Overview

Assets Under Management: $343 million
High-Net-Worth Clients: 51
Average Client Assets: $5 million

Services Offered

Services: Portfolio Management for Individuals, Portfolio Management for Institutional Clients

Fee Structure

Primary Fee Schedule (REIK & CO., LLC FIRM BROCHURE (PART 2A OF FORM ADV))

MinMaxMarginal Fee Rate
$0 $5,000,000 1.00%
$5,000,001 $10,000,000 0.75%
$10,000,001 and above 0.50%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $10,000 1.00%
$5 million $50,000 1.00%
$10 million $87,500 0.88%
$50 million $287,500 0.58%
$100 million $537,500 0.54%

Clients

Number of High-Net-Worth Clients: 51
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 68.29
Average High-Net-Worth Client Assets: $5 million
Total Client Accounts: 113
Discretionary Accounts: 110
Non-Discretionary Accounts: 3

Regulatory Filings

CRD Number: 142414
Last Filing Date: 2024-03-05 00:00:00

Form ADV Documents

Primary Brochure: REIK & CO., LLC FIRM BROCHURE (PART 2A OF FORM ADV) (2025-03-13)

View Document Text
Part 2A of Form ADV: Firm Brochure Reik & Co., LLC 15 West 53rd Street New York, NY 10019 Telephone: 212-262-4441 Email: ampierno@reikandco.com March 1, 2025 This brochure provides information about the qualifications and business practices of Reik & Co., LLC. If you have any questions about the contents of this brochure, please contact us at 212-262-4441 or ampierno@reikandco.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. Any references to Reik & Co., LLC. as a “registered investment adviser” or being “registered” with the SEC or any state does not imply a level of training or skill. Additional information about Reik & Co., LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Our firm's CRD number is 142414. Item 2 Material Changes Date of this Firm Brochure: March 1, 2025 Updated from our last Firm Brochure dated: March 1, 2024 This Item will be used to provide our clients with a summary of new and/or updated information on the ADV Part 2A as well as Form CRS (Customer Relationship Summary). We will inform you of the revision(s) based on the nature of the updated information. Consistent with the SEC current 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. As of the date of this Firm Brochure, our firm has had the following material changes to report: Item 4 Advisory Business. On August 28, 2024, the Financial Crimes Enforcement Network (FinCEN) issued a final rule mandating that certain SEC- registered investment advisers establish Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) programs. This rule becomes effective on January 1, 2026. As part of compliance, investment advisers are required to implement a Customer Identification Program (CIP) and must disclose to potential clients that their personal information will be collected for identity verification and regulatory purposes.1 To ensure compliance with this new rule, a new disclosure, found below, has been added to Item 4 Advisory Business disclosures of this Form ADV Part 2A, Firm Brochure: Important Information about Procedures for Opening a New Account To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each natural or legal person who opens an account, which may be an individual or a person other than an individual (such as a corporation, partnership, or trust). What this means for you: When you open an account, we will ask for the name, address, date of birth or formation, tax identification number, and other information pertaining to the accountholder. This information will help us verify the identity of the accountholder. We may also ask to see identifying documents pertaining to the 1 31 CFR Parts 101 and 1032, Found here: https://www.federalregister.gov/documents/2024/09/04/2024- 19260/financial-crimes-enforcement-network-anti-money-launderingcountering-the-financing-of-terrorism 2 accountholder, such as a driver’s license (if you are an individual) or a business license, articles of incorporation, or trust instrument (if the accountholder is not an individual). Form CRS. This year, our firm has no material updates to report. To obtain a copy of our complete Customer Relationship Summary (Form CRS), ADV Part 2A Firm Disclosure Brochure, individual supplemental information, our Code of Ethics or our Privacy Policy, please contact us at: Reik & Co., LLC Attn: COO 15 West 53rd Street New York, NY 10019 Telephone: 212-262-4441 Email: ampierno@reikandco.com 3 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 5 Item 5 Fees and Compensation 6 Item 6 Performance-Based Fees and Side-By-Side Management 9 Item 7 Types of Clients 10 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss 10 Item 9 Disciplinary Information 12 Item 10 Other Financial Industry Activities and Affiliations 12 Item 11 12 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 12 Brokerage Practices 14 Item 13 Review of Accounts 16 Item 14 Client Referrals and Other Compensation 17 Item 15 Custody 17 Item 16 Investment Discretion 17 Item 17 Voting Client Securities 18 Item 18 Financial Information 18 4 Item 4 Advisory Business Reik & Co., LLC