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SCHLINDWEIN ASSOCIATES, LLC
1717 Main Street, Suite 3975
Dallas, Texas 75201
(469) 385-7040
www.sallc.com
March 31, 2025
This brochure provides information about the qualifications and business practices of
Schlindwein Associates, LLC. If you have any questions about the contents of this brochure,
please contact us at (469) 385-7040 or info@sallc.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. Registration with the Securities and Exchange Commission
does not imply any particular level of skill or training.
Additional information about Schlindwein Associates, LLC is available on the SEC’s website
at www.adviserinfo.sec.gov.
Schlindwein Associates, LLC
March 31, 2025
Material Changes
There are no material changes to Schlindwein Associates, LLC’s (the “Firm”) Form ADV, Part
2A (“brochure”) since the Firm’s last annual brochure dated March 27, 2024.
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TABLE OF CONTENTS
Page
Table of Contents
MATERIAL CHANGES ............................................................................................................... 2
TABLE OF CONTENTS ............................................................................................................... 3
ADVISORY BUSINESS ............................................................................................................... 4
FEES AND COMPENSATION .................................................................................................... 5
PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ............................... 6
TYPES OF CLIENTS .................................................................................................................... 6
METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ................ 6
DISCIPLINARY INFORMATION ............................................................................................... 8
OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .................................. 8
CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
AND PERSONAL TRADING .......................................................................................... 9
BROKERAGE PRACTICES......................................................................................................... 9
REVIEW OF ACCOUNTS ......................................................................................................... 12
CLIENT REFERRALS AND OTHER COMPENSATION ....................................................... 12
CUSTODY ................................................................................................................................... 12
INVESTMENT DISCRETION ................................................................................................... 12
VOTING CLIENT SECURITIES ............................................................................................... 13
FINANCIAL INFORMATION ................................................................................................... 13
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Advisory Business
Schlindwein Associates, LLC (the “Firm”) provides discretionary and non-discretionary
investment supervisory services to individuals and institutions, investment guidance programs for
corporate and not-for-profit groups and consulting services on investment management issues.
The Firm was founded in 1995. Timothy A. Schlindwein indirectly owns 99% of the Firm and his
wife owns the remaining 1%. As of December 31, 2024, the Firm manages $195,754,361 million
in assets on a discretionary basis.
The Firm’s investment supervisory services consist primarily of a portfolio management service
that allocates and periodically reallocates the client’s assets among various investment vehicles
and securities. The Firm invests client assets primarily in open-end investment companies
(“mutual funds”) and exchange-traded funds (“ETFs”), but may also invest client assets in variable
annuity and variable life insurance contracts, closed-end investment companies and other types of
pooled investment products, structured notes, and, to a lesser extent, individual securities. Based
upon a review of the client’s investment objectives, risk tolerance and financial and tax
circumstances, the Firm creates a model client portfolio. Clients may restrict or prohibit purchases
of certain types of securities in their accounts. For clients with similar characteristics, the Firm
provides substantially identical portfolio recommendations, depending upon each client’s
individual circumstances.
The Firm’s investment consulting services include ongoing asset allocation advice, ongoing
mutual fund reviews and recommendations and mutual fund advisory programs. In certain
circumstances, the Firm will also provide clients recommendations based on third-party research.
The Firm has developed a questionnaire that is designed to assess investor risk tolerance, which it
uses to recommend overall asset allocation and specific investment options consistent with this
allocation.
The Firm may recommend that clients rollover their retirement or other account into an individual
retirement account (“IRA”) maintained at Charles Schwab. The Firm charges a flat fee plus an
asset-based fee on all investment advisory accounts, including IRA accounts. As a result, the Firm
has an incentive to encourage clients to rollover their assets to an IRA account to which the Firm
charges fees based on the amount of assets in the account. In addition, as discussed further below
in this section and in “Brokerage Practices” below, maintaining client accounts at Charles Schwab
creates some conflicts of interest for the Firm based on the way Charles Schwab charges fees to
the Firm and the benefits the Firm receives from Charles Schwab.
