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Firm Brochure
(Part 2A of Form ADV)
March 28th, 2025
Headquarters
661 University Blvd
Suite 100
Jupiter, FL 33458
Tel: 561-244-2504
Fax: 561-584-6945
Branch Offices
525 Junction Rd.
South Tower, Suite 6500
Madison, WI 53717
Tel: 608-616-4350
Fax: 608-268-8683
10364 W State Rd 84
The 595 Executive Suites
Davie, FL 33324
Tel: 954-606-0777
Fax: 608-268-8673
By appointment only
Regus Suites
2255 Glades Road, 3rd Fl
Boca Raton, FL 33431
www.SlateStone.com
This brochure provides information about the qualifications and business practices of
SlateStone Wealth, LLC. If you have any questions about the contents of this brochure,
please contact Gianna Moretto at gmoretto@slatestone.com or 561-931-0206. The Co-CEO and
Chief Compliance Officer is Sharon Daniels, Founder, the information in this brochure has not
been approved or verified by the United States Securities and Exchange Commission (SEC) or by
any state securities authority. Additional information about SlateStone is also available on
the SEC’s website, www.adviserinfo.sec.gov. The CRD number for SlateStone is
#286669. You will be able to view Parts 1 and 2 of our Form ADV and Form CRS.
Item 1 - Cover Page
SlateStone Wealth, LLC (SlateStone or SSW) is a registered investment adviser with the United
States Securities & Exchange Commission (SEC). References within this Brochure to SlateStone
Wealth, LLC as a “registered investment adviser” or any reference to “registered” does not imply
a certain level of skill or training. Likewise, the information in this brochure has not been
approved or verified by the SEC or by any state securities authority.
Item 2 - Material Changes
As part of our regulatory obligations, we annually update our brochure within 90 days after the
fiscal year-end. The revised information is made available on adviserinfo.sec.gov and is also
distributed to our clients within 120 days of our fiscal year-end. We will also provide updated
disclosure information about material changes on a more frequent basis. Any summary of
changes will include the date of the last update of our brochure. For a copy of our complete
brochure, please contact us at info@slatestone.com or visit our website www.slatestone.com.
Since our last brochure, dated October 2nd, 2024, we have made the following changes to this
brochure, dated March 28th, 2025:
Item 4 Advisory
Clarified the participation of the equity partners.
Included alternative assets as part of the assets we recommend, as well as provided
additional information and information on additional fees.
Defined Accredited Investor and Qualified Purchaser.
Item 5 Fees and Compensation
Added Alternative Private Investment Fees
Fees for clients referred via the Schwab Referral program are the same as other accounts.
Fees start at 1.25 and scale down.
Item 6 Performance-Based Fees and Side-by-Side Management
Added performance-based fees charged by Alternative Private funds that Adviser
recommends
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Clarified Interest Rate risk on Cash and defined Liquid Assets and Cash Equivalents
Modified the types of Strategies
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Item 14 Client Referrals and Other Compensation
Clarified referrals to SlateStone by clients.
Item 17 Voting Client Securities
Clarified that clients will provide instructions to receive proxy materials directly from the
issuer.
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Item 3 - Table of Contents
Item 1 - Cover Page ............................................................................................................................. 2
Item 2 - Material Changes .................................................................................................................. 2
Item 4 - Advisory Business ................................................................................................................. 5
Item 5 - Fees and Compensation ...................................................................................................... 14
Item 6 - Performance-Based Fees and Side by Side Management .................................................... 18
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ........................................... 18
Item 9 - Disciplinary Information ................................................................................................... 28
Item 10 - Other Financial Industry Activities and Affiliations ........................................................ 28
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..... 29
Item 12 - Brokerage Practices .......................................................................................................... 30
Item 13 - Review of Accounts ........................................................................................................... 34
Item 14 - Client Referrals and Other Compensation ........................................................................ 35
Item 15 - Custody ............................................................................................................................. 37
Item 16 - Investment Discretion .......................................................................................................38
Item 17 - Voting Client Securities ..................................................................................................... 39
Item 18 - Financial Information ....................................................................................................... 39
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Item 4 - Advisory Business
Description of Firm
SlateStone is a Florida limited liability company formed in 2017. SlateStone’s members include
SlateStone Holdings, LLC, a Florida limited liability company whose majority owners are
Patrick E. Tylander and Sharon A. Daniels, the Founders and Co-CEO’s of SlateStone, and
Temperance Wealth Partners LP (“Temperance”). Temperance is a private investment firm
backed by Family Office Capital that invests in privately held financial services businesses such
as SlateStone. Temperance is a strategic partner of SlateStone while Mr. Tylander and Ms.
