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Item 1.
Cover Page
Form ADV Part 2A Disclosure Brochure
100 Coxe Avenue
Asheville, NC 28801
Phone: 828-236-0610
Website: www.altamontcm.com
Dated: March 4, 2025
of
this
brochure,
contact
us
at
This brochure provides information about the qualifications and business practices
of Altamont Capital Management, LLC. If you have any questions about the
contents
828-236-0610
please
or snorris@altamontcm.com. The information in this brochure has not been
approved or verified by the United States Securities and Exchange Commission
(“SEC”) or by any state securities authority. Registration with the SEC or any state
securities authority does not imply a certain level of skill or training.
Additional information about Altamont Capital Management, LLC also is available
on the SEC’s website at www.adviserinfo.sec.gov.
Item 2. Material Changes Summary
This brochure provides prospective clients with information about Altamont Capital
Management, LLC that should be considered before or at the time of obtaining our advisory
services.
This brochure is required to be updated at least annually or sooner when material changes
to our business take place.
There have been the following material changes since our last update of this brochure on
February 14, 2024:
• None.
Each year we will deliver to you, by no later than April 30th, a free updated brochure that
includes or is accompanied by a summary of material changes; or a summary of material
changes and an offer to provide a copy of the updated brochure and how to obtain it.
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Item 3. Table of Contents
Description
Item 3.
Page
Table of Contents ........................................................................................................... 3
Item 4.
Advisory Business ........................................................................................................... 4
Item 5.
Fees and Compensation ................................................................................................. 4
Item 6.
Performance Based Fees and Side by Side Management ............................................. 7
Item 7.
Types of Clients and Minimum Requirements ............................................................. 8
Item 8.
Method of Analysis, Investment Strategies and Risk of Loss ...................................... 8
Item 9.
Disciplinary Information ............................................................................................... 9
Item 10.
Other Financial Industry Activities and Affiliations .................................................... 9
Item 11.
Code of Ethics, Interest in Client Transactions and Personal Trading ....................... 9
Item 12.
Brokerage Practices ....................................................................................................... 10
Item 14.
Client Referrals and Other Compensation ................................................................... 11
Item 15.
Custody ........................................................................................................................... 11
Item 16.
Investment Discretion ................................................................................................... 11
Item 17.
Voting Client Securities ................................................................................................ 12
Item 18.
Financial Information ................................................................................................... 12
Item 19.
Requirements for State Registered Advisers ............................................................... 13
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Item 4. Advisory Business
Firm Description
Altamont Capital Management LLC (the “Adviser”) is a Registered Investment Advisor based in
Asheville, NC and incorporated under the laws of North Carolina. Founded in 2001, Altamont
Capital Management, LLC provides investment advice and portfolio management services on a
continuing basis, which may include the review of client objectives and goals, recommending asset
allocation strategies of managed assets primarily in exchange-listed equity securities, variable
annuities and mutual fund shares, corporate bonds, and U.S. Government securities, and/or
preparing written investment strategies.
Altamont Capital Management, LLC provides investment advisory services through its Investment
Advisory Representatives ("IAR") to accounts opened with Altamont Capital Management, LLC.
Managed Accounts are available to both retail clients (for example, smaller accounts of individuals, IRAs,
trusts and employee benefit plans) and institutional clients (for example, corporate pension plans,
corporations and foundations). In addition, some programs will provide for the selection of specific
securities to help meet the client’s stated investment objectives or identifying, evaluating, and hiring
independent, unaffiliated money management firms on behalf of clients.
The Adviser provides continuous investment supervisory services and furnishes advice to clients on
matters not involving securities.
Principal Owners
The Adviser’s principal owners are Harvey Wayne Jenkins, Gerald Edward Towson, Shon Patrick Norris
and Daniel Rudell Mullinix.
More specific information regarding our services is as follows:
ASSET ALLOCATION THROUGH ADVISOR SERVICES
The Adviser offers an asset allocation program through Advisor Services by Savant Wealth Management,
an independent investment adviser registered with the Securities and Exchange Commission. Adviser
will work with the client to determine the client’s investment objectives, risk and return characteristics
and types of investments and provide a written Investment Policy Statement. Adviser assists clients in
selecting the investment strategies that are consistent with the client’s investment policy. Adviser
evaluates the client’s existing investments with respect to the client’s investment policy and individual
performance. We then work with clients to develop a transition plan in order to move from client’s
existing asset allocation to the desired asset allocation. Adviser will direct the investment and reinvestment
of the assets in the client’s account. We will monitor the performance of the assets as well as the asset
allocation strategy and then meet with the client as requested to review performance reports provided to
the client.
