Overview
Assets Under Management: $211 million
Headquarters: RIDGEFIELD, CT
High-Net-Worth Clients: 59
Average Client Assets: $3 million
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Fee Structure
Primary Fee Schedule (DIAMANT ASSET MANAGEMENT, INC.)
Min | Max | Marginal Fee Rate |
---|---|---|
$0 | $1,000,000 | 1.50% |
$1,000,001 | $2,500,000 | 1.25% |
$2,500,001 | $5,000,000 | 1.00% |
$5,000,001 | and above | 0.75% |
Minimum Annual Fee: $8,000
Illustrative Fee Rates
Total Assets | Annual Fees | Average Fee Rate |
---|---|---|
$1 million | $15,000 | 1.50% |
$5 million | $58,750 | 1.18% |
$10 million | $96,250 | 0.96% |
$50 million | $396,250 | 0.79% |
$100 million | $771,250 | 0.77% |
Clients
Number of High-Net-Worth Clients: 59
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 93.46
Average High-Net-Worth Client Assets: $3 million
Total Client Accounts: 62
Discretionary Accounts: 62
Regulatory Filings
CRD Number: 107788
Last Filing Date: 2024-10-07 00:00:00
Website: HTTP://WWW.PORTFOLIOADVISOR.COM
Form ADV Documents
Primary Brochure: DIAMANT ASSET MANAGEMENT, INC. (2025-03-25)
View Document Text
INFORMATION BROCHURE
ADVISORS ACT RULE 204-3
ON
DIAMANT ASSET MANAGEMENT, INC.
440 MAIN STREET
RIDGEFIELD, CONNECTICUT 06877
www.portfolioadvisor.com
203-661-6410
Dated 3/24/2025
PART II OF FORM ADV
INVESTMENT ADVISOR REGISTRATION
ON FILE WITH THE
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON D.C.
AS PER ADVISORS ACT RULE 204-3
Item 1 – Cover Page
This Brochure provides information about the qualifications and business practices of Diamant Asset
Management, Inc. If you have any questions about the contents of this Brochure, please contact us at
203-661-6410. 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.
Diamant Asset Management, Inc. 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 about which you determine to hire or retain an Adviser.
Additional information about Diamant Asset Management, Inc. also is available on the SEC’s website
at www.adviserinfo.sec.gov.
Applicant: Diamant Asset Management, Inc. Form ADV Part II Page 2
SEC File Number: 801-28801
Item 2 – Material Changes
On July 28, 2010, the United State Securities and Exchange Commission published “Amendments to
Form ADV” which amends the disclosure document that we provide to clients as required by SEC
Rules. This Brochure dated 3/24/2025 is a similar document to our previous brochure dated
10/07/2024, which was prepared according to the SEC’s requirements and rules.
This section discusses only specific material changes that are made to the Brochure and provides
clients with a summary of such changes. There have been no material changes made to the Brochure.
The date of our last annual update of this brochure was 3/20/2024.
In the past we have offered or delivered information about our qualifications and business practices to
clients on at least an annual basis. Pursuant to 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. 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 Herbert Diamant at 203-661-6410.
Additional information about Diamant Asset Management, Inc. is also available via the SEC’s web site
www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated
with Diamant Asset Management, Inc. who are registered, or are required to be registered, as
investment adviser representatives of Diamant Asset Management, Inc.
Applicant: Diamant Asset Management, Inc. Form ADV Part II Page 3
SEC File Number: 801-28801
Item 3 – Table of Contents
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 .............................................................................................................. 4
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 ............................................................................................................ 8
Item 10 – Other Financial Industry Activities and Affiliations ................................................................ 8
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............ 8
Item 12 – Brokerage Practices .................................................................................................................. 9
Item 13 – Review of Accounts ............................................................................................................... 11
Item 14 – Client Referrals and Other Compensation .............................................................................. 11
Item 15 - Custody ................................................................................................................................... 11
Item 16 – Investment Discretion ............................................................................................................. 12
Item 17 – Voting Client Securities ......................................................................................................... 12
Item 18 – Financial Information ............................................................................................................. 12
Brochure Supplement(s)
Applicant: Diamant Asset Management, Inc. Form ADV Part II Page 4
SEC File Number: 801-28801
Item 4 – Advisory Business
Diamant Asset Management, Inc. (“Investment Manager”) provides investment advisory and
supervisory services on a discretionary basis for a broad base of clients, including individuals, families,
trusts, and retirement plans. Services may include defining investment objectives, asset allocation
among types of securities, and portfolio management of equity and income oriented accounts.