In connection with its investment advisory services, the Firm assists eligible clients with IRAs
and/or employer-sponsored retirement accounts in meeting their required minimum distributions
(“RMDs”). In doing so, the Firm is not providing tax advice and assumes no responsibility for
miscalculations of RMDs
The Firm also offers its services to certain clients of CIBC Wealth Management (“CIBC”), a
division of CIBC Bank USA. The Firm renders continuous investment advice to CIBC regarding
the investment and reinvestment of assets in the accounts of certain clients of CIBC (“CIBC
Clients”) in mutual funds and other securities based upon the investment objectives, policies and
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restrictions applicable to each CIBC Client account. CIBC Clients deal directly with CIBC and
not with the Firm. The Firm manages the assets of CIBC Clients using a style similar to the style
the Firm uses in managing its own clients’ assets.
Fees and Compensation
The Firm charges clients participating in the portfolio management service a fee, payable quarterly
in arrears, at the following annual rates:
Standard
$1,000
Not-for-
Profit
$500
BASE FEE ..............................................................
Plus
ASSET FEE
$1,000,000 or less ...................................................
over $1,000,000 to $5,000,000 ................................
over $5,000,000 .......................................................
0.75%
0.50%
0.25%
0.50%
0.30%
0.15%
The Firm calculates the asset fee by applying the schedule to the value of the portfolio on the last
day of each calendar quarter, and pro-rates the fee for periods less than a full quarter. The Firm
typically bills the client’s custodian(s) which pays the fee from the assets of the client’s portfolio.
With respect to client assets held in Individual Retirement Accounts and retirement plans or
invested in variable annuity or variable life insurance contracts, clients may be given the option of
paying fees directly.
Alternatively, the Firm may, in certain instances, provide investment advisory services for an
hourly fee. In these instances, the Firm’s maximum hourly fee rate is $500.
Fees for the Firm’s portfolio management service are not negotiable, but the Firm may waive the
fee in whole or in part, for varying periods of time, at its sole discretion in connection with
promotional efforts or for any other reason. The Firm may waive fees for members or employees
of the Firm and members of their families.
With respect to the mutual funds and other pooled investment products held in the client’s account,
fees payable to the Firm are in addition to expenses and advisory fees borne by these holdings,
including sales charges and transaction fees. The Firm’s fees could be avoided if the client
invested directly in mutual funds and other pooled products. Clients will incur brokerage and other
transaction costs. For more information on the Firm’s brokerage practices, see “Brokerage
Practices” below.
The Firm charges for other forms of investment supervisory services, including investment
counseling with respect to non-mutual fund securities, investment guidance programs for corporate
and not-for-profit groups and consulting services on investment management issues, on a
negotiated basis.
For its consulting services, the Firm generally receives a negotiable annual fee, payable in quarterly
installments.
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As compensation for the services that the Firm provides to the Bank, the Bank pays the Firm a
quarterly fee based upon the value of each Bank Client account.
Performance‐Based Fees and Side‐by‐Side Management
This item is not applicable to the Firm since the Firm does not charge performance-based fees.
Types of Clients
The Firm provides discretionary and non-discretionary investment supervisory services to
individuals, institutions, investment guidance programs for corporate and not-for-profit groups and
consulting services on investment management issues.
The Firm’s consulting clients include profit sharing plans, bank trust departments, pension plans,
Individual Retirement Accounts, registered investment advisers and other institutional clients. The
Firm’s clients may also include guardians of persons and estates, custodians for individuals
(including minors), partnerships and retirement plans for self-employed persons.
The Firm imposes a $500,000 minimum portfolio value for its services, which the Firm may waive
in certain cases.
Methods of Analysis, Investment Strategies and Risk of Loss
The Firm conducts an initial in-depth review of the client’s financial situation, goals and
preferences in order to create an Investment Profile that acts as the blueprint for the client’s
investment portfolio. The Investment Profile is used to establish a strategic asset allocation that
addresses the client’s specific, short, mid and long-term financial goals and emphasizes risk
control.