Adviser provides ongoing investment supervisory services on the client’s behalf. These services include
the following:
A.
B.
C.
D.
Prepare the client’s Investment Policy Statement;
Review client’s risk profile;
Recommend options to achieve the client’s financial objectives;
Implement investment strategies; and
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E.
Report to client and monitor performance of the client’s investments.
Adviser has contracted with Savant Wealth Management for services including portfolio management,
trade processing, collection of portfolio management fees, report preparation and maintenance, marketing
assistance and research, and access to certain institutional class mutual funds and investment strategies.
The Adviser will supervise client accounts and otherwise provide services to clients and conduct its
activities in a manner that satisfies all applicable conditions of the Investment Advisers Act of 1940 and
Rule 3a-4 of the Investment Company Act, including: (i) obtaining information from the client about the
client’s particular financial situation and investment objectives (including any reasonable investment
restrictions the client may wish to impose on the management of Client’s account); (ii) contacting each
client at least annually to determine whether there have been any changes in the client’s financial situation
or investment objective, or whether the client wishes to impose any reasonable restrictions on the
management of the account or modify an existing restriction in a reasonable manner; and (iii) notifying
each client in writing at least quarterly to contact the Company if there have been any changes in the
client’s financial situation or investment objectives, or if the client wishes to impose or clarify an
investment restriction.
RETIREMENT PLAN SERVICES
Adviser has contracted with Savant Wealth Management for Retirement Plan 401(k) services, including
access to model investment portfolios and administrative and marketing support services.
INSURANCE SERVICES
Client may request that Adviser assist with procurement of a variety of insurance products. Adviser may
offer products for which Adviser will be paid commissions. The Advisors may make referrals to insurance
agents who have relationships with insurance companies.
Assets Under Management
The Adviser provides investment advice to clients on a discretionary basis. As of December 31, 2024, the
Adviser’s total assets under management are as follows:
Discretionary:
Assets Under Management
$341,810,724
Non-Discretionary:
$0
Total:
$341,810,724
Item 5. Fees and Compensation
ADVISOR SERVICES FEES
The Adviser’s standard fee schedules are as follows:
Assets under Management
On the first $500,000
$500,001 to $1,000,000
$1,000,001 to $3,000,000
$3,000,001 to $10,000,000
Above $10,000,001
Annual Fee
1.25%
1.10%
1.00%
.90%
.60%
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For its services, Savant Wealth Management charges a fee based on a percentage of client’s assets
under management. Savant Wealth Management’s fees are included in Adviser’s total fees as set
forth above. The Savant Wealth Management’ fee schedule is as follows:
Account Value
$150,000 - $3,000,000
$3,000,001 - $10,000,000
$10,000,001 and above
Annual Fee
0.50%
0.40%
0.30%
RETIREMENT PLAN SERVICES FEES
The standard fee schedule for Retirement Plan Services is:
On the first $1,000,000
On the next $1,000,000
On the next $3,000,000
On the next $5,000,000
On all amounts thereafter
1.00%
0.75%
0.55%
0.40%
0.35%
Minimum Annual Fee:
$3,000
Adviser and Savant Wealth Management each receive a portion the Retirement Plan Services fees paid by
participating 401(k) plans according to the schedule above. The percentage of fees paid to Savant Wealth
Management and the Advisor may vary from time to time as agreed upon in writing by Advisor and Savant
Wealth Management.
The fees are payable quarterly in arrears. The annual fee is charged on the entire account balance
computed and billed quarterly in arrears based on the account value as of the final business day of
the preceding quarter. Fees are negotiable and may be waived in certain circumstances.
Fee Billing
Client typically grants Adviser or its agent authority to receive quarterly payments directly from the
client’s account held by an independent custodian. The Adviser or its agent will send to the client and the
custodian a bill showing the amount of the fee, the value of client’s assets on which the fee was based,
and the specific manner in which the fee was calculated. The custodian will send to the client a statement,
at least quarterly, indicating all the amounts disbursed from the account including the amount of advisory
fees paid directly to the Adviser. It is the client’s responsibility to verify the accuracy of the fee
calculation, as the custodian will not do so.
