Overview
Assets Under Management: $144 million
Headquarters: NEW YORK, NY
High-Net-Worth Clients: 95
Average Client Assets: $1 million
Services Offered
Services: Portfolio Management for Individuals, Investment Advisor Selection
Fee Structure
Primary Fee Schedule (ADV PART 2A DISCLOSURE BROCHURE)
Min | Max | Marginal Fee Rate |
---|---|---|
$0 | $1,000,000 | 1.50% |
$1,000,001 | $5,000,000 | 1.00% |
$5,000,001 | and above | 0.75% |
Illustrative Fee Rates
Total Assets | Annual Fees | Average Fee Rate |
---|---|---|
$1 million | $15,000 | 1.50% |
$5 million | $55,000 | 1.10% |
$10 million | $92,500 | 0.92% |
$50 million | $392,500 | 0.78% |
$100 million | $767,500 | 0.77% |
Clients
Number of High-Net-Worth Clients: 95
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 98.64
Average High-Net-Worth Client Assets: $1 million
Total Client Accounts: 156
Discretionary Accounts: 152
Non-Discretionary Accounts: 4
Regulatory Filings
CRD Number: 172791
Last Filing Date: 2024-03-27 00:00:00
Form ADV Documents
Primary Brochure: ADV PART 2A DISCLOSURE BROCHURE (2025-03-14)
View Document Text
Radix Organization, Inc.
509 E 79th Street
#19A
New York, NY 10075
Telephone: 212-697-9141
Facsimile: 212-557-4770
March 14 , 2025
FORM ADV PART 2A
BROCHURE
This brochure provides information about the qualifications and business practices of Radix
Organization, Inc. If you have any questions about the contents of this brochure, please contact us at
212-697-9141. 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
Radix Organization, Inc. is available on the SEC's website at www.adviserinfo.sec.gov.
Radix Organization, Inc. is a registered investment adviser. Registration with the United States
Securities and Exchange Commission or any state securities authority does not imply a certain level of
skill or training.
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Item 2 Material Changes
Form ADV Part 2 requires registered investment advisers to amend their brochure when information
becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure,
the adviser is required to notify you and provide you with a description of the material changes.
Since our last annual updating amendment dated March 27, 2024, we have no material changes to
report.
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Item 3 Table Of Contents
Item 1 Cover Page
Item 2 Material Changes
Item 3 Table Of Contents
Item 4 Advisory Business
Item 5 Fees and Compensation
Item 6 Performance-Based Fees and Side-By-Side Management
Item 7 Types of Clients
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Item 9 Disciplinary Information
Item 10 Other Financial Industry Activities and Affiliations
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 12 Brokerage Practices
Item 13 Review of Accounts
Item 14 Client Referrals and Other Compensation
Item 15 Custody
Item 16 Investment Discretion
Item 17 Voting Client Securities
Item 18 Financial Information
Item 19 Requirements for State-Registered Advisers
Item 20 Additional Information
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Item 4 Advisory Business
Description of Services and Fees
Radix Organization, Inc. is a registered investment adviser organized as a corporation under the laws
of the State of New York. We have been providing investment advisory services since 2014. John Kelly
and Linda Schoenheimer are the owners of our firm.
The following paragraphs describe our services and fees. Please refer to the description of each
investment advisory service listed below for information on how we tailor our advisory services to your
individual needs. As used in this brochure, the words "we", "our" and "us" refer to Radix Organization,
Inc. and the words "you", "your" and "client" refer to you as either a client or prospective client of our
firm. We use the terms "we" and "our" throughout this disclosure brochure to refer to Radix
Organization, Inc. The use of these terms is not intended to imply that there is more than one individual
associated with this firm.
Portfolio Management Services
We offer discretionary and non-discretionary portfolio management services. Our investment advice is
tailored to meet our clients' needs and investment objectives. If you retain our firm for portfolio
management services, we will meet with you to determine your investment objectives, risk tolerance,
and other relevant information at the beginning of our advisory relationship. We will use the information
we gather to develop a strategy that enables our firm to give you continuous and focused investment
advice and/or to make investments on your behalf. As part of our portfolio management services, we
will customize an investment portfolio for you according to your risk tolerance and investing objectives.