The Firm seeks to dampen total portfolio risk and provide the client with a wide range of return
opportunities by building a diversified portfolio of high-quality, professionally managed
investment vehicles – primarily open-end mutual funds and exchange-traded funds. Structured
return investments in the form of debt obligations are used from time to time to provide a return
relative to a benchmark index within defined parameters.
Traditional asset classes and market sectors are assessed within a disciplined, return/risk
framework. The primary factors used within the stock allocation are: large versus small
capitalization; growth versus value orientation; and U.S. versus international location. The
primary parameters used within the bond allocation are: duration (the sensitivity of portfolio value
to changes in interest rates); credit quality (the trade-off of yield versus safety); and market sector.
An alternative investment allocation is used to bring diversification benefits to overall portfolio
strategy. Investments can include such asset categories as commodities, convertible securities,
master limited partnerships (MLPs) and real estate, and such strategies as absolute return.
The Firm uses a proprietary ranking system for identifying funds for client investment. Multiple
factors are used to evaluate funds within peer groups. A fund’s total rank is determined by
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applying a proprietary weighting to each of four primary factors – consistency, performance, cost
and experience. Measures of product consistency assess the degree to which a fund’s portfolio
characteristics vary from those of its peer group. Variances in product suggest potential variances
in a fund’s pattern of return and risk from that of the target sector. Funds are identified by their fit
to a primary market sector, but exposure to more than one sector over time is typical. Measures
of style consistency assess the degree to which a fund’s sector exposures vary over time relative
to the variances of its peer group. Variances in sector exposure suggest potential variances in a
fund’s pattern of return and risk from that of the target sector. Fund performance is assessed with
several measures. The Firm believes that consistency of return over time is a more reliable
indicator of superior, long term performance than magnitude of return over shorter periods.
Measures of return consistency assess the frequency with which a fund out-performs its peer group.
Funds with superior “batting averages” are preferred, with greater weight given to the length of
the experience. Fund return is adjusted both to control for risk and to evaluate funds on the basis
of return achieved relative to risk taken. Using a capital asset pricing framework, actual fund risks
are equalized to the peer group risk resulting in adjusted fund returns that are directly comparable.
Fund return and risk are assessed relative to the return and risk profile derived from the fund’s
actual sector exposure over time. Fund return patterns can vary over the market cycle, displaying
different relative performance in up markets versus down markets. Cycle analysis measures a
funds relative performance in up markets versus its relative performance in down markets. Fund
cost is measured on a relative, peer group basis with a scaling in favor of lower cost. Fund cost
consists of two factors, management cost and portfolio cost. Experience is measured on a relative,
peer group basis with a scaling in favor of higher experience. Experience includes three factors –
manager experience, style experience, and fund experience.
The Firm regularly monitors the performance of the investments and the asset allocation, and at
times will fine-tune the portfolio to reflect the current economic and market environment.
A performance benchmark is established based on the client’s asset allocation that enables the
client to measure personal portfolio results against market returns. The Firm periodically reviews
with the client their evolving financial goals and their Investment Profile to confirm the viability
of the current portfolio strategy or to make appropriate strategic shifts.
Investing in securities involves risk of loss that clients should be prepared to bear.
Material risks involved in investing in the Firm’s portfolio management service include:
Market Risk – All securities are subject to market risk. The values of the securities held by a client
may fall rapidly or unpredictably due to a variety of factors, including changing economic, political
or market conditions.
Mutual Fund/ETF Risk – As a shareholder of mutual funds or ETFs, clients bear their
proportionate share of the underlying fund’s fees and expenses. As a result, a client’s cost of
investing will be higher than the cost of investing directly in the underlying funds and may be
higher than investment strategies that invest directly in stocks. In addition, a client’s investments
in mutual funds or ETFs are subject to the particular risks described in the mutual funds/ETFs’
prospectuses, copies of which are provided to the client by the custodian and which the Firm urges
the client to read.