In providing its services, the sole standard of care imposed upon Investment Manager shall be to act
with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent
investment advisor acting in a like capacity and familiar with such matters would use in the conduct of
a like character with like aims. In addition, Investment Manager assumes no responsibility for the
accuracy of information furnished to Investment Manager by a client or a client's agent. With respect
to investing in mutual funds, the client in effect will be paying two management fees, one to
Investment Manager and one to the mutual fund advisor.
Investment Manager was granted registration on December 10th 1986, as an investment advisor
pursuant to Section 203 of the Investment Advisers Act of 1940. Herbert Diamant is the principal
shareholder of Investment Manager. Mr. Diamant has been engaged in the business of providing
investment services to investment clientele since 1978. Prior investment services were rendered
through Diamant Investment Corporation, which was an affiliated broker-dealer. That firm no longer
exists as a registered broker-dealer.
For more than forty-seven years, the Diamant family continues to be actively involved in the
investment business as the sole owners of both Diamant Asset Management, Inc. and Diamant
Investment Corporation. The Diamant’s remain committed to providing senior level, long term
investment advice and personal client attention. We avoid continuous turnover of key personnel to
enable continuity of our relationships.
A client's account is handled by a senior portfolio manager who is an experienced professional.
Although we require a minimum of 7 years of investment experience before becoming a portfolio
manager, Herbert Diamant has 47 years of experience, and Sheila Morgan has over 19 years of
experience. The combined investment experience and seasoning of our portfolio managers has
occurred through many economic and market conditions. To provide its hallmark of high quality and
hands on service to its clients, Investment Manager restricts portfolio management to a limited number
of sizable accounts. As of December 31, 2024, assets under management were $234,001,037, all of
which was held in discretionary accounts.
Item 5 – Fees and Compensation
The specific manner in which fees are charged by Investment Manager is established in a client’s
written agreement with Investment Manager. Fees are billed on a quarterly basis in arrears. Advisory
fees will not be prorated for each capital contribution and withdrawal made during the applicable
Applicant: Diamant Asset Management, Inc. Form ADV Part II Page 5
SEC File Number: 801-28801
calendar quarter. The amount of the portfolio management fee is negotiable. Accounts initiated or
terminated during a quarterly period will be charged a prorated fee. Upon termination of any account,
any earned, unpaid fees will be due and payable. Advisory fees will be determined as of the close of
business on the date at the end of each calendar quarter and will be charged within a two week period
following the end of the quarter. Low balance clients paying the minimum fee may end up with high
effective fee rates and lower cost alternatives may be available. Advisory fees will be allocated
proportionally between the accounts based on portfolio valuations. Management of the account will
commence upon receipt of assets into the account. Clients authorize Investment Manager to directly
debit fees from client accounts.
The annual fee schedule is based on a percentage of the market value and type of assets placed under
management. Fees are calculated by separating the equity and fixed income bond segments of the
overall portfolio. The Equities fee schedule is applied to the equities segment of the overall portfolio,
and the Fixed Income Bonds fee schedule is applied to the fixed income bond segment of the overall
portfolio. Cash equivalents are categorized as part of the fixed income bond portfolio.
The total advisory fee charged is the combination of the two segments. The total advisory fee as a
percentage of assets will be lower with the inclusion of a fixed income bond segment versus all assets
being held in the equity segment.
Equities fee schedule:
Annual Fee Rate
Market Value of Portfolio
$ 0 to $1,000,000
$1,000,001 to $2,500,000
$2,500,001 to $5,000,000
More than $5,000,000
1.50%
1.25%
1.00%
0.75%
Fixed Income Bonds fee schedule:
Annual Fee Rate
Market Value of Portfolio
$ 0 to $1,000,000
$1,000,001 to $10,000,000
More than $10,000,000
0.75%
0.50%
0.375%
Minimum quarterly fee of $2,000.00
Investment Manager’s fees are exclusive of brokerage commissions, transaction fees, and other related
costs and expenses which shall be incurred by the client. Clients may incur certain charges imposed by
custodians, brokers, and other third parties, such as custodial fees, transfer charges, wire transfer fees,
and other similar fees and charges on brokerage accounts and securities transactions. Mutual funds and
Applicant: Diamant Asset Management, Inc. Form ADV Part II Page 6
SEC File Number: 801-28801
exchange traded funds also charge internal management fees, which are disclosed in a fund’s
prospectus.