is a New York limited liability company and an SEC-registered investment adviser with its principal place of business located in New York, NY. Reik & Co., LLC began conducting business in 2006. William J. Reik, Jr. is the firm's principal shareholder and Managing Member. As of 12/31/2024, we were actively managing approximately $356,591,689 of client assets on a discretionary basis and $26,312,113 of client assets on a non- discretionary basis for a total of $382,903,804 in assets under management. When we act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the investment advice we provide you. Reik & Co., LLC offers the following advisory services to our clients. INVESTMENT SUPERVISORY SERVICES Reik & Co., LLC ("Reik & Co." or “we”) offers and provides clients with general asset management and investment advisory services, taking into account all aspects of each client's particular financial situation and investment objectives. Reik & Co. will render its investment advice via personal consultation with each client. SELECT INVESTOR Select Investor, an investment strategy employed by Reik & Co., is an equity strategy based on creating capital through long-term investment in high quality companies. Company selection criteria include: significant family or inside ownership; a strong franchise; little or no long-term debt and little or no institutional ownership. Portfolios are constructed with concentrated positions and are subject to greater performance and volatility than broader market averages. The strategy employs very low portfolio turnover, emphasizing compounded return rather than realization of capital gains. Our strategy focuses specifically on exchange traded securities and does not employ other types of securities to achieve our goals. Clients may choose to impose reasonable restrictions on investing in certain securities or types of securities. 5 LARGE CAP STRATEGY This investment strategy focuses on large cap securities which pay dividends with the goal of long-term investing. Clients may choose to impose reasonable restrictions on investing in certain securities or types of securities. Important Information about Procedures for Opening a New Account To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each natural or legal person who opens an account, which may be an individual or a person other than an individual (such as a corporation, partnership, or trust). What this means for you: When you open an account, we will ask for the name, address, date of birth or formation, tax identification number, and other information pertaining to the accountholder. This information will help us verify the identity of the accountholder. We may also ask to see identifying documents pertaining to the accountholder, such as a driver’s license (if you are an individual) or a business license, articles of incorporation, or trust instrument (if the accountholder is not an individual). Item 5 Fees and Compensation SELECT INVESTOR Advisory Fees Fees will be payable in arrears at the conclusion of each quarter in which services are rendered and will be based upon the market value of the assets managed by Reik & Co. as follows: Annual Rate 1.00% 0.75% 0.50% Assets under Supervision First $5,000,000 Next $5,000,000 Over $10 million LARGE CAP STRATEGY Assets under Supervision Annual Rate 0.75% All Fees are negotiable in that fees may vary from the above schedule to reflect special client circumstances, which may apply to a specific account. 6 Fixed Fees Reik & Co. may also provide, in limited circumstances, advisory services on a fixed annual advisory fee basis, which is billed on a quarterly basis in advance or in arrears as agreed upon with a client in writing. A fixed annual fee will be based upon the level of services, amount of client portfolio assets and other client specific circumstances and agreed upon with the client. The firm does not require a retainer when accepting a fixed fee arrangement. Conditions for Managing Accounts Although not a requirement, Reik & Co. recommends that clients provide a minimum asset level for new Select Investor accounts of $500,000. General Information on Fees: Clients generally elect to have fees directly debited by the client’s qualified custodian from the client’s designated account and paid to our firm. This authority is granted to Reik & Co., Inc. by the client’s written authorization obtained in the client’s investment management agreement. No fee adjustments shall be made for partial withdrawals, account appreciation, or depreciation within a billing period. If the relationship is closed within a billing period, a pro-rata refund of fees charged shall be made. Our firm does not impose start-up, closing, or penalty fees in connection with the account. Clients may alternatively choose to be invoiced separately. Negotiability of Fees In certain circumstances, Reik & Co.'s fees may be negotiable. Reik & Co. may charge different clients receiving the same services different fees. The above fee schedules are the firm's basic fee schedules generally charged to clients absent negotiable circumstances. Client facts, circumstances and needs are considered in determining the fee schedule. These include the complexity of the client, 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 is identified in the contract between the adviser and each client. Calculation Reik & Co. will directly debit fees, upon written permission of the client, or will bill the client as agreed upon with the client. If we directly debit fees, the client's custodian is advised of the amount of the fee to be deducted from that client's account. On at least a quarterly basis, the custodian is required to send to the client a statement showing all transactions within the account during the reporting period. 