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Part 2A of Form ADV: Firm Brochure
Arcadia Investment Management Corporation
161 East Michigan Avenue
Suite 500
Kalamazoo, MI 49007
Telephone: 269/349-0800
Email: info@arcimc.com
Website: www.arcimc.com
3/18/2025
This brochure provides information about the qualifications and business practices of Arcadia
Investment Management Corporation. If you have any questions about the contents of this
brochure or would like additional copies please contact us at 269/349-0800 or
dorsey@arcimc.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 Arcadia Investment Management Corporation is also available on
the SEC’s website at www.adviserinfo.sec.gov. You can search this site by entering a unique
identifying number, known as a CRD number. Our firm’s CRD number is 104867.
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Item 2 Material Changes
This brochure has been updated as follows:
1. Update Assets Under Management as of 12/31/2024 (Item 4).
2. Update assets considered under custody as of 12/31/2024 (Item 15).
Consistent with SEC rules, we will ensure that you receive a summary of any material changes to
this and subsequent Brochures within 120 days of the close of our business’ fiscal year.
Furthermore, we will provide you with other interim disclosures about material changes as
necessary.
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Item 3
Table of Contents
Page
Item 1
Cover Page ...........................................................................................................
1
Item 2 Material Changes .................................................................................................
2
Item 3
Table of Contents .................................................................................................
3
Item 4
Advisory Business ...............................................................................................
4
Item 5
Fees and Compensation .......................................................................................
5
Item 6
Performance-Based Fees and Side-By-Side Management ..................................
6
Item 7
Types of Clients ...................................................................................................
6
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ............................
6
Item 9
Disciplinary Information ......................................................................................
9
Item 10 Other Financial Industry Activities and Affiliations ...........................................
9
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading ..................................................................................................
9
Item 12 Brokerage Practices .............................................................................................
11
Item 13 Review of Accounts .............................................................................................
12
Item 14 Client Referrals and Other Compensation ...........................................................
12
Item 15 Custody ................................................................................................................
12
Item 16
Investment Discretion ..........................................................................................
13
Item 17 Voting Client Securities .......................................................................................
13
Item 18
Financial Information...........................................................................................
14
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Item 4
AIMC Fee-Only Advisory Business
Arcadia Investment Management Corporation (hereinafter referred to as “AIMC”) is a SEC-
registered investment advisor with its principal place of business located in Michigan. We opened
the firm in 1987.
We are owned by three shareholders, two control 25% or more of the company.
We offer the following advisory services to our clients:
PORTFOLIO MANAGEMENT
We provide continuous asset management of your funds based on your needs. We learn about
your goals and objectives based on your circumstances and develop a personal investment policy.
We consider the nature and amount of all assets and sources of income or support, including assets
other than those under our management. We create and manage a portfolio based on the
investment policy. During our data-gathering process, we determine your objectives, time
horizons, risk tolerance, and liquidity needs. As appropriate, we may also review and discuss your
prior investment history, as well as family composition and background.
We manage your accounts on a discretionary or non-discretionary basis. Account management is
guided by your stated objectives (i.e., maximum capital appreciation, growth, income, or growth
and income), as well as tax considerations.
Once your portfolio has been established, we review the portfolio regularly. Changes are made as
appropriate to meet your objectives.
Our investment recommendations are not limited to any specific product or service offered by a
broker-dealer or insurance company and will generally include advice regarding the following
securities:
Exchange-listed securities
Securities traded over-the-counter
Foreign issuers
Warrants
Corporate debt securities (other than commercial paper)
Commercial paper
Certificates of deposit
Municipal securities
Mutual fund shares
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United States government securities
Options contracts on securities
Exchange traded funds
Because some types of investments involve certain additional degrees of risk, they will only be
implemented when consistent with your stated investment objectives, tolerance for risk, liquidity
and suitability.
