View Document Text
Item 1 – Cover Page
Traub Capital Management, LLC
97 Chapel Street, Suite 7,
Needham, MA 02492
781-453-3929
www.traubcapital.com
February 26, 2026
This Brochure provides information about the qualifications and business practices of
Traub Capital Management [“TCM”]. If you have any questions about the contents of this
Brochure, please contact us at 781-453-3929 or h.traub@traubcapital.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.
Traub Capital Management is a registered investment adviser. Registration of an
Investment Adviser does not imply any level of skill or training. The oral and written
communications of an Adviser provide you with information, with which you determine to
hire or retain the Adviser.
Additional information about Traub Capital Management also is available on the SEC’s
website at www.adviserinfo.sec.gov.
i
Item 2 – Material Changes
This Brochure, dated February 2026 is a revision from February 2025.
There are no material changes.
Pursuant to SEC Rules, we will ensure that you receive a summary of any materials changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year,
which ends December 31st. We may further provide other ongoing disclosure information
about material changes as necessary.
We will further provide you with a new Brochure as necessary based on changes or new
information, at any time, without charge.
Currently, our Brochure may be requested by contacting Heydon Traub, CEO, at 781-453-
3929 or h.traub@traubcapital.com. Our Brochure is also available on our website
www.traubcapital.com, free of charge.
Additional information about Traub Capital Management is available via the SEC’s web site
www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons
affiliated with TCM who are registered, or are required to be registered, as investment
adviser representatives of TCM.
ii
Item 3 -Table of Contents
Item 1 – Cover Page ............................................................................................................................................... i
Item 2 – Material Changes ................................................................................................................................. ii
Item 3 -Table of Contents .................................................................................................................................. iii
Item 4 – Advisory Business ............................................................................................................................... 1
Item 5 – Fees and Compensation .................................................................................................................... 1
Item 6 – Performance-Based Fees and Side-By-Side Management ................................................... 2
Item 7 – Types of Clients .................................................................................................................................... 3
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................... 3
Item 9 – Disciplinary Information .................................................................................................................. 3
Item 10 – Other Financial Industry Activities and Affiliations ............................................................ 3
tem 11 – Code of Ethics ....................................................................................................................................... 3
Item 12 – Brokerage Practices ........................................................................................................................ 4
Item 13 – Review of Accounts ......................................................................................................................... 5
Item 14 – Client Referrals and Other Compensation .............................................................................. 5
Item 15 – Custody ................................................................................................................................................. 5
Item 16 – Investment Discretion .................................................................................................................... 5
Item 17 – Voting Client Securities .................................................................................................................. 6
Item 18 – Financial Information ...................................................................................................................... 6
Brochure Supplement(s)
iii
Item 4 – Advisory Business
We are an investment adviser and financial planning firm that was founded by current
owner, Heydon Traub, in 2003. We work with 1) individuals and families, 2) retirement
and profits sharing plans, and 3) trusts.
Our typical investment objective is to seek consistently strong total returns while seeking
to control risk. For separately managed accounts, we will work with clients to tailor a
given portfolio to suit their specific needs/issues such as income, risk tolerance, and/or
tax planning. For accounts that involve individual stock selection, we have a value-
oriented and quantitatively based process. This means that we use quantitative analysis
to identify potential holdings followed by fundamental analysis. The stock holdings are
likely to possess characteristics such as reasonable price multiple levels relative to
expected earnings and cash flow growth. They also reflect current interest rates and risk
premiums appropriate to the given security. In some cases we will work around a large
core holding that the client does not want to sell for tax reasons by avoiding other stocks
in the same industry and/or using options. Or similarly, we can work with clients who
work in certain industries and may have large amounts of company stock and options,
and avoid those industries for diversification reasons. We use mutual funds, ETF’s and
closed-end funds to access certain asset classes and for some clients we implement their
whole portfolio via funds. On the planning side we work with clients on narrow issues
such as college funding or social security claiming, out to a broader spectrum covered by
a retirement analysis or detailed financial plan.
Assets under management as of 12/31/25 were $211 million, all discretionary.