Such charges, fees and commissions are exclusive of and in addition to Investment Manager’s fee, and
Investment Manager shall not receive any portion of these commissions, fees, and costs.
Item 12 further describes the factors that Investment Manager considers in selecting or recommending
a broker-dealer for client transactions and determining the reasonableness of their compensation.
Generally, the Firm does not household accounts for adult family members; however, in the
circumstance that adult family members request their accounts to be held together in a household the
aggregated investment advisory fee is charged for all of the accounts in the household. In the case
where a parent opens an account and then adds his or her minor children to the account relationship, a
quarterly report will reflect all of the parent’s accounts and include the children’s accounts.
Item 6 – Performance Based Fees and Side-By-Side Management
Performance based fee arrangements (fees based on a share of capital gains on or capital appreciation
of the assets of a client) may create an incentive for an advisor to recommend investments which may
be riskier or more speculative than those which would be recommended under a different fee
arrangement. As we believe this process is contrary to providing conservative investment guidance,
Investment Manager does not charge any performance-based fees.
Side-By-Side Management typically permits an institutional manager to run a hedge fund alongside an
investment fund in order to provide higher compensation to the manager. Investment Manager does
not engage in this type of business, preferring to focus its efforts serving the needs of individual
investors.
Item 7 – Types of Clients
Investment Manager provides portfolio management services to individuals, high net worth individuals,
individual retirement plans, corporate pension and profit-sharing plans, trusts, estates, and foundations.
We typically provide investment advice and management to high net worth individuals and families.
Therefore, our focus is on the investment issues relating to individual accounts.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
The Investment Manager’s method of security analysis is mainly fundamental in nature, reviewing
information such as sales, profits, strength of balance sheet, product mix, and management.
Investment Manager may also use technical charting to confirm decisions.
Applicant: Diamant Asset Management, Inc. Form ADV Part II Page 7
SEC File Number: 801-28801
Our own research and judgment is used to select specific securities for portfolios. The main sources
of information include annual reports, filings with the Securities and Exchange Commission, research
material prepared by others, financial newspapers and magazines, and corporate rating services.
Investment Manager uses Argus Research for macroeconomic research, company specific research,
and for discussions and consultations with their analysts regarding specific stock and industry sector
ideas. Investment Manager also relies on information provided from Bloomberg Professional services
and data products.
Investment Manager’s investment strategy is to tailor each investment portfolio to meet the specific
needs of the client. Investment Manager evaluates and designs a portfolio that meets specific
objectives. Based on these goals, appropriate securities are selected. Tax impacts are always
considered, whether building portfolios or selling holdings. Most importantly, we constantly oversee
the portfolio to meet long term investment goals. We buy and hold securities for the long term, and
believe very strongly in the preservation of capital through our conservative investing in quality
securities.
Our preference is to discuss major investment decisions with our clients. Discussions or
correspondence are used to keep clients appraised on how their investments are meeting their
objectives. Communication is especially important when designing investment plans and objectives,
or with substantial shifts in portfolio strategy.
The investment time horizon of Investment Manager is long term in nature. The investment
experience of Investment Manager leads to an investment strategy of a buy and hold approach,
selecting quality equity securities that will grow over time, along with secure income securities.
Investment Manager’s primary strategy does not involve frequent trading of securities, margin, or the
use of option strategies in an attempt to amplify returns.
To position portfolios for a long term capital appreciation, Investment Manager buys and sells equity
securities primarily listed on a national exchange such as the New York Stock Exchange and the
NASDAQ. Our portfolios typically include high quality, domestic, blue chip type stocks, but may
include international stocks. Depending on the client’s investment objectives, some portfolios may
include more aggressive investments in mid-cap and/or small cap stocks. Portfolios may include
investments in ETF’s (exchange traded funds) to gain access to a particular market or industry sector.