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Equity Securities Risk – To the extent a client’s account invests in equity investments (i.e., stocks),
a particular stock, an industry or stocks in general may fall in value. The value of a client’s account
will go up and down with the prices of the securities in which the account invests. The prices of
stocks change in response to many factors, including the historical and prospective earnings of the
issuer, the value of its assets, management decisions, decreased demand for an issuer’s products
or services, increased production costs, general economic conditions, interest rates, currency
exchange rates, investor perceptions and market liquidity.
Fixed Income Securities Risks – To the extent a client’s account invests in fixed income securities
(i.e., bonds), the investment is subject to call risk, which is the possibility that an issuer may redeem
the security before maturity (a call) at a price below its current market price. An increased
likelihood of a call may reduce the security’s price. If a fixed income security is called, an account
may have to reinvest the proceeds in other fixed income securities with lower interest rates, higher
credit risk, or other less favorable characteristics.
Debt obligations are also generally subject to the risk that the issuer may be unable to make
principal and interest payments when they are due. In addition, securities could lose value because
of a loss of confidence in the ability of the borrower to pay back debt. Non-investment grade
debt – also known as “high-yield bonds” or “junk bonds” – has a higher risk of default and tends
to be less liquid than higher-rated securities.
Fixed income securities are subject to the risk that the securities could lose value because of interest
rate changes. For example, bonds tend to decrease in value if interest rates rise. Debt obligations
with longer maturities sometimes offer higher yields, but are subject to greater price shifts as a
result of interest rate changes than debt obligations with shorter maturities.
Certain fixed income securities, including mortgage-backed securities carry prepayment risks.
Prices and yields of mortgage-backed securities assume that the underlying mortgages will be paid
off according to a preset schedule. If the underlying mortgages are paid off early, for example
when homeowners refinance as interest rates decline, an account may be forced to reinvest the
proceeds in lower yielding, high-priced securities. This may reduce an account’s total return.
Disciplinary Information
The Firm does not have any material legal or disciplinary events to disclose.
Other Financial Industry Activities and Affiliations
This item is not applicable to the Firm since it does not have relationships or arrangements material
to its business or its clients with affiliated financial industry persons. However, Mr. Schlindwein,
the owner of the Firm, serves on the board of directors of Great Lakes Advisors, Inc., a registered
investment adviser.
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Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
The Firm has adopted a code of ethics as required by Rule 204A-1 under the Investment Advisers
Act of 1940. The Firm’s code of ethics sets forth certain standards of business conduct that govern
the personal investment activities of access persons of the Applicant, including the standard that
the interests of advisory clients must be placed first at all times. The code of ethics requires access
persons of the Firm to report their personal securities transactions to the Applicant on a quarterly
basis and their securities holdings upon commencement of employment (or upon becoming an
access person) and annually thereafter. Access persons also must obtain approval from the Firm’s
chief compliance officer before they acquire any security in an initial public offering or limited
offering. The code of ethics applies not only to transactions by the individual, but also to
transactions for accounts in which the person has an interest individually, jointly or as guardian,
executor or trustee, or in which the persons or the person’s spouse, minor children or other
dependents residing in the same household have an interest. Compliance with the code of ethics
is a condition of employment. The code of ethics requires all employees and officers of the Firm
to comply with applicable federal securities laws and to promptly report any violation of the code
to the chief compliance officer. Clients may obtain a copy the Firm’s code of ethics from the Firm
upon request.
The Firm provides investment supervisory services to family members of Mr. Schlindwein. This
may create a conflict of interest, including a possible incentive for the Firm to favor Mr.
Schlindwein’s family members who are clients over other clients. However, the Firm seeks to
mitigate these conflicts by treating these accounts the same as other client accounts.
The Firm invests working capital in shares of money market mutual funds and/or time or demand
deposits in banks.
The Firm may invest in shares of mutual funds, ETFs or other securities that are recommended for
purchase or sale by clients. These investments are in segregated accounts and are for purposes of
creating, analyzing and testing different portfolio strategies in real-time.