Once we construct an investment portfolio for you, we will monitor your portfolio's performance on an
ongoing basis, and will rebalance the portfolio as required by changes in market conditions and in your
financial circumstances.
If you participate in our discretionary portfolio management services, we require you to grant our firm
discretionary authority to manage your account. Discretionary authorization will allow us to determine
the specific securities, and the amount of securities, to be purchased or sold for your account without
your approval prior to each transaction. Discretionary authority is typically granted by the investment
advisory agreement you sign with our firm and the appropriate trading authorization forms. You may
limit our discretionary authority (for example, limiting the types of securities that can be purchased for
your account) by providing our firm with your restrictions and guidelines in writing. If you enter into non-
discretionary arrangements with our firm, we must obtain your approval prior to executing any
transactions on behalf of your account.
Portfolio Consulting Services
We provide Portfolio Consulting services where the investment advice provided is custom tailored to
meet your needs and investment objectives. Such services may include a risk tolerance assessment,
asset allocation recommendations, and/or monitoring your account. We may assist you in identifying
categories of mutual funds, government securities, and other investments that are suitable based on
your investment profile. We will not cause any transactions in conjunction with the advice and/or
recommendations given. You will be responsible for implementing our investment recommendations. If
we have access to your account statements, we will monitor your account on a periodic basis to
ensure the account remains aligned with your stated financial objectives. You are free at all times to
accept or reject any of our investment recommendation.
Selection of Other Advisers
As part of our portfolio management services, we may recommend that you use the services of a third
party asset manager ("TPAM") to manage all, or a portion of, your investment portfolio. Factors that we
take into consideration when making our recommendation(s) may include, but are not limited to, the
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following: the TPAM's performance, methods of analysis, fees, your financial needs, investment goals,
risk tolerance, and investment objectives. We will periodically monitor the TPAM(s)' performance to
ensure its management and investment style remains aligned with your investment goals and
objectives.
Types of Investments
We primarily offer advice on equity securities. Additionally, we may advise you on any type of
investment that we deem appropriate based on your stated goals and objectives. We may also provide
advice on any type of investment held in your portfolio at the inception of our advisory relationship. You
may request in writing that we refrain from investing in particular securities or certain types of
securities.
Assets Under Management
As of December 31, 2024, we provide continuous management services for $134,998,160 in client
assets on a discretionary basis, and $49,234,638 in client assets on a non-discretionary basis.
Item 5 Fees and Compensation
Portfolio Management Services
Our fee for portfolio management services is based on a percentage of your assets we manage and is
set forth in the following fee schedule:
Assets Under Management
Up to $1,000,000
$1,000,001 - $5,000,000
Over $5,000,000
Annual Fee
1.50%
1.00%
0.75%
Our annual portfolio management fee is billed and payable quarterly in arrears based on the value of
your account on the last day of the quarter. If the portfolio management agreement is executed at any
time other than the first day of a calendar quarter, our fees will apply on a pro rata basis, which means
that the advisory fee is payable in proportion to the number of days in the quarter for which you are a
client. Our advisory fee is negotiable, depending on individual client circumstances.
At our discretion, we may combine the account values of family members living in the same household
to determine the applicable advisory fee. For example, we may combine account values for you and
your minor children, joint accounts with your spouse, and other types of related accounts. Combining
account values may increase the asset total, which may result in your paying a reduced advisory fee
based on the available breakpoints in our fee schedule stated above.
We will deduct our fee directly from your account through the qualified custodian holding your funds
and securities only when you have given our firm written authorization permitting the fees to be paid
directly from your account. Further, the qualified custodian will deliver an account statement to you at
least quarterly. These account statements will show all disbursements from your account. You should
review all statements for accuracy. In limited circumstances and in our sole discretion, we may invoice
you directly for our fee in lieu of directly deducting our fee from your account. All terms and payment
arrangements will be evidenced in the advisory agreement that you execute with our firm.
You may terminate the portfolio management agreement upon 7-days' written notice to our firm. You
will incur a pro rata charge for services rendered prior to the termination of the portfolio management
agreement, which means you will incur advisory fees only in proportion to the number of days in the
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quarter for which you are a client. We encourage you to review the statement(s) you receive from the
qualified custodian. If you find any inconsistent information with the statement(s) you receive from the
qualified custodian, please call our main office number located on the cover page of this brochure.