To meet income needs, portfolios of high net worth individual investors may include quality municipal
bonds. Portfolios of tax exempt entities (such as retirement accounts) and low tax bracket individuals,
may include secure corporate bonds to satisfy income needs. Investment Manager generally avoids
investing in below investment grade municipal bonds or corporate bonds, as it focuses on the goal of
capital preservation and stable income over the objective of maximizing return. Publicly traded
limited partnerships and real estate investment trusts may also be used as income vehicles.
Our client investment portfolios are allocated by selected asset classes, which may include equities,
bonds, and cash equivalents. Stock portfolios are further diversified between industry groups and
stock selections. Bond holdings are diversified into multiple securities to avoid concentration with one
Applicant: Diamant Asset Management, Inc. Form ADV Part II Page 8
SEC File Number: 801-28801
municipality. We believe this investment strategy and style typically does not involve significant or
unusual risks. Our experience is that our buy and hold philosophy, combined with a long term time
horizon, mitigates material risks. Nonetheless, 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 Investment Manager or the integrity of
Investment Manager’s management. At all times which are material to this disclosure, neither
Investment Manager or its personnel has been disciplined.
Item 10 – Other Financial Industry Activities and Affiliations
Investment Manager has no other financial industry activities or affiliations.
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
Investment Manager‘s corporate Code of Ethics (Code) establishes standards of conduct that are
expected of supervised persons and reflect Investment Manager’s fiduciary duties to its clientele. This
Code reflects Investment Manager’s commitment to high ethical practices and the sharing of
responsibility for maintaining those practices among employees. Fundamental to the personnel
policies and practices that implement the Code is Investment Manager’s insistence that business be
conducted in an environment of mutual respect. Many of these policies are based upon laws and
regulations, others upon widely held philosophical and ethical principles. Violation of these policies
may result in discipline, including termination.
Investment Manager has the responsibility to render professional, continuous, and unbiased
investment advice. As a fiduciary, Investment Manager owes its clients a duty of honesty, good faith,
and fair dealing. Further, Investment Manager must act at all times in the client's best interests, and
must either avoid or disclose conflicts of interest. All employees personal securities transactions shall
be conducted in such a manner as to be consistent with the Code, to avoid any actual or potential
conflict of interest, or any abuse of an employee's position of trust and responsibility. As a hallmark of
Investment Manager’s business is confidentiality, information concerning the identity of security
holdings and financial circumstances of clients is and must remain confidential.
Each employee shares the responsibility to comply not only with the plain language of these policies
and applicable laws, but to embrace the spirit and purposes of these policies in their business and
interpersonal conduct. Investment Manager’s reputation is built on principles of honesty, integrity, and
professionalism, and its ability to prosper in the future is dependent on all employees embracing these
Applicant: Diamant Asset Management, Inc. Form ADV Part II Page 9
SEC File Number: 801-28801
principles. All supervised persons at Investment Manager must acknowledge the terms of the Code of
Ethics annually, or as amended. Investment Manager will provide a copy of its Code of Ethics to any
client, or prospective client, upon written request.
Investment Manager does not recommend, buy, or sell securities in which the advisor has a material
financial interest.
Advisory personnel (which includes company officers, employees, directors, stockholders, or members
of their families) may at times have a position in the same securities that clients own and may make
purchases or sales of these securities from time to time in the open market. Personal trading by
Advisory personnel are to be conducted in an ethical manner that complies with industry regulations.
The fact that such persons acquire, or not acquire securities themselves or for any other client is not to
be considered in determining the advisability of acquiring or not acquiring similar securities for the
portfolio account of any client.
All personal securities transactions by Employees must avoid a conflict with the interests of a client.
Personal securities trading that may conflict with the interests of any client is strictly prohibited.
Clients of Investment Manager have priority on purchases and sales before placing orders for advisory
personnel. Advisory personnel must follow Investment Manager’s Client Priority Rule detailed in its
written supervisory procedures when conducting personal securities trading. When entering the same
side trades from a customer and advisory personnel, the customer trade shall be entered ahead of the
advisory personnel trade, except where the market is liquid enough where entering simultaneous trades
would not impact market depth or ability to execute the customer trade. All advisory personnel are
subject to specific procedures, including pre-clearance of transactions and detailed trade reporting and
compliance review.
Item 12 – Brokerage Practices
Investment Manager suggests transactions be placed with Fidelity Brokerage Services LLC., which is
not affiliated with Investment Manager. Clients are not required to designate this broker-dealer.