7 The fee charges are calculated as described above and are not charged on the basis of a share of capital gains upon or capital appreciation of the funds or any portion of the funds of an advisory client (Section 205(a)(1) of the Investment Advisers Act of 1940, as amended). Termination of Advisory Relationship A client agreement may be canceled at any time, by either party, for any reason upon receipt of 30 days’ prior written notice. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. The client has the right to terminate an agreement without penalty within five business days after entering into the agreement. Mutual Fund and ETF Fees Our firm normally does not recommend mutual funds. Should your account hold such instruments, you should be aware of additional product fees. All fees paid to Reik & Co., LLC for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and/or ETFs to their shareholders. These fees and expenses are described in each fund's prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund directly, without our services. In that case, the client would not receive the services provided by our firm which are designed, among other things, to assist the client in determining which mutual fund or funds are most appropriate to each client's financial condition and objectives. Accordingly, the client should review both the fees charged by the funds and our fees to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Additional Fees and Expenses In addition to our advisory fees, clients are also responsible for the fees and expenses charged by custodians and imposed by broker dealers, including, but not limited to, any transaction charges imposed by a broker dealer with which an independent investment manager effects transactions for the client's account(s). Custodians will also charge custodial and other additional fees for their services. Clients should consult their separate agreements with their respective broker/dealer(s) and qualified custodian(s) to understand these fees and how they impact the client’s account. Grandfathering of Minimum Account Requirements Pre-existing advisory clients are subject to Reik & Co., LLC's minimum account requirements and advisory fees in effect at the time the client entered into the advisory relationship. Therefore, our firm's minimum account requirements will 8 differ among clients. ERISA Accounts / Pension Protection Act of 2006 (PPA) Reik & Co., LLC also manages IRA or other retirement accounts subject to the Pension Protection Act of 2006 (PPA). In all cases, an “eligible investment advice arrangement” or advisory agreement will be executed with the client. We will be considered a “fiduciary advisor” and charge fees to the retirement account based on a level fees basis, which means the fees will not vary based on the investment option selected. The amount of compensation and other consideration reasonably anticipated to be paid, directly or indirectly, to us, in connection with the recommendation(s) is not more than reasonable compensation within the meaning of § 4975(d)(2) of the IRC and ERISA Section 408(b)(2). ERISA Accounts: Our firm is deemed to be a fiduciary to advisory clients that are employee benefit plans or have IRAs according to the Employee Retirement Income and Securities Act ("ERISA") and regulations under the Internal Revenue Code of 1986 (the "IRC"), respectively. As such, our firm is subject to specific duties and obligations under ERISA and the IRC, including restrictions concerning certain forms of compensation. To avoid engaging in prohibited transactions, our firm will only charge fees for investment advice about products for which our firm and related persons do not receive commissions or 12b-1 fees. Advisory Fees in General Clients should note that similar advisory services may (or may not) be available from other registered (or unregistered) investment advisers for similar or lower fees. In addition to our advisory fees, clients are also responsible for any exchange fees and any fees and expenses charged by custodians and imposed by broker- dealers, including, but not limited to, any transaction charges imposed by a broker- dealer with which an independent investment manager affects transaction for the client's account(s). For additional information, please refer to this Form ADV's "Brokerage Practices" section (Item 12). Limited