Members, managers and employees of the Firm may also invest in shares of mutual funds and
other securities that are recommended for purchase or sale by clients. The Firm and its employees
face a conflict of interest when they buy or sell securities at or about the same time that the Firm
buys or sells the same securities for client accounts, because the Firm or its employees could take
advantage of the information regarding the client transactions and execute their trades prior to the
clients (commonly called “front running”). However, since the Firm, its employees and clients all
predominantly invest in shares of mutual funds, the Firm does not believe the potential for front
running is present.
Brokerage Practices
The Firm generally requires that clients participating in the portfolio management service appoint
Charles Schwab & Co. as custodian and as a designated broker/dealer. This is often called a
directed brokerage arrangement. Not all investment advisers require their clients to direct
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brokerage to a particular firm. By directing brokerage to Charles Schwab, the Firm may be unable
to obtain favorable execution of client transactions, and this may cost clients more money. To the
extent the Firm places transactions involving shares of mutual funds, these costs or disadvantages
should not exist since shares of most mutual funds may be purchased at the offering price (which
may include a sales charge) as set forth in the funds’ prospectuses (“No Transaction Fee Funds”).
The Firm, however, intends to recommend for purchase, and purchase under its discretionary
authority, both No Transaction Fee Funds and Transaction Fee Funds (mutual funds purchased
through designated brokers or dealers which charge a separate and additional transaction fee). A
client would not incur the transaction fee on a Transaction Fee Fund if the shares were purchased
directly from the mutual fund or its underwriter rather than through the designated brokers or
dealers.
Charles Schwab provides on-line services and other support to the Firm. Charles Schwab also
makes its research available to the Firm. The Firm receives substantial benefit from Charles
Schwab since the on-line, other support and research provided to the Firm relieves the Firm from
having to maintain the computer software and other back-office and record keeping systems
provided and from having to purchase or pay for the research provided. The Firm also licenses
and utilizes the computer software and accounting system of Morningstar, Inc. to support the
management of client assets and to provide an array of reporting capabilities for its clients.
Schwab Advisor Services™ (formerly called Schwab Institutional) is Schwab’s business serving
independent investment advisory firms like the Firm. Through Schwab Advisor Services, Charles
Schwab provides the Firm and the Firm’s clients with access to its institutional brokerage
services— trading, custody, reporting, and related services—many of which are not typically
available to Charles Schwab retail customers. However, certain retail customers may be able to
get institutional brokerage services from Schwab without going through the Firm. Charles Schwab
also makes available various support services. Some of those services help the Firm manage or
administer the Firm’s clients’ accounts, while others help the Firm manage and grow the Firm’s
business. Charles Schwab’s support services described below are generally available on an
unsolicited basis (the Firm doesn’t have to request them) and at no charge to the Firm. The
availability to the Firm of Charles Schwab’s products and services is not based on the Firm giving
particular investment advice, such as buying particular securities for the Firm’s clients.
Charles Schwab’s institutional brokerage services include access to a broad range of investment
products, execution of securities transactions, and custody of client assets. The investment
products available through Schwab include some to which the Firm might not otherwise have
access or that would require a significantly higher minimum initial investment by the Firm’s
clients. Charles Schwab’s services described in this paragraph generally benefit the client and the
client’s account.
Charles Schwab also makes available to the Firm other products and services that benefit the Firm
but do not directly benefit the client or its account. These products and services assist the Firm in
managing and administering the Firm clients’ accounts and operating the Firm. They include
investment research, both Schwab’s own and that of third parties. The Firm uses this research to
service all or some substantial number of the Firm’s clients’ accounts, including accounts not
maintained at Charles Schwab In addition to investment research, Charles Schwab also makes
available software and other technology that:
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provide access to client account data (such as duplicate trade confirmations and account
statements);
facilitate trade execution and allocate aggregated trade orders for multiple client accounts;
provide pricing and other market data;
facilitate payment of the Firm’s fees from the Firm’s clients’ accounts; and
assist with back-office functions, recordkeeping, and client reporting.