Daniels, SlateStone’s Co-CEO’s, manage SlateStone’s operations.
Our corporate headquarters are in Jupiter, Florida and regional offices are in Boca Raton, FL,
Davie, FL. Weston, FL and Madison, WI. For additional information on ownership please see
form ADV Part 1 at www.investor.gov.
As an independent registered investment adviser, SlateStone offers personalized investment
management services and comprehensive wealth and financial planning to high-net-worth
individuals, families, trusts, estates, corporations, and other business entities.
SlateStone serves as a fiduciary investment advisor to its clients. In fulfilling its fiduciary duty,
SlateStone maintains policies and procedures, including a Code of Ethics designed to mitigate
potential conflicts of interest. We uphold the following principles and practices in serving our
clients’ best interests:
• We place clients’ interests ahead of our own
• We provide investment and financial advice and strive to control investment expenses
• We are independent from any bank, broker-dealer, insurance company or custodian
• We work with national custodians and do not hold client assets, securities, or cash
• We provide full transparency to your portfolio and investments
• We use third parties to value your securities and report on your portfolio results
• We act prudently – with the care, skill, and judgment of a professional to avoid conflicts
of interest
• We disclose all material facts
Our wealth advisory team is supported by investment industry veterans with decades of
investment management experience upholding a fiduciary standard and providing transparency
into the wealth management process. We cater to clients seeking high-touch services across a
spectrum of financial needs that may be encountered over generations. SlateStone offers a
comprehensive suite of specialized services delivered through a defined and robust discovery
approach with each client. When working with SlateStone, you can expect personal service and a
long-term commitment. Our mission is to create deeply rooted relationships and to deliver
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superior long-term results by integrating your financial plan with a disciplined investment
process that instills a greater sense of confidence that goals are achievable.
Assets Under Management
As of December 31, 2024, the Firm had approximately $1.63 Billion in discretionary and $17.2
Million in nondiscretionary assets under management
Assets Under Advisement
As of December 31, 2024. The firm had approximately $71.2 Million in Assets under Advisement.
Principal Partners
Sharon “Sherri” A. Daniels and Patrick E. Tylander are Founders and Co-CEOs. You can view
their bios by visiting our website www.SlateStone.com. Temperance Wealth Partners, a private
investment firm focused on the financial services sector is an investor in SlateStone, but does not
participate in the day-to-day management and operations of the Firm. More details regarding the
ownership and partners of SlateStone Wealth can be found on the Form ADV Part 1, Direct
Ownership and Indirect Ownership.
Mutual Engagement with Clients
At SlateStone, every client receives personalized service designed with a long-term
perspective that integrates standard financial planning elements with a disciplined and robust
investment offering and process. Our purpose is to help clients gain a sense of comfort and
confidence that their financial objectives are achievable. In upholding a fiduciary standard, we
place our client’s interests first and these standards guide us as we deliver independent advice
and an authentic experience to our clients.
General Description of Advisory Services
SlateStone is a multi-asset class investment advisory and wealth management firm. We provide
strategic wealth management and comprehensive financial planning services on a discretionary
fee basis and offer consulting services on a pre-approved, non-discretionary fee basis.
We strive to be our client’s trusted advisor and advocate within a fiduciary standard of care that
provides unbiased, independent advice designed to meet each client’s personal objectives.
Whether the goal is building a successful retirement, accumulating and growing assets, or
building a family legacy, we will be there for you each step of the way.
We serve private clients and families seeking a holistic view of wealth across both the high net
worth and ultra-high net worth investor categories. Our services are tailored to meet specific
and varied objectives including complex and sophisticated requirements with access to public
and private investment solutions.
