation of the firm or its management.
E. Material Relationships That Management Persons Have With Issuers
of Securities (If Any)
Neither TAM, nor its management persons, has any relationship or arrangement with
issuers of securities.
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