Prepayment of Fees Under no circumstances do we require or solicit payment of fees in excess of $1,200 more than six months in advance of services rendered. Item 6 Performance-Based Fees and Side-By-Side Management Reik & Co., as a matter of policy and practice, does not charge any performance- based fees for its portfolio management services. Side-by-side management refers to multiple client relationships where an adviser manages advisory client relationships and portfolios on a simultaneous basis for 9 individuals, businesses, institutions and also mutual funds and/or hedge funds. In such circumstances, potential conflicts of interest may arise by and between the clients and the mutual and hedge funds, e.g., performance fee arrangements. Reik & Co. does not have these relationships, so we do not have side-by-side management potential or actual conflicts of interests. Our firm, has not in the past and currently does not manage any client relationships for mutual funds or hedge funds or charge any performance fees. Item 7 Types of Clients Reik & Co., LLC does not mandate any minimum fees or account size but does recommend clients have at least $500,000 of assets for management to benefit from our services. Our firm provides advisory services to the following types of clients: • Individuals (other than high net worth individuals) • High net worth individuals • Pension and profit-sharing plans(other than plan participants) • Charitable organizations Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Select Investor, an investment strategy employed by Reik & Co., is an equity strategy based on creating capital through long-term investment in what we believe are high quality companies. Company selection criteria include: significant family or inside ownership; a strong franchise; little or no long-term debt and little or no institutional ownership. Portfolios are constructed with concentrated positions and are subject to greater performance and volatility than broader market averages. The strategy employs very low portfolio turnover, emphasizing compounded return rather than realization of capital gains. We will use any or a combination of the following methods of analysis in formulating our investment advice and/or managing client 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. 10 Resources. Reik & Co., LLC purchases various forms of research and data, as well as receives market newsletters and information from various sources when formulating our opinions. 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. We use the following strategy(ies) in managing client accounts, provided that such strategy(ies) are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: Long-term purchases. We purchase securities with the idea of holding them in the client's 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 to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Short sales. We borrow shares of a stock for your portfolio from someone who owns the stock on a promise to replace the shares on a future date at a certain price. Those borrowed shares are then sold. On the agreed-upon future date, we buy the same stock and return the shares to the original owner. We may engage in short selling based on our determination that the stock will go down in price after we have borrowed the shares. If we are correct and the stock price has gone down since the shares were purchased from the original owner, the client account realizes the profit. Margin transactions. Reik & Co. manages margin accounts in limited client circumstances when requested by a client and consistent with a client's investment objectives and risk tolerance. Advisory fees can be based on the total market value of a client’s managed portfolio. Stock Market Risk. Stock market risk involves the possibility that stock prices will decline over short or extended periods. Markets tend to move in cycles, with periods of rising prices and falling prices. Investing in the stocks of small- and medium-sized companies involves greater risk than is customarily associated with companies with large market capitalizations. The stock of such companies may be subject to more 11 volatility in price than large-cap company securities. Foreign Securities Risk. Foreign securities are subject to the same market risks as U.S. securities, such as general economic conditions and company and industry prospects. However, foreign securities involve the additional risk of loss due to political, economic, legal, regulatory, and operational uncertainties, differing accounting and financial reporting standards, limited availability of information, currency conversion, and pricing factors affecting investments in the securities of foreign businesses or governments. Risk of Loss. Investing in securities involves the risk of loss that clients should be prepared to bear. Even when the value of the securities sold is greater than the price paid, there is the risk that the appreciation will be less than inflation. In other words, the purchasing power of the proceeds may be less than the