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We provide wealth management services to wealthy clients including: Entrepreneurs &
Founders, Business Owners & Professionals, Multi-generational families, and Foundations &
Endowments
Wealth Management & Investment Advisory Services
SlateStone offers a comprehensive set of wealth advisory services and dedicated resources
designed to respond to the unique needs of our clients. We seek a deep understanding of our
client’s unique life vision and current financial situation before creating a tailored wealth and
investment plan to serve as a roadmap for the future. Understanding a client’s life values and
financial goals aids in our ability to successfully govern the relationship and provide a guideline
for the ongoing management of our client’s wealth plan. Whether the relationship is broad and
deep (including comprehensive life management and financial planning combined with
investment management and other services), or focused solely on strategic investment
management services, our advice is designed to simplify our clients’ lives and give definition to
the mutually established investment objectives we seek to deliver. By taking into consideration
time horizons, tax considerations, liquidity, and any other unique circumstances that could
impact the management of a client’s financial plan and investment portfolio, we are equipped to
address a lifetime of changing needs. Throughout the relationship, our advisors and investment
team members use their skills to educate, communicate, and collaborate on financial and non-
financial issues providing recommendations on investment options to be considered.
Interactive management, monitoring, rebalancing of the client portfolio strategy and detailed
reporting is part and parcel of our guidance.
SlateStone’s Investment Policy Committee identifies the big-picture global economic themes
and specific investment vehicles it believes offer the best investment opportunities for its clients,
assessing the geo-political landscape, direction of interest rates, prospects for inflation/
deflation, among many other factors, with the goal of identifying opportune investment themes
and vehicles.
Based on our economic and market outlook, our research team performs in-depth research and
analysis of individual equities, mutual funds, external managers, and non-traditional
investments such as public and private alternatives which for qualified clients may include
direct investments in segments such as private equity, real estate, hard asset lending, hedge
funds, and venture capital. Our goal is to identify investments we believe will produce the
greatest return, within certain risk parameters, to meet our clients’ varied objectives.
SlateStone serves primarily high net worth and ultra-high net worth individuals, families as well
as entities and foundations who have in excess of $1 million in investable assets, however
different service levels may require higher minimums . Most of SlateStone’s clients receive
discretionary investment advisory services. Discretionary means you provide us written
authorization to make investment decisions and securities transactions on your behalf and in
accordance with stated objectives. We make all decisions to buy, sell or hold securities or other
investments, including cash, in your account and allocate assets in a manner deemed
appropriate to meet your financial objectives. SlateStone primarily invests on behalf of its
clients in securities that are publicly traded. We may also recommend Alternative Private
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Investments as we determine are suitable and appropriate to qualified clients and depending on
clients’ specific objectives, risk profile, time horizon and preferences. We supervise client
portfolios proactively and will execute transactions to buy and sell positions or rebalance
holdings when we believe it is appropriate to help achieve objectives and/or to limit risk.
Private Client Services is designed for individuals and families with investment portfolios
typically exceeding $5 million, have significant annual income, and net worth, and who require
complex guidance and reporting, coordination with other financial professionals, and who
qualify for access and introduction to direct private investments.
We provide in-depth guidance covering a comprehensive set of needs, from creating a full
financial and investment plan to the coordination of all investments and risk management;
managing and leveraging debt through appropriate lending solutions; defining estate goals and
coordinating with key legal advisors; consolidated reporting and administration of all assets
whether managed by SlateStone or others.
The Private Client Services encompasses the following as requested:
•
Investment Management, asset allocation and security selection including sourcing,
vetting, and monitoring direct investment opportunities
• Consolidated reporting, including periodic global asset allocation summary, real estate,
and income summary
• Review of insurance coverages, including homeowner’s, auto, life and disability
• Business opportunities and other services, utilizing SlateStone’s extensive connections to
expedite the introduction and connection process between client, potential business
partners and service providers
• Coordinates with client’s other professional including legal counsel, accountant, etc on
•
financial matters, tax planning, asset location, etc. to meet overall objectives
Introduces and provides guidance on private investment opportunities for accredited
investors and/or qualified purchasers in the areas of real estate, private equity, venture
capital, and hedge funds
Family Office Services is designed to consolidate many of the financial and non-financial
services for ultra-high net worth families with the complexities of multi-generational wealth.
The service is an expansion of the firm’s Private Client offering and is designed for families of
significant net worth typically over $30 million and investable net worth above $10 million.