Portfolio Consulting Services
Our annualized fee for Portfolio Consulting services is consistent with the fee schedule under our
Portfolio Management Services (see tiered fee schedule above), which may range up to 1.50% of your
portfolio assets. Our fee for this service is billed either monthly or quarterly in arrears. Our fees will be
assessed pro rata in the event that the advisory agreement is executed at any time other than the first
day of a billing period. In certain circumstances, we may also offer Portfolio Consulting Services for a
fixed fee rather than a percentage of your portfolio assets. Our fixed fee for Portfolio Consulting
Services may range up to $50,000, and will be due and payable in either monthly or quarterly in arrear
installments. In limited circumstances, we may charge a fixed fee higher than our stated maximum
where the client's financial circumstances are more complex in nature. Clients engaging our firm
for Portfolio Consulting Services will either be invoiced for payment, or the client can authorize the
acting custodian to deduct the fee from a managed the client for which we are also engaged for
advisory services. All terms of our engagement will be clearly stated in the advisory agreement you
sign with our firm.
You may terminate the Portfolio Consulting Agreement upon 7-days' written notice to our firm. You will
incur a pro rata charge for services rendered prior to termination, which means you will incur advisory
fees only in proportion to the number of days in the month or quarter for which you are a client.
Selection of Other Advisers
Advisory fees charged by TPAMs are separate and apart from our advisory fees. Advisory fees that
you pay to the TPAM are established and payable in accordance with the disclosure brochure provided
by each TPAM to whom you are referred. These fees may or may not be negotiable. You should
review the recommended TPAM's disclosure brochure and take into consideration the TPAM's fees
along with our fees to determine the total amount of fees associated with this program.
You may be required to sign an agreement directly with the recommended TPAM(s). You should
review each TPAM's disclosure brochure for specific information on how you may terminate your
advisory relationship with the TPAM and how you may receive a refund, if applicable. You should
contact the TPAM directly for questions regarding your advisory agreement with the TPAM.
Additional Fees and Expenses
As part of our investment advisory services to you, we may invest, or recommend that you invest, in
mutual funds and exchange traded funds. The fees that you pay to our firm for investment advisory
services are separate and distinct from the fees and expenses charged by mutual funds or exchange
traded funds (described in each fund's prospectus) to their shareholders. These fees will generally
include a management fee and other fund expenses. You will also incur transaction charges and/or
brokerage fees when purchasing or selling securities. These charges and fees are typically imposed by
the broker-dealer or custodian through whom your account transactions are executed. We do not
share in any portion of the brokerage fees/transaction charges imposed by the broker-dealer or
custodian. To fully understand the total cost you will incur, you should review all the fees charged by
mutual funds, exchange traded funds, our firm, and others. For information on our brokerage practices,
please refer to the Brokerage Practices section of this brochure.
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Item 6 Performance-Based Fees and Side-By-Side Management
We do not accept performance-based fees or participate in side-by-side management. Performance-
based fees are fees that are based on a share of capital gains or capital appreciation of a client's
account. 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. Our fees are calculated as described in the Advisory Business section above, and are not
charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in your
advisory account.
Item 7 Types of Clients
We offer investment advisory services to individuals and high net worth individuals.
In general, we do not require a minimum dollar amount to open and maintain an advisory account;
however, we have the right to terminate your account if it falls below a minimum size which, in our sole
opinion, is too small to effectively manage.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Our Methods of Analysis and Investment Strategies
We may use one or more of the following methods of analysis or investment strategies when providing
investment advice to you:
Charting Analysis - involves the gathering and processing of price and volume pattern information for a
particular security, sector, broad index or commodity. This price and volume pattern information is
analyzed. The resulting pattern and correlation data is used to detect departures from expected
performance and diversification and predict future price movements and trends.
Risk: Our charting analysis may not accurately detect anomalies or predict future price movements.
Current prices of securities may reflect all information known about the security and day-to-day
changes in market prices of securities may follow random patterns and may not be predictable with
any reliable degree of accuracy.
Technical Analysis - involves studying past price patterns, trends, and interrelationships in the financial
markets to assess risk-adjusted performance and predict the direction of both the overall market and
specific securities.