Other Fees and Expenses
In addition to advisory fees paid to Altamont Capital Management, LLC as explained above, clients may
pay custodial service, account maintenance, transaction, and other fees associated with maintaining the
account. These fees vary by broker and/or custodian. Clients should ask Altamont Capital Management,
LLC for details on transaction fees or other custodial fees specific to their account, as these fees are not
included in the annual advisory fee. Altamont Capital Management, LLC does not share any portion of
such fees. Additionally, for any mutual funds purchased, the client may pay their proportionate share of
the funds’ distribution, internal management, investment advisory and administrative fees. Such fees are
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not shared with Altamont Capital Management, LLC and are compensation to the fund manager. Clients
are urged to read the mutual fund prospectus prior to investing.
Mutual fund companies impose internal fees and expenses on clients. These fees are in addition to the
costs associated with the investment advisory services as described above. Complete details of such
internal expenses are specified and disclosed in each mutual fund company’s prospectus. Clients are
strongly advised to review the prospectus(es) prior to investing in such securities.
Mutual funds purchased or sold in broker-dealer accounts may generate transaction fees that would not
exist if the purchase or sale were made directly with the mutual fund company. Mutual funds held in
broker-dealer accounts also charge management fees. These mutual fund management fees may be more
or less than the mutual fund management fees charged if the client held the mutual fund directly with the
mutual fund company.
Clients may purchase shares of mutual funds directly from the mutual fund issuer, its principal
underwriter, or a distributor without purchasing the services of Altamont Capital Management, LLC or
paying the advisory fee on such shares (but subject to any applicable sales charges). Certain mutual funds
are offered to the public without a sales charge. In the case of mutual funds offered with a sales charge,
the prevailing sales charge (as described in the mutual fund prospectus) may be more or less than the
applicable advisory fee. However, clients would not receive Altamont Capital Management, LLC’s
assistance in developing an investment strategy, selecting securities, monitoring performance of the
account, and making changes as necessary.
Please refer to Item 12 “Brokerage Practices” of this brochure for additional information
Termination of Advisory Agreement
Clients may terminate their contract with the Adviser at any time upon written notice without the
imposition of any penalty. The client will be billed for costs incurred up to the date of termination. The
Adviser will refund the pro rata, unearned portion of the advisory fees paid to the Adviser.
Clients will receive full refunds should they terminate the agreement within five business days of signing
with the Adviser.
Item 6. Performance Based Fees and Side by Side Management
Altamont Capital Management, LLC does not charge performance-based fees or participate in side-by-
side management. Side-by-side management refers to the practice of managing accounts that are charged
performance-based fees while at the same time managing accounts that are not charged performance-
based fees. Performance-based fees are fees that are based on a share of capital gains or appreciation of
the assets of a client. Our fees are calculated as described in Fees and Compensation section above and
are not charged on the basis of performance of your advisory account.
Item 7. Types of Clients and Minimum Requirements
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The Adviser generally provides investment advice to individuals, high net worth individuals, pension and
profit-sharing plans, trusts, estates, corporations and other business entities.
In general, a minimum of $150,000 is required to open and maintain an advisory account. At our
discretion, we may waive the minimum account size. For example, we may waive the minimum if you
appear to have significant potential for increasing your assets under management. We may also combine
account values for you and your minor children, joint accounts with your spouse, and other types of related
accounts to meet the stated minimum.
Item 8. Method of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
The Adviser’s method of security analysis is primarily fundamental, based upon sources of information
from research materials, financial newspapers and magazines, annual reports, prospectuses, filings with
the SEC and company press releases.
When using fundamental analysis, the data we review is generally considered reliable, but we cannot
guarantee, nor have we verified its accuracy. In addition, the data that we review is sometimes subjective
in nature and open to interpretation. Even if our data and interpretation of the data is correct, there may
be other factors that determine the value of securities other than those considered in fundamental analysis.
Principal Investment Strategies
The Adviser typically uses a long-term investment strategy to implement investment advice given to
clients.
Adviser’s investment strategy is based upon long-term investment objectives that incorporate the
principles of Modern Portfolio Theory. Adviser’s investment approach is firmly rooted in the belief that
markets are “efficient,” and that investors’ returns are determined principally by asset allocation decisions,
not market timing or stock picking. Adviser provides access to diversified portfolios, which make use of
passively managed, asset class mutual funds that are available only to institutional investors and clients
of a network of selected investment advisors.
A long-term purchase strategy generally assumes the financial markets will go up in the long-term, which
may not be the case. There is also the risk that the segment of the market that you are invested in or
perhaps just your particular investment will go down over time even if the overall financial markets
advance. Purchasing investments long-term may involve an opportunity cost – that of “locking-up” assets
that may be better utilized in the short-term for other investments.