Family governance and dynamics
Lifestyle management
Record keeping and reporting
Bill pay (services outsourced)
Investment strategy & asset management Philanthropy
Risk management
Tax guidance/planning (not prep)
Estate planning
Liquidity/cash flow management
Liability/debt management
Customized Investment Management Service is designed for those clients who typically have
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$5 million or more in investable assets and/or who have special situations or investment
restrictions that require highly specialized solutions. Custom portfolios are individually tailored
and address sophisticated investment requirements such as situations that involve special tax
considerations, concentrated or low-basis stock positions, inheritance issues or closely held
businesses. SlateStone’s investment professionals determine through an in-depth review with
the client an appropriate plan of action to meet the client’s unique circumstances. Our
customized portfolio solutions provide review and analysis of existing holdings, risk
management reduction, asset allocation and portfolio construction with regular rebalancing.
Within these portfolios, we typically invest in individual equity and fixed income securities, and,
where suitable, options strategies and alternative investments that could include exposure to
private placements, hedge funds, private equity, and real estate.
SlateStone may utilize internally managed asset allocation strategies alongside, or in
combination with, individual equities and bonds to create a blended and diversified portfolio to
achieve overall investment goals based upon suitability. These services include a comprehensive
review of existing assets to ensure a streamlined and tax efficient transition of the client’s assets
and/or securities to meet an appropriate portfolio aligned to individual investment objectives.
Our Strategic Asset Allocation Portfolio Service is a comprehensive investment management
solution designed primarily for investors with investable assets up to $3 million and includes
investment portfolio design and implementation, tax efficient management and reporting plus
ongoing and continuous oversight of client accounts. When advising on and constructing client
portfolios, the firm will typically utilize equity and bond related ETFs and mutual funds to build
a diversified portfolio. Within this framework, and if appropriate, we will utilize a mutual fund
or ETF asset allocation strategy, model portfolios, or the use of an external third-party manager.
Depending on the client’s objectives, the firm allocates primarily for results over time, however,
we will also employ short term tactical moves to protect from downside market conditions when
deemed appropriate. Tactical moves may include the use of specialized funds or ETFs over the
shorter term or increasing cash levels as deemed appropriate based on the specific client risk
tolerance and short- and long-term objectives.
Financial Planning and Consulting Services
Financial planning services are provided as a component of wealth management and investment
advisory services but may be offered as a stand-alone service under a separate engagement with
the client. Financial planning services include guidance on both investment and non-investment
related matters based on a client’s financial situation and specific goals and objectives. The
service can be focused or broad and may include but not be limited to:
Budgeting and expense Planning
Cash flow analysis & Planning
Retirement Planning
Trust & Estate Planning
Charitable Giving
Tax Planning
Wealth Transfer
Education Planning
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The process of financial planning begins with an in-depth client consultation and requires
specific information about the client’s income, assets, net worth, debts, objectives, and goals at
different life stages among other factors and are necessary to provide planning advice and
recommendations. A formal financial plan or specific advice will be rendered to the client based
upon the information provided and specific actions may be offered to meet the plan dynamics.
As part of our comprehensive wealth planning service, the financial plan will be integrated with
the investment plan. Should a client choose only financial planning services under a separate
agreement, it will be the client’s decision and responsibility to take action on any
recommendations provided as a result of the planning service.
Within the scope of financial planning and consulting services, SlateStone does not serve as an
attorney or accountant, does not prepare estate planning documents or tax returns, and its
services should not be construed as legal or tax advice. Where appropriate, we will recommend
outside professionals for non-investment-related services (accountants, attorneys, insurance
agents). The client is never under any obligation to engage with a recommended professional.
Whereby a client uses the services of a recommended professional, and a dispute arises
thereafter, relative to that engagement, the client agrees to seek recourse exclusively from and
against the engaged professional.
Whenever SlateStone makes a recommendation for the Financial Planning client to utilize the
services of a third-party as mentioned above, SlateStone shall:
• Have a reasonable basis for the recommendation or engagement based on the person’s
reputation, experience, and qualifications.
• Disclose to the client, at the time of the recommendation or prior to the engagement, any
arrangement by which someone who is not the client will compensate or provide other
material economic benefit to the firm, or a related party for the recommendation or
engagement.