Fiduciary Status
Pursuant to the Employee Retirement Income Security Act (“ERISA”), and regulations under the
Internal Revenue Code of 1986 (the “Code”), AIMC and individuals providing investment advice
on our behalf (“Fiduciary Advisers” or “FAs”) will be deemed to be investment advice fiduciaries
(“ERISA Fiduciaries”) when we render individualized investment advice to a plan, plan fiduciary,
plan participant or beneficiary, IRA, or IRA owner, Health Savings Accounts (“HSAs”), Archer
Medical Savings Accounts and Coverdell Education Savings Accounts (together, “Retirement
Accounts”) for a fee or other compensation, whether direct or indirect. While we are already
fiduciaries for all of your advisory accounts under the Investment Advisers Act of 1940, we are
required to acknowledge this new ERISA Fiduciary status.
Acknowledgement of Fiduciary Status
Pursuant to the recommendations we provide to your retirement account(s) and your acceptance
thereof, we acknowledge that we are acting as Fiduciaries under ERISA with respect to
recommended transactions. As ERISA Fiduciaries to our clients, we have an affirmative duty of
undivided loyalty to always serve our clients’ best interests and act in utmost good faith, placing
our clients’ interests first and foremost without regard to the financial interests of our employees,
affiliates, and related entities or other parties. Further, as Fiduciaries we are required to act
prudently on our clients’ behalf, exercising care, skill and diligence when providing our services.
As ERISA Fiduciaries, we are committed to these Impartial Conduct Standards:
(i)
providing prudent advice that is, at the time of the recommendation, in the best interest of
our client,
receiving no more than reasonable compensation, and
(ii)
(iii) statements made regarding the recommended transaction, fees and compensation, material
conflicts of interest and other matters relevant to the retirement investor’s investment
decisions, will not be materially misleading at the time they are made.
Managed Assets
As of 12/31/2024, we were actively managing $687,890,000 of assets on a discretionary basis.
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Item 5 Fees and Compensation
INVESTMENT SUPERVISORY SERVICES (“ISS”)
PORTFOLIO MANAGEMENT FEES
Effective July 1, 2011, the annualized fees for Investment Supervisory Services are charged as a
percentage of assets under management, as follows:
9/10 of 1% per year for the initial $1,000,000;
7.5/10 of 1% per year for the next $4,000,000;
5/10 of 1% per year for the balance of the account.
The minimum annual fee is $5,000 per family relationship.
This minimum annual fee may be negotiable under certain circumstances. We may group certain
related accounts for the purpose of achieving the minimum annual fee.
Fees are calculated on the market value of supervised assets on the effective date of our agreement
and quarterly thereafter. You are billed quarterly in advance. You can choose to have invoices
sent directly to the custodian, in which case, a copy will be provided to you for information
purposes.
Limited Negotiability of Advisory Fees: Although we have established the fee schedule reflected
above, we retain the discretion to negotiate alternative fees on a client-by-client basis. Your facts,
circumstances and needs are considered in determining the fee schedule. These include the
complexity of the accounts, assets to be placed under management, anticipated future additional
assets; related accounts; portfolio style, account composition, reports, among other factors. The
specific annual fee schedule will be reflected in your account agreement.
Item 6 Performance-Based Fees and Side-By-Side Management
We do not charge performance-based fees.
Item 7 Types of Clients
We provide advisory services to the following types of clients:
Individuals (other than high net worth individuals)
High net worth individuals
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Pension and profit sharing plans (other than plan participants)
Charitable organizations
Corporations of other businesses not listed above
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
METHODS OF ANALYSIS
We use the following methods of analysis in formulating our investment advice and/or managing
your assets:
Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at
economic and financial factors (including the overall economy, industry conditions, and the
financial condition and management of the company itself) to determine if the company is
underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to
sell).
Fundamental analysis does not attempt to anticipate market movements. This presents a potential
risk, as the price of a security can move up or down along with the overall market
regardless of the economic and financial factors considered in evaluating the stock.
Technical Analysis. We analyze past market movements and apply that analysis to the present in
an attempt to recognize recurring patterns of investor behavior and potentially predict future price
movement.