Item 5 – Fees and Compensation
For separately managed accounts, the management fees are:
Portfolios Incorporating Individual Stocks
First $1,000,000
Annual Fee = 1.00%
Next $1,000,000 to $5,000,000
Annual Fee = .75%
Next $5,000,000 and over
Annual Fee = .50%
Minimum annual fee is $4,000 (this translates to minimum account size of $400,000 at a
1% fee- clients may choose to hire us with less assets, but the minimum fee would apply)
1
Portfolios Utilizing Mutual Funds Only
First $1,000,000
Annual Fee = 0.70%
Next $1,000,000 to $5,000,000
Annual Fee = .50%
Next $5,000,000 and over
Annual Fee = .30%
Minimum annual fee is $2,800 (this translates to minimum account size of $400,000 at a
0.7% fee- clients may choose to hire us with less assets, but the minimum fee would apply)
Fees for larger accounts are negotiable and we will sometimes waive the minimum fee
calculation.
The specific manner in which fees are charged by the adviser is established in a client’s
written agreement with Adviser. The Adviser will calculate fees monthly based on month-
end values but generally bill its fees on a quarterly basis in arrears. Clients may specifically
opt to elect to be billed directly for fees, but otherwise we will directly debit fees from
client accounts. Management fees shall not be prorated for each capital contribution and
withdrawal made during the applicable calendar month. Accounts initiated or terminated
during a calendar quarter will be charged a prorated fee. Upon termination of any account,
unpaid fees will be due and payable.
Our fees are exclusive of brokerage commissions, transaction fees, and other related costs
and expenses which may be incurred by the client. Clients may incur certain charges
imposed by custodians, brokers, third party investment and other third parties such as fees
charged by managers, custodial fees, transfer taxes, wire transfer and electronic fund fees,
and other fees and taxes on brokerage accounts and securities transactions. Mutual funds
and exchange traded funds also charge internal management fees, which are disclosed in a
fund’s prospectus. We work to minimize these costs and for the most part trade at low
electronic commission rates and in most cases can trade at zero commissions. Such
charges, fees and commissions are exclusive of and in addition to our fee, and we shall not
receive any portion of these commissions, fees, and costs. We do not receive any
compensation or commissions for a given account beyond the management fee.
Item 12 further describes the factors that we consider in selecting or recommending
broker-dealers for client transactions and determining the reasonableness of their
compensation (e.g., commissions).
Item 6 – Performance-Based Fees and Side-By-Side Management
We do not use performance fees.
2
Item 7 – Types of Clients
TCM provides portfolio management services to individuals, high net worth individuals,
corporate retirement and profit-sharing plans, and trusts. As noted in Item 5, the effective
minimum account size is $400,000.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
As discussed in Item 4, for accounts that involve individual stock selection, we have a value-
oriented and quantitatively based process. This means that we use quantitative analysis to
identify potential holdings and the stock holdings are likely to possess characteristics such
as reasonable price multiple levels relative to expected earnings and cash flow growth.
They also reflect current interest rates and risk premiums appropriate to the given
security.
When investing in mutual funds, we analyze expense ratios and sales charges as well as
past performance and our expectation of future results based on our qualitative analysis of
the fund manager’s approach. We also utilize closed-end funds and ETFs (exchange traded
funds) where an additional key factor is the premium or discount the fund trades at
relative to its underlying assets.
There will be periods with little or no turnover based on the fact that we typically have a
long-term investing approach. Investing in securities involves risk of loss that clients
should be prepared to bear.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any
legal or disciplinary events that would be material to your evaluation of TCM or the
integrity of our management. We have no disciplinary events to report.
Item 10 – Other Financial Industry Activities and Affiliations
None to report.
Item 11 – Code of Ethics
We allow personal trading of similar securities that we transact in for our clients.
However, personal trades cannot be done until client trading in the same securities is
complete.
3
TCM has adopted a Code of Ethics for all supervised persons of the firm describing its high
standard of business conduct, and fiduciary duty to its clients (including under ERISA and
in determining rollovers to IRAs). The Code of Ethics includes provisions relating to the
confidentiality of client information, a prohibition on insider trading, and personal
securities trading procedures, among other things. All supervised persons at TCM must
acknowledge the terms of the Code of Ethics annually, or as amended.
In circumstances where TCM must execute new trades for advisory clients, the resulting
purchase or sale of securities in which TCM and/or clients have a position of interest
(direct or indirect) may benefit.