• When engaging a person to provide services for a client, exercise reasonable care to
protect the client’s interests.
• Disclose additional fees to be charged to the Financial Planning client by the third-
party service provider.
When selecting or using and recommending technology, SlateStone shall document the due-
diligence process which will include:
• Exercising reasonable care and judgment when selecting, using, or recommending any
software, digital advice tool, or other technology while providing professional services to a
client.
• Having a reasonable level of understanding of the assumptions and outcomes of the
technology employed.
• Having a reasonable basis for believing that the technology produces reliable,
objective, and appropriate outcomes.
Financial planning and consulting recommendations may pose a conflict between the interests
of the advisor and the client. As an advisor may be incented to recommend that client engage the
advisor for investment management services or increase the amount of assets being managed
which could increase the amount of advisory fees paid for the services. Furthermore, it would be
a conflict of interest if we were to suggest investing funds over loan repayments to enhance your
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assets under management with us, thus increasing the advisory fee. Our priority is to provide
advice that best serves the client's interests, ensuring transparency and alignment with their
goals. A client is not obligated to implement any recommendations or take any specific action
advised or maintain a relationship.
Account Aggregation Reporting
To assist with our planning and consulting services, SlateStone offers aggregation of outside
assets/accounts held by a client and will provide periodic comprehensive reporting services
which incorporate all of the client’s investment assets, including those investment assets that are
not part of the assets being managed by SlateStone. SlateStone’s service, related to outside
assets, is limited to reporting only and does not include discretionary investment management
of the outside assets. SlateStone does not have trading authority over the outside assets and as
such the client is exclusively responsible for directing and implementing any recommendations
SlateStone may provide in the course of our financial planning or investment management
relationship related to outside assets. Furthermore, SlateStone shall not be responsible for any
implementation error (trading, etc.) that may occur related to any outside assets. In the event
the client desires that SlateStone provide investment management services on any of the outside
assets, the client will do so under the terms and conditions of SlateStone’s Investment
Management /Consulting Services Agreement.
Separately Managed Accounts or Subadvisors
In certain circumstances, and to meet overall client investment objectives, our internally
managed solutions could be augmented with an investment strategy from an external manager,
or a Sub-Adviser, skilled in specialized management strategies (options, alternatives, real
estate, structured notes, etc.).
SlateStone reviews a client’s time horizon, objectives, tax situation, income and liquidity needs
and recommends a portfolio asset allocation mix based on this criteria. In recommending
independent managers, SlateStone will consider factors such as the manager’s designated
investment objective, management style, performance, reputation, financial strength,
reporting, and pricing. When utilizing an independent manager, SlateStone will continue to
provide investment advisory services to the client on a discretionary basis and relative to
ongoing monitoring and review of account performance, overall portfolio asset allocation, and
client investment objectives. In such circumstances, the independent manager shall be granted
discretionary trading authority and have day-to-day responsibility for the active management of
the allocated assets.
Prior to providing investment management services with external managers, the client will enter
into a separate investment management agreement with SlateStone and with each Investment
Manager recommended by SlateStone (this is a “dual contract arrangement”). The investment
manager is contracted by the client, on the recommendation of SlateStone in accordance with
the client’s objectives, subject to any agreed upon restrictions.
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SlateStone receives no direct financial compensation from the investment managers it
recommends. Investment managers may host educational seminars for the firm’s clients.
Cash/Liquid Positions
In the course of managing investments for clients, SlateStone may choose to take a defensive
position and increase cash positions based upon perceived or anticipated negative market
conditions. All cash positions (money markets etc.) are included as part of assets under
management for purposes of calculating the firm’s advisory fee.
Alternative Private Investments
When appropriate, and in accordance with the clients’ financial experience, objectives, income
and net worth, SlateStone may recommend the use of one or more alternative private
investments, which may be interests in limited partnerships, funds, or other entities. Clients for
whom such services are suitable must meet the definition of “accredited investors” as defined in
the Securities Act.
SlateStone will provide advice on private alternative investments such as real estate-related
investments (e.g., mortgages, direct investments in real estate, and investments in real estate
funds) as well as private equity, hedge funds, and hard-asset lending funds, etc. Services
included within the scope of such advice include sourcing, strategic research, due diligence,
investment monitoring, and reporting.