Risk: The risk of market timing based on technical analysis is that our analysis may not accurately
detect anomalies or predict future price movements. Current prices of securities may reflect all
information known about the security and day-to-day changes in market prices of securities may
follow random patterns and may not be predictable with any reliable degree of accuracy.
Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a
company's financial statements, details regarding the company's product line, the experience and
expertise of the company's management, and the outlook for the company and its industry. The
resulting data is used to measure the true value of the company's stock compared to the current
market value.
Risk: The risk of fundamental analysis is that information obtained may be incorrect and the
analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's
value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not
result in favorable performance.
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Cyclical Analysis - a type of technical analysis that involves evaluating recurring price patterns and
trends. Economic/business cycles may not be predictable and may have many fluctuations between
long term expansions and contractions.
Risk: The lengths of economic cycles may be difficult to predict with accuracy and therefore the
risk of cyclical analysis is the difficulty in predicting economic trends and consequently the
changing value of securities that would be affected by these changing trends.
Long-Term Purchases - securities purchased with the expectation that the value of those securities will
grow over a relatively long period of time, generally greater than one year.
Risk: Using 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 create an
opportunity cost - "locking-up" assets that may be better utilized in the short-term in other
investments.
Short-Term Purchases - securities purchased with the expectation that they will be sold within a
relatively short period of time, generally less than one year, to take advantage of the securities' short-
term price fluctuations.
Risk: Using a short-term purchase strategy generally assumes that we can predict how financial
markets will perform in the short-term which may be very difficult and will incur a disproportionately
higher amount of transaction costs compared to long-term trading. There are many factors that
can affect financial market performance in the short-term (such as short-term interest rate
changes, cyclical earnings announcements, etc.) but may have a smaller impact over longer
periods of times.
Margin Transactions - a securities transaction in which an investor borrows money to purchase a
security, in which case the security serves as collateral on the loan.
Risk: If the value of the shares drops sufficiently, the investor will be required to either deposit
more cash into the account or sell a portion of the stock in order to maintain the margin
requirements of the account. This is known as a "margin call." An investor's overall risk includes
the amount of money invested plus the amount that was loaned to them.
Option Writing - a securities transaction that involves selling an option. An option is the right, but not
the obligation, to buy or sell a particular security at a specified price before the expiration date of the
option. When an investor sells an option, he or she must deliver to the buyer a specified number of
shares if the buyer exercises the option. The seller pays the buyer a premium (the market price of the
option at a particular time) in exchange for writing the option.
Risk: Options are complex investments and can be very risky, especially if the investor does not
own the underlying stock. In certain situations, an investor's risk can be unlimited.
Our investment strategies and advice may vary depending upon each client's specific financial
situation. As such, we determine investments and allocations based upon your predefined objectives,
risk tolerance, time horizon, financial horizon, financial information, liquidity needs, and other various
suitability factors. Your restrictions and guidelines may affect the composition of your portfolio.
Risk of Loss
Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or
guarantee that our services or methods of analysis can or will predict future results, successfully
identify market tops or bottoms, or insulate clients from losses due to market corrections or declines.
We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past
performance is in no way an indication of future performance.
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Recommendation of Particular Types of Securities
As disclosed under the Advisory Business section in this brochure, we primarily recommend equity
securities. However, we may recommend other types of investments as appropriate for you since each
client has different needs and different tolerance for risk. Each type of security has its own unique set
of risks associated with it and it would not be possible to list here all of the specific risks of every type
of investment. Even within the same type of investment, risks can vary widely. However, in very
general terms, the higher the anticipated return of an investment, the higher the risk of loss associated
with it.
Equity Securities (Stocks): There are numerous ways of measuring the risk of equity securities (also
known simply as "equities" or "stock"). In very broad terms, the value of a stock depends on the
financial health of the company issuing it. However, stock prices can be affected by many other factors
including, but not limited to: the class of stock (for example, preferred or common); the health of the
market sector of the issuing company; and, the overall health of the economy. In general, larger, more
well established companies ("large cap") tend to be safer than smaller start-up companies ("small cap")
but the mere size of an issuer is not, by itself, an indicator of the safety of the investment.
Item 9 Disciplinary Information
Radix Organization, Inc. has been registered and providing investment advisory services since 2014.