purchasing power of the original investment. The profitability of our firm’s recommendations depends much upon correctly assessing the future course of price movements among investments. There can be no assurance that Reik & Co., LLC will be able to predict those price movements accurately. Recommendations made by our firm are subject to certain risks, and loss of principal may occur. Past performance is not indicative of future results. Item 9 Disciplinary Information We are required to disclose any legal or disciplinary events that are material to a client's or prospective client's evaluation of our advisory business or the integrity of our management. Our firm and our management personnel have no reportable regulatory or disciplinary events to disclose. Item 10 Other Financial Industry Activities and Affiliations William Reik, Jr., Member of Reik & Co., serves as a Trustee of Alice Lloyd College and as a Member of the Visiting Committee of the University of Kentucky, College of Law. Although these activities will take some of Mr. Reik’s time during the trading day, Mr. Reik mitigates potential conflicts by ensuring that he has staff in place at all times during the trading day. Mr. Reik spends substantially most of his time on the advisory activities of Reik & Co. and on behalf of the firm’s advisory clients. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Reik & Co. has adopted a Code of Ethics expressing the firm's commitment to ethical conduct. Reik & Co.'s Code of Ethics describes the firm's fiduciary duties and responsibilities to clients and sets forth Reik & Co.'s practice of supervising the personal securities transactions of supervised persons with access to client information. 12 It is the expressed policy of Reik & Co. that no person employed by Reik & Co. shall prefer his or her own interest to that of an advisory client or make personal investment decisions based on the investment decisions of advisory clients. Reik & Co. also requires that anyone associated with this advisory practice with access to advisory recommendations provide initial and annual securities holdings reports and quarterly transaction reports to the firm's Chief Compliance Officer. Reik & Co. requires such access persons to also receive approval prior to investing in certain reportable securities, and any IPOs or private placements (limited offerings). Reik & Co. requires that all individuals must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. Reik & Co.'s Code of Ethics further includes the firm's Insider Trading Policy prohibiting the use of material non-public information. Any individual not in observance of the above may be subject to discipline. Reik & Co. will provide a copy of its Code of Ethics to any client upon request to the Chief Compliance Officer at Reik & Co.'s principal address. Reik & Co. or individuals associated with Reik & Co. may buy or sell securities identical to or different than those recommended to clients for their personal accounts. In addition, any related person(s) may have an interest or position in a certain security(ies) which may also be recommended to a client. It is the expressed policy of Reik & Co. that no person employed by Reik & Co. may purchase or sell any security prior to a transaction(s) being implemented for an advisory account, and therefore, preventing such employees from benefiting from transactions placed on behalf of advisory accounts. As these situations represent a conflict of interest, Reik & Co. has established the following additional restrictions in order to ensure its fiduciary responsibilities: 1. A member, officer or employee of Reik & Co. shall not buy or sell securities for their personal portfolio(s) where their decision is substantially derived, in whole or in part, by reason of his or her employment unless the information is also available to the investing public on reasonable inquiry. No person of Reik & Co. shall prefer his or her own interest to that of the advisory client. 2. Reik & Co. maintains records of all securities holdings and transactions for itself, and anyone associated with this advisory practice with access to advisory recommendations. These holdings are reviewed on a regular basis by an appropriate officer/individual of Reik & Co. 3. Reik & Co. requires that all individuals must act in accordance with applicable regulations governing investment advisory activities. 