Principal Investment Risks
Investing in securities involves risk of loss that clients should be prepared to bear. Risk refers to the
possibility that you will lose money (both principal and any earnings) or fail to make money on an
investment. The Adviser cannot guarantee that it will achieve a client’s investment objective. Below are
some of the more specific risks of investments which the Adviser may recommend to clients:
Investment Company Risk. When a client invests in open end mutual funds or ETFs, the client indirectly
bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the
client will incur higher expenses, many of which may be duplicative. In addition, the client’s overall
portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment
practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following
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risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii) the
ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s
shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-
listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large
decreases in stock prices) halts stock trading generally. Adviser has no control over the risks taken by the
underlying funds in which clients invest.
Item 9. Disciplinary Information
The Adviser has no material legal or disciplinary events to report.
Item 10. Other Financial Industry Activities and Affiliations
All but one of the Adviser’s investment advisory representatives are CPAs affiliated with Gould Killian
CPA Group, P.A., an accounting and consulting firm providing accounting, compliance, and tax
consulting services to clients. These advisory representatives spend approximately 95% of their time
providing advice to clients of the accounting firm and 5% of their time providing investment advice.
Savant Wealth Management, LLC is an independent investment adviser registered with the SEC under
the Investment Advisers Act of 1940. Savant Wealth Management’s Advisor Services platform provides
a full array of quality investment management services to the Adviser and its clients. The program also
offers back-office support in the form of quarterly performance reports to clients, risk/return assessments,
investment policy statements, and client services agreements that provide a clear, written description of
the advisory relationship between the Adviser and its clients. Altamont Capital Management, LLC and
Savant Wealth Management are independently owned and operated and are not affiliated.
Item 11. Code of Ethics, Interest in Client Transactions and Personal Trading
Altamont Capital Management, LLC’s Code of Ethics includes guidelines for professional standards of
conduct for our Associated Persons. Our goal is to protect client interests at all times and to demonstrate
our commitment to fiduciary duties of honesty, good faith, and fair dealing. All of Altamont Capital
Management, LLC’s Associated Persons are expected to strictly adhere to these guidelines. Persons
associated with Altamont Capital Management, LLC are also required to report any violations to the Code
of Ethics. Additionally, the firm maintains and enforces written policies reasonably designed to prevent
the misuse or dissemination of material, non-public information about our clients or client accounts by
persons associated with our firm.
Altamont Capital Management, LLC does not buy or sell securities for itself that we also recommend to
clients however, our advisory representatives may buy or sell the same securities for personal and family
accounts that are bought and sold for your account(s).
Altamont Capital Management, LLC’s Code of Ethics is available to you upon request. You may obtain
a copy of our Code of Ethics by contacting Shon Norris at (828) 236-0610.
Item 12. Brokerage Practices
Recommending Brokerage Firms
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Adviser typically recommends Charles Schwab & Co. or Mid Atlantic Trust, to serve as custodian of
clients’ assets and to execute trades in client accounts. Altamont typically recommends Mid Atlantic Trust
Company and Schwab to serve as custodian and broker of record for its retirement plan clients. This
selection criteria is based on these firms’ ability to provide Adviser with duplicate confirmations and
statements, access to a dedicated trading desk and access to an electronic communication network for
client order entry and account information. Each client is charged a transaction fee or commission to
execute securities transactions. The custodian, not the Adviser, determines the transaction fees charged
to clients and, while Adviser believes these fees are competitive these transactions may not always be
executed at the lowest available rate.
Best Execution
As a fiduciary, with respect to transactions it implements on behalf of its advisory clients, the Adviser has
an obligation to obtain best execution under the circumstances of the particular transaction. The Adviser
seeks to execute client transactions in such a manner that the client’s total cost or proceeds in each
transaction is the most favorable under the circumstances. Where client has entered into an arrangement
where a third-party manager executes transactions for the client’s account (for example, clients
participating in Advisor Services) the client should consult the third-party manager’s disclosure brochure
for that manager’s policy with respect to best execution.
Soft Dollars
Adviser does not enter into so-called “soft dollar arrangements,” where the Adviser directs client
commissions to a broker-dealer that provides research and brokerage services to the Adviser.
Order Aggregation
Adviser typically recommends mutual funds, which are purchased and sold for a transaction fee charged
by the client’s executing broker-dealer. Adviser does not “block” or aggregate client trades, because the
trades are executed for a flat fee per fund trade basis and blocking client trades would not result in the
reduction of such fees.