Substantially all of Investment Manager’s clients have authorized Investment Manager to use this
broker-dealer to hold securities and handle security transactions. If a Client has selected a directed
broker other than Fidelity Brokerage Services LLC., Client agrees the advisor will not be required to
effect any transaction through that directed broker if Investment Manager believes that to do so may
result in a breach of its duties as a fiduciary. Client understands that by instructing Investment
Manager to execute all transactions on behalf of the Account through that directed broker, a disparity
may exist between the commissions borne by the Account and the commissions borne by Investment
Manager’s other client’s that do not direct Investment Manager to use a particular broker-dealer.
Client also understands that by instructing Investment Manager to execute all transactions on behalf of
the Account through such directed broker, Client may not necessarily obtain commission rates and
execution as favorable as those that would be obtained if Investment Manager were able to place
transactions with Fidelity Brokerage Services LLC.
Applicant: Diamant Asset Management, Inc. Form ADV Part II Page 10
SEC File Number: 801-28801
Each portfolio is individually managed. Decisions to buy and sell are made for each account
separately. This process does not create conditions for aggregating the purchase or sale of securities
for various client accounts. If the opportunity arises when customers are buying or selling the same
security, and market conditions are such that in our judgment the aggregating of the order does not
harm the best execution of the transaction, the shares may be aggregated. As the transaction cost is a
small amount of the transaction, the decision to aggregate, or not aggregate orders, does not materially
impact the trade cost to the client.
Investment Manager has an arrangement with National Financial Services LLC, and Fidelity
Brokerage Services LLC (together with all affiliates, "Fidelity") through which Fidelity provides
Investment Manager with Fidelity's "platform" services. The platform services include, among others,
brokerage, custodial, administrative support, record keeping and related services that are intended to
support intermediaries like Investment Manager in conducting business and in serving the best
interests of their clients but that may benefit Investment Manager.
Fidelity charges brokerage commissions and transaction fees for effecting certain securities
transactions (i.e., transactions fees are charged for certain no-load mutual funds, commissions are
charged for individual equity and debt securities transactions). Fidelity enables Investment Manager to
obtain many no-load mutual funds without transaction charges and other no-load funds at nominal
transaction charges. Fidelity’s commission rates are generally considered discounted from customary
retail commission rates. However, the commissions and transaction fees charged by Fidelity may be
higher or lower than those charged by other custodians and broker-dealers.
As part of the arrangement, Fidelity also makes available to Investment Manager, at no additional
charge to Investment Manager, certain research and brokerage services, including research services
obtained by Fidelity directly from independent research companies, as selected by Investment Manager
(within specified parameters). These research and brokerage services presently include services on the
Fidelity platform as detailed above, typical services to effect purchases and sales of securities, business
building solutions ranging from marketing support to client management tools, retirement programs to
help meet asset accumulation and income distribution needs of clients, a dedicated relationship
manager for consultation and support of day-to-day business needs, a data feed of securities activity,
and combined technology integration, training and support. These research and brokerage services are
used by Investment Manager to manage accounts for which Investment Manager has investment
discretion.
As a result of receiving such services for no additional cost, Investment Manager may have an
incentive to continue to use or expand the use of Fidelity's services. Investment Manager examined
this potential conflict of interest when it chose to enter into the relationship with Fidelity and has
determined that the relationship is in the best interests of Investment Manager's clients and satisfies its
client obligations, including its duty to seek best execution. A client may pay a commission that is
higher than another qualified broker-dealer might charge to effect the same transaction where the
Investment Manager determines in good faith that the commission is reasonable in relation to the value
of the brokerage and research services received. In seeking best execution, the determinative factor is
not the lowest possible cost, but whether the transaction represents the best qualitative execution,
taking into consideration the full range of a broker-dealer’s services, including the value of research
Applicant: Diamant Asset Management, Inc. Form ADV Part II Page 11
SEC File Number: 801-28801
provided, execution capability, commission rates, and responsiveness. Accordingly, although
Investment Manager will seek competitive rates, to the benefit of all clients, it may not necessarily
obtain the lowest possible commission rates for specific client account transactions. Although the
investment research products and services that may be obtained by Investment Manager will generally
be used to service all of Investment Manager’s clients, a brokerage commission paid by a specific
client may be used to pay for research that is not used in managing that specific client’s account.