Clients that invest in Private Alternative Investments will receive additional information on
such investments, including a private placement memorandum and fee disclosures. Private
Alternative Investments may be held away from clients’ custodians and the managers of such
investments may charge performance fees as well as flat, or AUM fees, which fees are typically
charged directly by the Private Alternative Investment manager, either by debiting the
investment account or sending an invoice. Such fees for Private Alternative Investment
services are not charged or received by SlateStone.
SlateStone coordinates when appropriate with outside consultants or alternatives platforms for
additional support in sourcing investments, providing specialized guidance, and assistance with
due diligence and research.
In some cases, the offerors or control persons of Private Alternative Investments (or their
affiliated funds or other entities) we recommend and invest in, may be clients of SlateStone.
SlateStone receives no compensation for recommending these private investments and gains no
advantage by utilizing their products. All Private Alternative Investments that may be
recommended to our clients will undergo our due diligence process as described in this
Brochure.
Qualifications for Private Alternative Asset Investors
When recommending a Private Alternative Asset that is available only to investors who meet
specific regulatory qualifications, SlateStone will require that the client confirm eligibility by
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signing the appropriate attestation form. Depending on the offering, an investment may require that
investors be either accredited investors or qualified purchasers.
• Accredited Investor:
An individual qualifies as an accredited investor under Regulation D, Rule 501 of the
Securities Act of 1933 if they meet at least one of the following criteria:
• Earned income exceeding $200,000 (or $300,000 when combined with a spouse
or spousal equivalent) in each of the two most recent years, with a reasonable
expectation of maintaining that income in the current year, OR
• A net worth exceeding $1,000,000, either individually or jointly with a spouse or
spousal equivalent, excluding the value of the primary residence, OR
• Possession of certain professional certifications in good standing (e.g., FINRA
Series 7, Series 65, or Series 82), OR
• Status as a knowledgeable employee of a Private Fund.
• Qualified Purchaser:
• An individual (or entity) qualifies as a qualified purchaser under the SEC’s
December 2001 final rule if, as a natural person, they own at least $5,000,000 in
investments (excluding non-investment assets such as the primary residence), or, in
the case of an entity, if the entity owns at least $5,000,000 in investments and was
not formed solely for the purpose of acquiring the offered securities.
When recommending a Private Alternative Asset, SlateStone will determine whether the offering
requires that investors meet specific regulatory qualifications. Some investments are limited to
those who qualify as either accredited investors or qualified purchasers, while others impose no
such restrictions.
Discretionary and Non-Discretionary Investment Services for Retirement
Accounts (Held Away)
SlateStone provides non-discretionary advice for accounts where it is not possible for the firm
to transact trades through the standard custodial arrangements and will provide
Discretionary Investment Services for such accounts where SlateStone is authorized to
transact in those Accounts by the Client. These services include investment advice on
company retirement accounts, 529 plans, and variable annuities. Such advice will be limited
to the investment alternatives provided under the governing documents of such Retirement
Accounts.
SlateStone will periodically discuss holdings in accounts and the overall investment objectives
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with clients who have these types of accounts to suggest adjustments to holdings, monitor the
investments and provide statements and performance reporting (where given access) on an
ongoing basis.
Retirement Rollover
If we recommend that you rollover your retirement plan, such as a 401(k) into an account we
manage there is an inherent conflict of interest as we will be paid a fee. You are never under any
obligation to rollover retirement plan assets to an account managed by us.
When considering rolling over a 401(k) to an IRA your options generally include:
• Leave in the 401(k) plan if permitted
• Rollover to a new employer’s plan if permitted
• Cash out the account value – depending on age may have adverse tax concerns.
A few of the benefits of rolling over the 401(k) to an account we manage for you may include:
• Increased asset selection
• Alignment with your financial objectives
• Enhanced services
• Access to discretionary asset management
• A reduction of fee rates based on larger assets under management.
When we provide 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. 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 and not put our interest
ahead of yours. 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; and
• Give you basic information about conflicts of interest.
Item 5 - Fees and Compensation
The specific fees charged to clients will be disclosed in the client’s Investment Management or
Consulting Agreement when the relationship is established. SlateStone’s fees are assessed in the
following ways:
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For Private Client and Family Office Services, we charge a fee based on assets under
management, both discretionary and non-discretionary, and services being provided. Typically,
fees range from $24,000 to $150,000 annually and are negotiable.