Neither our firm nor any of our management persons has any disciplinary information reportable under
this Item instruction.
Item 10 Other Financial Industry Activities and Affiliations
We have not provided information on other financial industry activities and affiliations because we do
not have any relationship or arrangement that is material to our advisory business or to our clients with
any of the types of entities listed below.
1. broker-dealer, municipal securities dealer, or government securities dealer or broker .
2. investment company or other pooled investment vehicle (including a mutual fund, closed-end
investment company, unit investment trust, private investment company or "hedge fund," and
offshore fund).
3. other investment adviser or financial planner.
4. futures commission merchant, commodity pool operator, or commodity trading advisor.
5. banking or thrift institution.
6. accountant or accounting firm.
7. lawyer or law firm.
8. insurance company or agency.
9. pension consultant.
10.real estate broker or dealer.
11.sponsor or syndicator of limited partnerships.
Recommendation of Other Advisers
We may recommend that you use a third party asset manager ("TPAM") based on your needs and
suitability. You are not obligated, contractually or otherwise, to use the services of any TPAM we
recommend.
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Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Description of Our Code of Ethics
We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code
of Ethics includes guidelines for professional standards of conduct for persons associated with our
firm. Our goal is to protect your interests at all times and to demonstrate our commitment to our
fiduciary duties of honesty, good faith, and fair dealing with you. All persons associated with our firm
are expected to adhere strictly to these guidelines. Persons associated with our firm are also required
to report any violations of our Code of Ethics. Additionally, we maintain and enforce written policies
reasonably designed to prevent the misuse or dissemination of material, non-public information about
you or your account holdings by persons associated with our firm. Clients or prospective clients may
obtain a copy of our Code of Ethics by contacting us at the telephone number on the cover page of this
brochure.
Participation or Interest in Client Transactions
Neither our firm nor any persons associated with our firm has any material financial interest in client
transactions beyond the provision of investment advisory services as disclosed in this brochure.
Personal Trading Practices
Our firm or persons associated with our firm may buy or sell the same securities that we recommend to
you or securities in which you are already invested. A conflict of interest exists in such cases because
we have the ability to trade ahead of you and potentially receive more favorable prices than you will
receive. To mitigate this conflict of interest, it is our policy that neither our firm nor persons associated
with our firm shall have priority over your account in the purchase or sale of securities.
Item 12 Brokerage Practices
Brokerage
If you engage our firm for portfolio management services, you will be required to establish an account
with a Qualified Custodian approved by our firm. If you do not direct our firm to execute transactions
through a Qualified Custodian approved by our firm, we reserve the right to not accept your account.
Not all advisers require their clients to direct brokerage. We recommend Qualified Custodians that we
believe to provide quality execution services for you at competitive prices. Price is not the sole factor
we consider in evaluating best execution. We also consider the quality of the brokerage services,
including the value of the firm's reputation, execution capabilities, commission rates, and
responsiveness to our clients and our firm.
Research and Other Soft Dollar Benefits
Our firm does not receive additional brokerage products and services that are considered to have been
paid for with "soft dollars."
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers in exchange for cash or other compensation,
such as brokerage services or research.
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Block Trades
We may combine multiple orders for shares of the same securities purchased for discretionary
accounts; however, we do not combine orders for non-discretionary accounts. If you enter into non-
discretionary arrangements with our firm, we may not be able to buy and sell the same quantities of
securities for you and you may pay higher transaction costs, fees, and/or transaction costs than clients
who enter into discretionary arrangements with our firm.
Item 13 Review of Accounts
Portfolio Management
The Investment Adviser Representative of our firm that is assigned to your account will be
primarily responsible for monitoring your managed accounts on an ongoing basis and conducting
account reviews (at least annually and upon your request) to ensure that the advisory services
provided to you are consistent with your stated investment needs and objectives. Additional reviews
may be conducted based on various circumstances, including, but not limited to: contributions and
withdrawals; year-end tax planning; market moving events; security specific events; and/or, changes in
your risk/return objectives.
You will receive trade confirmations and monthly or quarterly statements from your account
custodian(s). Typically, we do not provide you with additional or regular written reports in conjunction
with account reviews unless otherwise negotiated in the advisory agreement you sign with our firm.