Investment Manager and Fidelity are not affiliates, and no broker-dealer affiliated with Investment
Manager is involved the relationship between Investment Manager and Fidelity.
Item 13 – Review of Accounts
Reviews of an investment advisory account are triggered by the calendar year. A full review occurs
every six months. Minor reviews are performed when changes in price or income occur on securities.
There is one reviewer of the portfolio. This person is either a principal or an investment advisory
representative of Investment Manager. The reviewer may rely on assistance from Investment
Manager’s portfolio managers in an account review. The President performs reviews of all accounts. It
is Investment Manager’s intent to seek approximately one hundred accounts. The reviewer is
instructed to monitor investment performance in relation to each client's goals and objectives. If, as a
result of a review performed when changes of price or income occurred, the reviewer concludes that a
change in investment is warranted, the reviewer may take the action needed to implement the change
in investment.
The nature and frequency of regular reports to clients on their accounts is a quarterly portfolio analysis
and review. These market valuation reports are sent separately from Customer Statements sent by a
broker-dealer, which detail the account activity and the custody and safekeeping of positions for the
period. For information on custody, see Item 15.
Item 14 – Client Referrals and Other Compensation
We encourage referrals of potential clients from our existing client base, based on the presumption
Investment Manager may be able to provide needed assistance with their financial affairs. No
economic benefit or compensation is paid directly or indirectly to any person, for any referral of
business.
Item 15 - Custody
Investment Manager does not actually hold any securities. It is engaged in the investment advisory
business and maintains regulatory compliance pursuant to the Investment Advisors Act of 1940.
Applicant: Diamant Asset Management, Inc. Form ADV Part II Page 12
SEC File Number: 801-28801
Investment Manager is deemed to have custody under the Investment Advisers Act of 1940 because its
principal, Herbert Diamant, is a trustee of various client trust accounts.
Item 16 – Investment Discretion
Investment Manager 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. Investment discretion
is part of the investment advisory contract signed by the client. 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, Investment Manager observes the investment
policies, limitations and restrictions of the clients for which it advises. Investment guidelines and
restrictions must be provided to Investment Manager in writing.
Item 17 – Voting Client Securities
It is the policy of Investment Manager that when it exercises voting authority over client proxies, the
proxies are voted in the best interests of the clients. We shall exercise the duties of care and loyalty
when voting proxies. The duty of care requires us to monitor corporate events and to vote the proxies.
This duty of care does not mean that failure to vote on every proxy would necessarily violate our
fiduciary obligations. To satisfy its duty of loyalty, Investment Manager must cast the proxy votes in a
manner consistent with the best interest of its client and must not subrogate client interests to
Investment Manager’s own interest. Upon receipt of a written request directly from a client, we shall
provide records of proxy voting information with respect to the particular client’s holdings. On receipt
of a written request from a client, we shall provide a copy of our voting policies and procedures.
Item 18 – Financial Information
Registered investment advisers are required in this Item to provide you with certain financial
information or disclosures about Investment Manager’s financial condition. Investment Manager 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.
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Item 1 – Cover Page
Herbert Diamant
DIAMANT ASSET MANAGEMENT, INC.
440 Main Street
Ridgefield, Connecticut 06877
203-661-6410
Brochure Supplement
Dated 3/24/2025
This Brochure Supplement provides information about Herbert Diamant that supplements the Diamant
Asset Management, Inc. Brochure. You should have received a copy of that Brochure. Please contact
Herbert Diamant if you did not receive Diamant Asset Management, Inc.’s Brochure or if you have
any questions about the contents of this supplement. Additional information about Herbert Diamant is
available on the SEC’s website at www.adviserinfo.sec.gov.
Item 2 – Educational Background and Business Experience
Herbert Diamant: Born 1957. Graduated from Georgetown University BSBA with Finance and
Marketing dual majors, and an Economics minor. Business background: Officer and Senior Portfolio
Manager of the registered investment advisory firm of Diamant Asset Management, Inc. Officer,
General Securities Principal, Financial and Operations Principal, Limited Representative Equity Trader,
Municipal Securities Principal, and General Securities Registered Representative of self-clearing,
general securities broker/dealer firm of Diamant Investment Corporation for thirty-nine years from
1978 to 2017.