TCM’s employees and persons associated with TCM are required to follow our Code of
Ethics. Subject to satisfying this policy and applicable laws, officers, directors and
employees of TCM may trade for their own accounts in securities which are recommended
to and/or purchased for our clients. The Code of Ethics is designed to assure that the
personal securities transactions, activities and interests of the employees of TCM will not
interfere with (i) making decisions in the best interest of advisory clients and (ii)
implementing such decisions while, at the same time, allowing employees to invest for their
own accounts. Under the Code certain classes of securities have been designated as exempt
transactions, based upon a determination that these would materially not interfere with
the best interest of our clients. In addition, the Code requires pre-clearance of many
transactions, and restricts trading in close proximity to client trading activity. Nonetheless,
because the Code of Ethics in some circumstances would permit employees to invest in the
same securities as clients, there is a possibility that employees might benefit from market
activity by a client in a security held by an employee. Employee trading is continually
monitored under the Code of Ethics to reasonably prevent conflicts of interest between
TCM personnel and its clients.
TCM’s clients or prospective clients may request a copy of the firm's Code of Ethics by
contacting Heydon Traub.
It is TCM’s policy that the firm will not affect any principal or agency cross securities
transactions for client accounts. We will also not cross trade between client accounts.
Principal transactions are generally defined as transactions where an adviser, acting as
principal for its own account, buys from or sells any security to any advisory client.
4
Item 12 – Brokerage Practices
TCM has the authority to select brokers to execute trades. We do not use soft dollars and
thus look to minimize the overall transaction costs for our clients. The majority of trades
are executed with the broker affiliated with our custodians (primarily Fidelity or Schwab).
This is done because it eliminates any extra ticket charges that in many cases would be
larger than the commissions and/or fees charged. In general, TCM does not usually
aggregate trades as we find that the potential savings on trading costs would be minimal
given our firm size and our already extremely low trading costs. Commissions on stocks or
ETF trades are typically $0 per trade (sometimes higher for certain accounts requiring
paper statements) while mutual fund commissions are mostly free, but in some cases are
$25 or $50 per trade.
Item 13 – Review of Accounts
Reviews of accounts are done on an ongoing basis without a specific timeframe, but are
done at least monthly. Reasons accounts would be reviewed outside of the monthly cycle
could include: a stock that a client holds becomes a sell candidate (or a stock they don’t
own becomes a “buy”), a fund they hold becomes a “sell”, a cash flow, a change in our
outlook for a given asset class, and/or a client’s situation changes in terms of income or risk
aversion. Reviews are done by Heydon Traub, Jake Bulian, and Agnes Olshansky.
In terms of reporting, the custodian provides a statement each month summarizing
holdings and transactions. TCM provides a quarterly performance report that has specific
results for each client as well as a market summary and outlook.
Item 14 – Client Referrals and Other Compensation
TCM does have a referral fee relationship with Gold Advisory LLC.
Item 15 – Custody
Clients receive monthly statements from the qualified custodian (currently Fidelity or
Schwab) that holds and maintains client’s investment assets. We urge you to carefully
review such statements and compare such official custodial records to the quarterly
reports that we provide to you. Our statements may vary from custodial statements based
on accounting procedures, reporting dates, or valuation methodologies of certain
securities.
5
Item 16 – Investment Discretion
As noted in Item 4, TCM usually receives discretionary authority from the client at the
outset of an advisory relationship to select the identity and amount of securities to be
bought or sold. In all cases, however, such discretion is to be exercised in a manner
consistent with the stated investment objectives for the particular client account.
When selecting securities and determining amounts, we observe the investment policies,
limitations and restrictions of the clients for which it advises. For registered investment
companies, TCM’s authority to trade securities may also be limited by certain federal
securities and tax laws that require diversification of investments and favor the holding of
investments once made.
Investment guidelines and restrictions must be provided to TCM in writing.
Item 17 – Voting Client Securities
Unless otherwise instructed, we vote proxies for all of our clients. In general, our votes
support efforts that we think will maximize shareholder value. In any cases where the
client’s interest may conflict with our firm’s interest we will vote based on what we think is
in the best interest of the client.
Clients may obtain a copy of our complete proxy voting policies and procedures upon
request. Clients may also obtain information from us about how we voted any proxies on
behalf of their account(s).
Item 18 – Financial Information
Registered investment advisers are required in this Item to provide you with certain
financial information or disclosures about our financial condition. TCM has no financial
commitment that impairs its ability to meet contractual and fiduciary commitments to
clients, and has not been the subject of a bankruptcy proceeding.
6