Item 13. Review of Accounts
REVIEWS
Accounts are monitored at regular intervals and reviewed at least semi-annually by the Adviser. There is
no minimum number of accounts assigned to a reviewer. The review process covers each of the following
elements:
A. Review of the client’s Investment Policy Statement;
B. Review of the client’s risk profile; and
C. Recommend rebalancing client’s portfolio if needed.
More frequent account reviews may be triggered by any one or more of the following events:
A. Client’s specific request;
B. Change in client’s investment objectives, risk and return characteristics; and
C.
Imbalance of asset allocation.
REPORTS
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Clients will receive quarterly performance reports, prepared by Savant Wealth Management which
summarize the clients’ asset management account performance. The clients will also receive monthly
statements from Schwab Institutional, which outline the clients’ current securities positions, security cost
basis, and current market value of the client’s portfolio.
Item 14. Client Referrals and Other Compensation
Incoming Referrals
Adviser encourages and promotes referrals of clients to our advisory firm. We do not compensate people
or firms for providing referrals.
Referrals of Other Professionals
Adviser will refer clients to other service professionals if requested or deemed necessary, based on the
specific needs of the client. For example, Adviser may refer clients to legal counsel, accountants and
insurance agents. It is possible that these professionals may, in turn, make referrals of their clients seeking
investment advice to Adviser.
The Adviser will refer clients to other service professionals if requested or deemed necessary, based on
the specific needs of the client. For example, the Adviser may refer clients to legal counsel, accountants
and insurance agents. It is possible that these professionals may, in turn, make referrals of their clients
seeking investment advice to the Adviser.
Item 15. Custody
Adviser does not maintain physical custody of client assets, which are held by the client’s independent
qualified custodian (described under Item 12). All checks deposited into client’s custodial accounts must
be made payable either to the custodian or for the benefit of the account name. Adviser may be deemed
to have limited custody of client assets if it has the authority to deduct its fees from the client’s custodial
account. Clients will receive monthly account statements from their custodian. Clients should review
their account statements carefully. Clients are encouraged to compare the account statements received
from their qualified custodian with any reports received from the Adviser.
Item 16. Investment Discretion
Discretionary Trading Authority
The Adviser provides investment advice on a discretionary basis to certain clients. In such cases, the
client and the Adviser execute an investment advisory agreement wherein the client grants to the Adviser
discretionary authority to act on the Client’s behalf for the limited purpose of buying, selling and trading
securities and all actions necessary or incident to such activities. Clients may impose reasonable
restrictions or limitations on the Adviser’s investment discretion by providing the restrictions or
limitations in writing to the Adviser. Clients are contacted at least annually to determine whether there are
any changes to their financial circumstances or restrictions they wish to impose.
Limited Power of Attorney
Clients typically custody their assets that the Adviser manages with Charles Schwab & Company’s
Institutional Service Group (Schwab), a registered broker-dealer and FINRA/SIPC member, as custodian,
or an agreed-upon money manager/broker dealer. Schwab permits the Adviser or its agent to direct the
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purchase of no-load mutual funds on behalf of the client’s account, as well as to direct the purchase of
individual securities at discounted transaction costs. This arrangement allows all of the client’s
investments to be maintained with one custodian. Clients typically grant Savant Wealth Management a
limited power of attorney for trading purposes only with respect to their custodial account to allow Savant
Wealth Management to place trades or rebalance the client’s account as directed by the Adviser.
Item 17. Voting Client Securities
It is currently the Adviser’s policy not to exercise proxy voting authority over client securities. The
Adviser does not have authority to vote proxies for its clients on any matters regardless of whether the
Adviser’s investment authority is discretionary or non-discretionary. Each client retains sole and absolute
authority and responsibility to vote proxies at client’s own expense with respect to investments owned by
the client. Clients will receive their proxies or other solicitations directly from their custodian. Clients
are free to contact us about a particular solicitation and our office may provide them with assistance.
Item 18. Financial Information
We are capitalized in compliance with applicable regulations and are not aware of any financial conditions
that are reasonably likely to impair the fulfillment of our contractual commitments to our clients. In
addition, we are not required to provide financial information to clients because we do not require the
prepayment of $1,200 or more, six or more months in advance.
Item 19. Requirements for State Registered Advisers
This section is not applicable because the Adviser is registered with the Securities and Exchange
Commission.
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