Item 14 Client Referrals and Other Compensation
We do not receive any compensation from any third party in connection with providing investment
advice to you. In addition, we do not compensate any individual or firm for client referrals.
Item 15 Custody
We do not take custody of your funds or securities. Your funds and securities will be held with a bank,
broker-dealer, or other independent, qualified custodian. We may have the authority to deduct our
advisory fees from your account, but only if you previously consented to such deduction in writing.
Your independent custodian may directly debit your account(s) for the payment of our advisory fees,
but only if you previously consented to such deduction in writing. This authority to deduct our advisory
fees from your accounts causes our firm to exercise limited custody over your funds or securities. We
do not have physical custody of any of your funds and/or securities. You will receive account
statements from the independent, qualified custodian(s) holding your funds and securities at least
quarterly. The account statements from your custodian(s) will indicate the amount of our advisory fees
deducted from your account(s) each billing period. You should carefully review account statements for
accuracy.
Under certain circumstances, and only at our client's request, we may wire money on our client's
behalf. We maintain agreements with certain clients via the client's custodian to only wire money to a
like titled account, which our client controls, or to a specific list of third party vendors authorized by our
client's signature with the account custodian. Neither our firm nor any of our Associated Persons have
the ability to affect third party disbursements without client authorization.
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Item 16 Investment Discretion
You may grant our firm discretion over the selection and amount of securities to be purchased or sold
for your account(s) without obtaining your consent or approval prior to each transaction. Before we
can buy or sell securities on your behalf, you must first sign our discretionary management agreement,
and any necessary trading authorization forms. In our sole discretion, we may approve your request
to impose certain conditions or investment parameters for your account(s).
If you enter into non-discretionary arrangements with our firm, we will obtain your approval prior to the
execution of any transactions for your account(s). You have an unrestricted right to decline to
implement any advice provided by our firm on a non-discretionary basis.
Item 17 Voting Client Securities
Proxy Voting
We will not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice
regarding corporate actions and the exercise of your proxy voting rights. If you own shares of
applicable securities, you are responsible for exercising your right to vote as a shareholder.
In most cases, you will receive proxy materials directly from the account custodian. However, in the
event we were to receive any written or electronic proxy materials, we would forward them directly to
you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we
would forward any electronic solicitation to vote proxies.
Item 18 Financial Information
Our firm does not have any financial condition or impairment that would prevent us from meeting our
contractual commitments to you. We do not take physical custody of client funds or securities, or serve
as trustee or signatory for client accounts, and, we do not require the prepayment of more than $1,200
in fees six or more months in advance nor have we filed a bankruptcy petition at any time in the past
ten years. Therefore, we are not required to include a financial statement with this brochure.
Item 19 Requirements for State-Registered Advisers
We are a federally registered investment adviser; therefore, we are not required to respond to this
item.
Item 20 Additional Information
Your Privacy
We view protecting your private information as a top priority. Pursuant to applicable privacy
requirements, we have instituted policies and procedures to ensure that we keep your personal
information private and secure.
We do not disclose any nonpublic personal information about you to any nonaffiliated third parties,
except as permitted by law. In the course of servicing your account, we may share some information
with our service providers, such as transfer agents, custodians, broker-dealers, accountants,
consultants, and attorneys.
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We restrict internal access to nonpublic personal information about you to employees, who need that
information in order to provide products or services to you. We maintain physical and procedural
safeguards that comply with regulatory standards to guard your nonpublic personal information and to
ensure our integrity and confidentiality. We will not sell information about you or your accounts to
anyone. We do not share your information unless it is required to process a transaction, at your
request, or required by law.
You will receive a copy of our privacy notice prior to or at the time you sign an advisory agreement with
our firm. Thereafter, we will deliver a copy of the current privacy policy notice to you on an annual
basis. Please contact our main office at the telephone number on the cover page of this brochure if you
have any questions regarding this policy.
Trade Errors
In the event a trading error occurs in your account, our policy is to restore your account to the position
it should have been in had the trading error not occurred. Depending on the circumstances, corrective
actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account.
Class Action Lawsuits
We do not determine if securities held by you are the subject of a class action lawsuit or whether you
are eligible to participate in class action settlements or litigation nor do we initiate or participate in
litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or
negligence by issuers of securities held by you.
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