Technical analysis does not consider the underlying financial condition of a company. This
presents a risk in that a poorly-managed or financially unsound company may underperform
regardless of market movement.
Cyclical Analysis. In this type of technical analysis, we measure the movements of a particular
stock against the overall market in an attempt to predict the price movement of the security.
Risks for All Forms of Analysis. Our securities analysis methods rely on the assumption that the
companies whose securities we purchase and sell, the rating agencies that review these securities,
and other publicly-available sources of information about these securities, are providing accurate
and unbiased data. While we are alert to indications that data may be incorrect, there is always a
risk that our analysis may be compromised by inaccurate or misleading information.
INVESTMENT STRATEGIES
We use the following strategy(ies) in managing your accounts, provided that such strategy(ies) are
appropriate to your needs and consistent with your investment objectives, risk tolerance, and time
horizons, among other considerations:
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Long-term Purchases. We purchase securities with the idea of holding them in your account for a
year or longer. Typically, we employ this strategy when:
We believe the securities to be currently undervalued, and/or
We want exposure to a particular asset class over time, regardless of the current projection
for this class.
A risk in a long-term purchase strategy is that by holding the security for this length of time, we
may not take advantage of short-term gains that could be profitable. Moreover, if our predictions
are incorrect, a security may decline sharply in value before we make the decision to sell.
Short-term purchases. When utilizing this strategy, we purchase securities with the idea of selling
them within a relatively short time (typically a year or less). We do this in an attempt to take
advantage of conditions that we believe will soon result in a price swing in the securities we
purchase.
Trading. We purchase securities with the idea of selling them very quickly (typically within 30
days or less). We do this in an attempt to take advantage of our predictions of brief price swings.
Margin transactions. We will purchase stocks for your portfolio with money borrowed from your
brokerage account. This allows you to purchase more stock than you would be able to with your
available cash and allows us to purchase stock without selling other holdings.
Option writing. We may use options as an investment strategy. 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.
A put gives us the holder 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 use options to speculate on the possibility of a sharp price swing. We 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.
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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.
We use a “spreading strategy” in which we purchase two or more option contracts (for example, a
call option that you buy and a call option that you sell) for the same underlying security. This
effectively puts you on both sides of the market, but with the ability to vary price, time and other
factors.
Risk of Loss. Securities investments are not guaranteed and you may lose money on your
investments. We ask that you work with us to help us understand your tolerance for risk.
Item 9 Disciplinary Information
We are required to disclose any legal or disciplinary events that could be material to your
evaluation of our advisory business or the integrity of our management.
Our firm and our management personnel have no reportable disciplinary events to disclose.
Item 10 Other Financial Industry Activities and Affiliations
We are not engaged in other financial industry activities and have no other industry affiliations.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
We have adopted a Code of Ethics which sets forth high ethical standards of business conduct that
we require of all employees, including compliance with applicable federal securities laws.
We owe a duty of loyalty, fairness and good faith towards you and have an obligation to adhere
not only to the specific provisions of the Code of Ethics but to the general principles that guide the
Code.
Our Code of Ethics includes policies and procedures for the review of quarterly securities
transactions reports as well as initial and quarterly securities holdings reports that must be
submitted by the firm’s access persons. Among other things, our Code of Ethics also requires the
prior approval of any transaction in securities in a limited offering (e.g., private placement), an
initial public offering, or any securities on our Approved List. Our code also provides for
oversight, enforcement and recordkeeping provisions.
We believe the limited nature of the investments made by our officers, directors, shareholders or
investment advisors of securities on the Approved List causes the likelihood of a conflict of
interest to be extremely remote. Purchases and sales by officers, directors, shareholders, and
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investment advisors in the same securities that are purchased in your account indicates our
confidence and commitment to the investment advice we provide. Officers, directors,
shareholders and investment advisors are putting their own funds at risk, largely to the same extent
your funds are put at risk.