For Investment Advisory Services, either Customized Investment Management Services or
Strategic Asset Allocation Portfolio Management Services, we charge new clients, a tiered
percentage-based fee calculated on the total market value of the assets in the portfolio at the
end of each quarter, beginning at 1.00% on the first $2 Million, 0.85% on the next $3 Million,
0.70% on the next $5 Million and negotiable above $10 Million. Our minimum annual fee is
$10,000.
We may accept relationships below our investment minimum; however, fees start at 1.25% and
scale down based on the level of assets under management. Our fees and minimums can be
reduced or waived at SlateStone’s discretion.
For standalone Financial Planning/ Wealth Planning, we charge a flat fee depending on the
scope of the services required. Planning fees start at a minimum $5,000.
Investment Advisory Fees - Automatic Fee Deduction/Billing
The client shall authorize the deduction of investment advisory fee directly from their custodial
account, which shall be directly remitted to SlateStone in compliance with regulatory
procedures. In those situations where SlateStone cannot debit the account directly, the client is
invoiced, and payment is due upon receipt of the invoice.
The annual management fee is prorated and paid quarterly in advance and is based on the total
market value of the assets in the account on the last business day of the previous quarter. In
calculating total market value, we take into consideration all cash and accrued interest. We are
currently using security prices as priced by Charles Schwab or from our client’s custodians. If a
custodian is unable to give us a price, we will go to ICE Data Services (ICE). Prior to 2024, we
utilized ICE , a global leading provider of pricing services, to price client’s holdings, which was
then used for the calculation of our investment management fees.
At the end of each quarter, we conduct a thorough comparison of client account values with
their corresponding custodian/broker statement. It is important to note that discrepancies
between the values derived from our internal systems and those reflected on the account
statement can arise due to several factors, such as: pricing sources utilized, recording
transactions on settlement date value verses trade date value, and the value of pending accrued
interest, as we do consider accrued interest as part of your account value. Typically, if the value
creates a cost difference to the client of less than $10.00 during the calendar quarter, we will
accept the market value as priced. Otherwise, we will investigate and make any necessary
corrections prior to billing.
Account statements provided by the custodian will show all transactions and positions in the
account, including the amount deducted for our fees. It is the responsibility of the client, not the
custodian, to verify that the advisory fee is applied to client’s account correctly.
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In certain relationships, the fees differ from those described herein, typically for those clients
who joined SlateStone as part of a corporate merger or acquisition. We typically maintain the
pre-existing wealth management fee structure. In its sole discretion, SlateStone may charge a
lower investment management fee based upon certain criteria (anticipated future additional
assets, dollar amount of assets to be managed, related client relationship, composition of assets
to be managed, future earning capacity of client, etc.).
Unless otherwise stated, SlateStone’s investment management fees do not cover or include
brokerage commissions, transaction costs, custody fees or other related expenses (see
Additional Fees and Expenses below).
Private investments are direct investments and are not publicly traded and therefore do not
have a daily indication of their fair market value. It is our policy to use the most recent value
provided by either the qualified custodian or issuer, or the private fund operator for reporting
and billing purposes. In some cases where no updated valuations are provided, we will use the
investment cost as the valuation until an updated valuation is received.
SlateStone does not accept compensation from the sales of securities, nor share in commissions
or transaction costs.
Under no circumstances does the firm require or solicit payment of fess in excess of $1,200,
more than six months in advance of services.
Cancellation Process, Accrued Fees & Refunds
A client can terminate an account or the entire relationship at any time upon notification to
SlateStone. You shall have five (5) business days from the date of execution of the Investment
Management Agreement to terminate services for a full refund.
SlateStone requires a written notice of termination of any of its services. Upon such notice,
SlateStone will cease making investment decisions under the Investment Management
Agreement and/or providing financial advice incidental to the Financial Planning and
Consulting Agreement and will implement any reasonable written instructions that are
provided. The investment account(s) can be closed, and funds withdrawn, only after any open
trades have been settled. Upon termination of an investment account, SlateStone will refund any
pre-paid management fees, pro-rated to the date of termination. The client refund amount will
be either credited to the account or paid by check to the account holder.