Item 3 – 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 each supervised person providing
investment advice. No information is applicable to this item.
Item 4 – Other Business Activities
Herbert Diamant is solely engaged in the investment related business of Diamant Asset Management,
Inc. There are no other business activities to report.
Applicant: Diamant Asset Management, Inc. Form ADV Part II
Brochure Supplement: Herbert Diamant
Item 5 – Additional Compensation
There are no arrangements for additional compensation or economic benefit to Herbert Diamant from
any person who is not a client.
Item 6 – Supervision
Diamant Asset Management Inc. and its employees follow both a written Code of Ethics and written
General Office Supervisory Procedures. These manuals provide procedures and methods to ensure the
firm maintains compliance with laws, regulations, and the proper practices of an investment advisor.
The Firm has purposely limited the number of employees and has maintained itself as a small company.
Given its small size, one or two individuals must provide appropriate supervision, inspection, and other
responsibilities which at larger firms may be provided by larger staffs. Despite its limited personnel,
the Firm follows procedures to operate a regulatory compliant business.
Herbert Diamant has the experience to hold several positions at Diamant Asset Management Inc. His
roles include Senior Portfolio Manager and Chief Compliance officer. The Chief Compliance Officer
is responsible for monitoring the advice the supervised person provides to clients. In this case, Sheila
Morgan monitors the advice of Herbert Diamant. Mr. Diamant can be reached at 203-661-6410.
The sole shareholder and owner of Diamant Asset Management Inc. is Herbert Diamant. As such, he
has a vested interest in ensuring the advice rendered is in line with stated procedures. To continue the
long-term client relationships he enjoys, his focus is therefore aligned with customers to make sure
client investment needs continue to be met over time.
Item 1 – Cover Page
Sheila Morgan
DIAMANT ASSET MANAGEMENT, INC.
440 Main Street
Ridgefield, Connecticut 06877
203-661-6410
Brochure Supplement
Dated 3/24/2025
This Brochure Supplement provides information about Sheila Morgan that supplements the Diamant
Asset Management, Inc. Brochure. You should have received a copy of that Brochure. Please contact
Herbert Diamant if you did not receive Diamant Asset Management, Inc.’s Brochure or if you have
any questions about the contents of this supplement. Additional information about Sheila Morgan is
available on the SEC’s website at www.adviserinfo.sec.gov.
Item 2 – Educational Background and Business Experience
Sheila Morgan: Born 1979. Graduated from the University of Connecticut in 2004 with dual degrees
in Economics and Political Science, with a minor in history. Business background: Portfolio Manager
of the registered investment advisory firm of Diamant Asset Management, Inc. Financial Consultant
for Charles Schwab & Co., for two years. Worked for ten years in the High Net Worth space for U.S.
Trust, Bank of America Private Wealth Management, and Northern Trust Global Advisors, Inc. Held
the Series 7 and 66 securities licenses. Holds the Accredited Asset Management Specialist,
AAMS® designation from the College of Financial Planning.
Item 3 – 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 each supervised person providing
investment advice. No information is applicable to this item.
Item 4 – Other Business Activities
Sheila Morgan is solely engaged in the investment related business of Diamant Asset Management, Inc.
There are no other business activities to report.
Item 5 – Additional Compensation
There are no arrangements for additional compensation or economic benefit to Sheila Morgan from
any person who is not a client.
Applicant: Diamant Asset Management, Inc. Form ADV Part II
Brochure Supplement: Sheila Morgan
Item 6 – Supervision
Diamant Asset Management Inc. and its employees follow both a written Code of Ethics and written
General Office Supervisory Procedures. These manuals provide procedures and methods to insure the
firm maintains compliance with laws, regulations, and the proper practices of an investment advisor.
The Firm has purposely limited the number of employees and has maintained itself as a small company.
Given its small size, one or two individuals must provide appropriate supervision, inspection, and other
responsibilities which at larger firms may be provided by larger staffs. Despite its limited personnel,
the Firm follows procedures to operate a regulatory business which is compliant.
Sheila Morgan has sufficient experience in investment management to be a Portfolio Manager to
clients. The Chief Compliance Officer is responsible for monitoring the advice the supervised person
provides to clients. In this case, Herbert Diamant acts as Chief Compliance Officer and monitors the
advice of Sheila Morgan. Mr. Diamant can be reached at 203-661-6410.