Our Code of Ethics further includes the firm’s policy prohibiting the use of material non-public
information. While we do not believe that we have any particular access to non-public
information, we are all reminded that such information may not be used in a personal or
professional capacity.
A copy of our Code of Ethics is available if you wish. You may request a copy by email sent to
Dorsey@arcimc.com, or by calling us at 800/230-6690.
Our Code of Ethics is designed to assure that the personal securities transactions, activities and
interests of our employees will not interfere with (i) making decisions in your best interest and (ii)
implementing such decisions while, at the same time, allowing employees to invest for their own
accounts.
As these situations represent actual or potential conflicts of interest to you, we have established the
following policies and procedures for implementing our firm’s Code of Ethics, to ensure we
comply with its regulatory obligations and provides you with full and fair disclosure of such
conflicts of interest:
1. No principal or employee of our firm may put his or her own interest above your interest.
2. No principal or employee of our firm may buy or sell securities for their personal portfolio(s)
where their decision is a result of information received as a result of his or her employment
unless the information is also available to the investing public.
3.
It is our expressed policy that no person employed by us may purchase or sell any security
prior to a transaction(s) being implemented for an advisory account. This prevents us from
benefiting from transactions placed on behalf of your accounts.
4.
Our firm requires prior approval for any IPO, private placement investments, or securities on
the Approved List by employees of the firm.
5. We maintain a list of all reportable securities holdings for our firm and anyone associated
with this advisory practice that has access to advisory recommendations (“access person”).
These holdings are reviewed on a regular basis by our firm’s Chief Compliance Office or
his/her designee.
6. We have established procedures for the maintenance of all required books and records.
7.
All of our principals and employees must act in accordance with all applicable Federal and
State regulations governing registered investment advisory practices.
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8. We require annual delivery and acknowledgement of the Code of Ethics by every employee
of our firm.
9. We have established policies requiring the reporting of Code of Ethics violations to our
senior management.
10. Any individual who violates any of the above restrictions may be subject to termination.
Item 12 Brokerage Practices
In some cases, you direct us to use a particular broker dealer, so we do not have discretionary
authority to select a different broker dealer. In these cases, when you direct the use of a particular
broker dealer, you may pay higher commissions than if we had discretion to choose the broker
dealer. Your commissions may be different than those charged to other client accounts.
In some cases, we may select or suggest a broker dealer where security transactions are executed.
Our chief objective in the selection of a broker dealer is the best combination of price and
execution. The best price, including commissions and other transaction costs, is normally an
important factor in this decision, but we also consider the quality of brokerage services. Factors
included in brokerage services are execution capability, willingness to commit capital, financial
stability and clearance settlement capability. Given these factors, transactions will not always be
executed at the lowest available commission.
Where more than one broker dealer is believed to be capable of providing the best combination of
price and execution, we will sometimes select a broker dealer who provides research. Research
includes reports on companies, industries and securities; economic and financial data; financial
publications; and computer databases.
We do not pay any broker dealer higher commissions to receive research.
We evaluate brokerage commissions on an ongoing basis using our general knowledge of the
securities and brokerage industry. From time to time, we make a good faith determination that
commissions are reasonable in relation to the value of brokerage services and research received.
AIMC does not receive any non-research products or services from broker dealers.
Research received from broker dealers may be used for any or all accounts.
As a matter of policy and practice, AIMC does not participate in any soft dollar arrangements.
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Item 13 Review of Accounts
INVESTMENT SUPERVISORY SERVICES (“ISS”)
PORTFOLIO MANAGEMENT
REVIEWS: While the underlying securities within accounts are continually monitored, the
accounts are also reviewed regularly. Accounts are reviewed in the context of your investment
objectives and guidelines. More frequent reviews may be triggered by material changes in
variables such as your circumstances, the market, or the political or economic environments.
Accounts are reviewed by the portfolio manager responsible for the account.
REPORTS: In addition to the monthly statements and confirmations of transactions that you
receive from your custodian, we provide quarterly reports summarizing account activity, balances
and holdings.