13 ERISA Accounts When our firm provides investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. Our firm wants you to know that the way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice). • Never put our financial interests ahead of yours when making recommendations (give loyal advice). • Avoid misleading statements about conflicts of interest, fees, and investments. • Follow policies and procedures designed to ensure that we give advice that is in your best interest. • Charge no more than is reasonable for our services. • Finally, we must give you basic information about conflicts of interest. Item 12 Brokerage Practices Selection of Broker-dealers Reik & Co., LLC requires that you direct us to your choice of qualified custodian or broker/dealer. We do not accept discretion to choose the qualified custodian or broker-dealer. As well, we have no arrangements whereby we recommend certain qualified custodians or broker-dealers. Brokers or dealers that Reik & Co., LLC. execute transactions may from time to time refer clients to Reik & Co, LLC. Reik & Co. LLC will not make commitments to any broker or dealer to compensate that broker or dealer through brokerage or dealer transactions for client referrals; however, a potential conflict of interest arises between the client's interest in obtaining best price and execution and Reik & Co.'s interest in receiving future referrals. Direction of Brokerage Many clients, when undertaking an advisory relationship, already have a pre- established relationship with a broker or will instruct the firm to use the brokerage and custody services of that firm or one of the firms recommended by Reik & Co. In these circumstances, clients will instruct Reik & Co. to execute all transactions through that broker. In the event that a client directs Reik & Co. to use a particular broker or dealer, it should be understood that under those circumstances Reik & Co. will not have authority to negotiate commissions, obtain volume discounts and best execution may not be achieved. In addition, under these circumstances a 14 disparity in commission charges may exist between the commissions charged to other clients. Recommendation of Broker-Dealers For clients in need of brokerage or custodial services, and depending on client circumstances and needs, Reik & Co. may recommend the use of several broker dealers, of which the client can choose provided Reik & Co. can meet its fiduciary obligation of best execution. Clients must evaluate these brokers before opening an account. Reik & Co. has no arrangements with any broker/dealer or clearing firm. The factors considered by Reik & Co. when making these recommendations are the broker's ability to provide professional services, Reik & Co.'s experience with the broker, the broker's reputation, and the broker's quality of execution services, commissions and costs of such services, among other factors. Clients are not under any obligation to effect trades through any recommended broker. All clients are free to select any broker-dealer of his or her choice. Aggregation of Transactions Reik & Co. generally does not have the ability to aggregate transactions and clients are not afforded the benefits of aggregated trading. Should it be possible, and we choose to aggregate trades for clients' portfolios, clients may be eligible to receive some benefits from the aggregation. Our firm will only be able to aggregate at each broker-dealer separately, therefore trades will only occur with clients who are using that broker dealer. Aggregated trades at broker dealers are entered separately and prices vary depending on the circumstances of each aggregation. Aggregating trades permits the trading of aggregate blocks of securities composed of assets from multiple clients' accounts so long as transaction costs are shared equally and on a pro-rated basis between all accounts included in any aggregation. Aggregated trading allows Reik & Co. to facilitate equity trades in a more timely, equitable and efficient manner and to seek to reduce overall commission charges to clients. The majority of Reik & Co.'s trades are done on an agency basis with the broker/dealer. Thus, clients pay a commission to the broker for effecting the trade and also pay the market makers the offering or bid prices of the securities purchased or sold. In addition, certain of the broker-dealers may charge a minimum ticket charge ranging from $125 to $150 depending on the firm and the size of the transaction. Minimum ticket charges may be in place of a commission or in addition to a cents per share commission. Allocation of Investments As a matter of policy and practice Reik & Co. seeks to allocate investments fairly and equitably among clients over time so as not to advantage or disadvantage any clients 15 over other clients. In circumstances where only a portion of an order is completed, the firm typically allocates securities among eligible client portfolios on a pro-rata basis. While we strive to achieve fair and equitable treatment for all clients, there is no guarantee that clients using different broker-dealers will receive the same execution price or trade allocation. Orders can be executed in multiple transactions and at different prices, depending on market conditions and execution timing. Clients should consider that variations in execution prices and fees may impact investment performance over time. Soft Dollar Arrangements Reik & Co., LLC does not have any formal soft-dollar arrangements and does not receive any soft-dollar benefits except to the extent that our firm has certain access to proprietary investment research made available by the broker-dealers our firm trades with. Item 13 Review of Accounts & Client Reports Client Reviews The frequency