Charles Schwab also offers other services intended to help the Firm manage and further develop
the Firm’s business enterprise. These services include:
educational conferences and events;
technology and business consulting;
consulting on legal and related compliance needs;
publications and conferences on practice management and business succession; and
access to employee benefits providers, human capital consultants, and insurance providers.
Charles Schwab provides some of these services itself. In other cases, it will arrange for third-party
vendors to provide the services to the Firm. Charles Schwab also discounts or waives its fees for
some of these services or pays all or a part of a third party’s fees. Charles Schwab also provides
the Firm with other benefits such as occasional business entertainment of the Firm’s personnel. If
the client did not maintain their account with Schwab, the Firm would be required to pay for these
services from the Firm’s own resources.
The Firm’s use of any of these services is at the sole discretion of the Firm and is based on the
Firm’s assessment of potential assistance in managing and administering the Firm clients’ accounts
and operating the Firm.
The availability of services from Charles Schwab benefits the Firm because the Firm does not have
to produce or purchase them. The Firm doesn’t have to pay for these services, and they are not
contingent upon the Firm committing any specific amount of business to Charles Schwab in
trading commissions or assets in custody. The fact that the Firm receives these benefits from
Schwab is an incentive for the Firm to recommend the use of Schwab rather than making such a
decision based exclusively on the client’s interest in receiving the best value in custody services
and the most favorable execution of transactions. This is a conflict of interest. The Firm believes,
however, that taken in the aggregate the Firm’s recommendation of Charles Schwab as custodian
and broker is in the best interests of the Firm’s clients. It is primarily supported by the scope,
quality, and price of Charles Schwab’s services and not Schwab’s services that benefit only the
Firm.
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The Firm receives an economic benefit from Schwab in the form of the support products and
services it makes available to the Firm. The client does not pay more for assets maintained at
Schwab as a result of these arrangements. However, the Firm benefits from the arrangements
because the cost of these services would otherwise be borne directly by the Firm. The client should
consider these conflicts of interest when selecting a custodian. The products and services provided
by Schwab, how they benefit the Firm, and the related conflicts of interest are described above
under Brokerage Practices. The availability to the Firm of Schwab’s products and services is not
based on the Firm giving particular investment advice, such as buying particular securities for the
Firm’s clients.
Review of Accounts
The Firm monitors client portfolios as part of an ongoing process, including ongoing review of the
securities held for developments that might affect them. The size of the Firm allows
Mr. Schlindwein to personally supervise all accounts and monitor the securities held.
All accounts have their assets in the custody of institutions that provide regular, at least quarterly,
reports on all transactions and portfolio valuations. The Firm regularly reports to clients orally
and in writing about investment activity in their accounts, and provides quarterly or more frequent
valuations of portfolios to clients, which list each portfolio security and include current market
value.
Client Referrals and Other Compensation
The Firm has no agreements providing cash compensation to persons who refer clients to the Firm
Custody
The Firm is deemed to have custody of client assets for purposes of the Investment Advisers Act
of 1940 when it bills the client’s custodian who deducts the Firm’s advisory fee from client
accounts. Clients will receive at least quarterly account statements from the client’s custodian.
The Firm urges clients to carefully review those statements and to compare those statements to
those the client receives from the Firm.
Investment Discretion
The Firm accepts discretionary authority to manage investments on behalf of clients pursuant to
an investment advisory agreement in which the client appoints the Firm as its agent and attorney-
in-fact with full investment power and authority on behalf of the client’s account. Clients may
place limitations on this authority, including restricting or prohibiting purchases of certain types
of securities.
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Voting Client Securities
The Firm does not have authority to vote client securities. Clients receive their proxies directly
from their custodian. Clients may contact the Firm with questions about a particular solicitation;
however, the Firm will not advise clients regarding how they should vote.
Financial Information
The Firm does not believe there is any financial condition that is reasonably likely to impair its
ability to meet contractual commitments to clients.
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