Item 14 Client Referrals and Other Compensation
As stated in Item 12, our overriding objective in executing transactions, is seeking the best
combination of price and execution. We do not have agreements with any broker dealer to
compensate the broker dealer for client referrals. If a broker dealer can provide the best price and
execution for a transaction, we might select that broker dealer in recognition of a past referral. We
do not incur higher commission costs for your account than from other broker dealers.
It is our policy to not accept or allow any form of compensation, including cash, sales awards or
other prizes, from a non-client in conjunction with the advisory services we provide to you.
Item 15 Custody
We previously disclosed in the “Fees and Compensation” section (Item 5) of this Brochure that
our firm directly debits advisory fees from your accounts at your direction.
As part of this billing process, your custodian is advised of the amount of the fee to be deducted
from your account. Additionally, a copy of the invoice is mailed to you. On at least a quarterly
basis, the custodian is required to send to you a statement showing all transactions within the
account during the reporting period.
Because the custodian does not calculate the amount of the fee to be deducted, it is important for
you to carefully review the copy of the invoice statement to verify the accuracy of the calculation,
among other things. You should contact us directly with any questions or if you believe that there
may be an error in the fee calculation.
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In addition to the periodic statements that you receive directly from the custodian, we also provide
account statements to you on a quarterly basis. We urge you to carefully compare the information
provided on these statements to ensure that all account transactions, holdings and values are
correct and current.
For a small number of accounts, portfolio managers are serving as trustee, creating custody for
those assets. As of 12/31/2024, there are 29 accounts with assets of $56,945,000. A surprise
exam is conducted on an annual basis by an independent accounting firm.
Item 16 Investment Discretion
You may hire us to provide discretionary asset management services, in which case we place
trades in your account without contacting you prior to each trade to obtain permission.
Our discretionary authority includes the ability to do the following without contacting you:
Determine the security to buy or sell; and/or
Determine the amount of the security to buy or sell
You give us discretionary authority when you sign a discretionary agreement with us, and you
may limit this authority by giving us written instructions. You may also change/amend such
limitations by once again providing us with written instructions.
For non-discretionary accounts, you can decline to implement any advice rendered.
Item 17 Voting Client Securities
You can optionally direct us to vote proxies for your accounts, or you can vote proxies yourself.
To make a change to the election selected on the investment management agreement, please
instruct us in writing.
We will vote proxies in your best interest and in accordance with our established policies and
procedures. Our firm will retain all proxy voting books and records for the required length of time
including a copy of each proxy statement received, a record of each vote cast, a copy of any
document created by us that was material in making a decision how to vote proxies, and a copy of
each written client request for information on how the adviser voted proxies. If our firm has a
conflict of interest in voting a proxy, we will notify you of the conflict and retain an independent
third-party to cast a vote.
You may obtain a copy of our complete proxy voting policies and procedures by contacting your
portfolio manager by telephone, email, or in writing. You may also request, in writing,
information on how proxies for your shares were voted. If you make such a request, we will
promptly provide the information.
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With respect to ERISA accounts, we will vote proxies unless the plan documents specifically
reserve the plan sponsor’s right to vote proxies. To direct us to vote a proxy in a particular
manner, contact your portfolio manager by telephone, email, or in writing.
You can instruct us to vote proxies according to particular criteria (for example, to always vote
with management, or to vote for or against a proposal to allow a so-called “poison pill” defense
against a possible takeover). These requests must be made in writing. You can also instruct us on
how to cast your vote in a particular proxy contest by contacting your portfolio manager.
Item 18 Financial Information
Under no circumstances do we require or solicit payment of fees in excess of $1,200 per client
more than six months in advance of services rendered. Therefore, we are not required to include a
financial statement.
As an advisory firm that maintains discretionary authority for accounts or is deemed to have
custody, we are also required to disclose any financial condition that is reasonably likely to impair
our ability to meet our contractual obligations. We have no additional financial circumstances to
report.
We have not been the subject of a bankruptcy petition at any time during the past ten years.
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