of reviews varies. Portfolio securities will be reviewed on an ongoing basis and investment advisory portfolios will be reviewed by Tyler Bowden, Portfolio Manager, Anne Marie Pierno, Head Trader, William Reik, Jr., Managing Member and Mr. Jeffery Schuss, Consultant, at least quarterly but some accounts may be reviewed more often. Reviews – Reviews will be supported by computerized account information such as an appraisal of market value and performance and gains and losses reports. The account review will focus on fundamental information about the account holdings. Stocks that have deteriorating fundamentals will trigger further investigation and appropriate action. Industry and general market conditions will also be considered. The nature of reviews also varies depending on the goals and directives of the client. Reviewers - Accounts will be reviewed by Tyler Bowden, Portfolio Manager, Anne Marie Pierno, William Reik, Jr., Managing Member and Mr. Jeffery Schuss, Consultant. Investment programs are tailored to the needs of the individual client; however, regular meetings may be held to ensure that the client's investment objectives are being met. Client Reports Reik & Co., LLC will provide a quarterly statement to each client that includes an asset list and appraisal of market value, cost, annual income and current yield. Some clients request more frequent reports, i.e., monthly, and others request additional information, i.e., performance, gains and losses reports. We are flexible about the frequency and nature of client reports. 16 Clients also receive statements of account from their broker-dealer/custodian reflecting activity, positions and values among other things. Clients also receive confirmations of transactions. Item 14 Client Referrals and Other Compensation Reik & Co. has no arrangements where we pay referral fees to solicitors. It is Reik & Co.'s policy not to accept or allow our related persons to accept any form of compensation, including cash, sales awards or other prizes, from a non- client in conjunction with the advisory services we provide to our clients. Item 15 Custody Clients must maintain a qualified custodian to house their assets, as Reik & Co. does not hold client assets. We previously disclosed in the "Fees and Compensation" section (Item 5) of this Brochure that our firm directly debits advisory fees from client accounts. Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review their custodial statements to verify the accuracy of the calculation, among other things. Clients should contact us directly if they believe that there may be an error in their statement. In addition to the periodic statements that clients receive directly from their custodians, we also send account statements directly to our clients on a quarterly basis. We urge our clients to carefully compare the information provided in these statements to ensure that all account transactions, holdings and values are correct and current. Item 16 Investment Discretion Clients may hire us to provide discretionary asset management services, in which case we place trades in a client's account without contacting the client prior to each trade to obtain the client's permission. Our discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell; and/or • determine the amount of the security to buy or sell Clients give us discretionary authority when they sign a discretionary agreement with our firm and may limit this authority by giving us written instructions. Clients may also 17 change/amend such limitations by once again providing us with written instructions. Item 17 Voting Client Securities Proxy Policy Reik & Co., as a matter of policy and practice, does not vote proxies on behalf of clients. Although our firm may provide investment advisory services relative to client investment assets, clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets. Clients are responsible for instructing each custodian of the assets to forward to the client copies of all proxies and shareholder communications relating to the client’s investment assets. We may offer any consulting assistance regarding proxy issues to clients if requested. Our Proxy Policy and information about the voting of a client's proxies, in the event Reik & Co. may ever have proxy voting responsibility for any client(s), are available to a client upon written request sent to Anne Marie Pierno. Legal Proceedings Reik & Co., as a matter of policy and practice, may not provide legal advice or advise or act on behalf of clients for any legal proceedings, including class actions, bankruptcies or other proceedings, involving companies whose securities are held or previously held in client portfolios. 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 a registered advisory firm, we are also required to disclose any financial condition that is reasonably likely to impair our ability to meet our contractual obligations. Reik & Co. has no additional financial circumstances to report. Reik & Co. has not been the subject of any financial or bankruptcy petition at any time. 18