A one-time fee of $1,000 to cover account set-up expenses and advisory services will apply to a
household if the client terminates within 180 days.
Clients in Private Client, Family Office or Consulting Services terminating their account prior to
twelve months from inception, will have a minimum fee imposed of $10,000 to cover the costs
of services. This fee can be deducted from any reimbursement owed to the client for pre-paid
fees.
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Additional Fees and Expenses
Mutual Fund and ETF Management Fees. Accounts invested in mutual funds and
exchange-traded funds generally also pay, indirectly, investment advisory fees to the
managers of those funds. As such, client accounts with investments in those types of
securities will be subject to two layers of management fees. An explanation of the fees
and expenses paid by each mutual fund is contained in that mutual fund’s prospectus.
Mutual Fund transaction fees. Depending on the custodian, some purchases and sales of mutual
funds will have no transaction fees. However, not all mutual funds are without fees. Some funds
have early redemption fees. An explanation of fees and expenses charged by each mutual fund is
contained in that fund’s prospectus.
Brokerage Fees. SlateStone’s management fee does not include brokerage commissions,
transaction fees, exchange fees, SEC fees and other related trading costs and expenses. These
fees are paid for directly by the client and SlateStone does not receive any portion of these types
of fees.
External Account Manager Fees. If SlateStone engages an external independent investment
manager to manage a portion of the client’s assets, the client will be responsible for paying all
fees charged by the external account manager on those assets in addition to SlateStone’s
Investment Advisory fees. SlateStone will obtain written consent from the client for outside
manager fees and additional documents will be required.
Sub Advisory Fees. Fee schedules for clients utilizing Sub-Advisers or dual contract programs
will be separately negotiated with the relevant client or intermediary. The sub-adviser
generally charges clients quarterly in advance a comprehensive fee, based upon the percentage
of the value of the client’s assets under management in the program.
Alternative Private Investment Fees. Fee schedules for Alternative Private Investments will be
included with the documents provided by the third-party manager. Fees related to Alternative
Private Investments will not be billed or earned by the Firm and all such fees will be charged by
and paid to the applicable third-party manager. Alternative Private Investment fees may
include performance fees in addition to, or in lieu of asset-based fees and are disclosed in the
Private Fund Operating Memorandum and Subscription documents.
Donor Advised Fund Fees. When a client’s assets are allocated toward a donor advised
fund, the client will be responsible for paying all fees charged by the fund on those assets in
addition to SlateStone’s advisory fees. The fund will impose and arrange for the automatic
deduction of its own fees from the account of the client.
The following represents additional fees and expenses that could be directly billed or
assumed proportionately by you and third parties:
Custodial fees, transfer taxes, odd-lot differentials, margin interest, deferred sales
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charges (on mutual funds or annuities), wire transfer and electronic fund processing
fees, advisory fees and administrative fees charged by mutual funds and exchange traded
funds (ETFs).
The fees listed above are charged by and paid to a broker-dealer, custodian, mutual fund
company, or annuity issuer, as applicable. We do not directly or indirectly share or receive any
portion of these fees.
Item 6 - Performance-Based Fees and Side by Side
Management
We do not currently offer or manage accounts that pay performance-based compensation and
therefore, we have no side-by-side management. However, clients may invest in Alternative Private
Investments, managed by a third party who may charge performance-based fees. Clients that invest
in Alternative Private Investments will receive private placement memoranda and such other
documents that would disclose the nature and amount of the applicable fees. Item 7 - Types of
Clients
SlateStone provides services to high net worth Individuals, Entrepreneurs & Founders, Business
Owners & Professionals, Multi-generational families, and Foundations & Endowments.
SlateStone typically prefers clients establish a relationship with a minimum of $1,000,000 or
more to invest. SlateStone reserves the right to waive minimums at its sole discretion.
Employee benefit plans which select SlateStone to provide investment advisory services should
be aware that the Employee Retirement Income Security Act of 1974 (ERISA) sets forth rules
under which Plan Fiduciaries may retain investment advisers for various types of services with
respect to Plan assets. For certain clients, SlateStone will be providing non-discretionary
investment advice to the Plan Fiduciaries by recommending a suite of investments choices
which Plan Participants may select. Also, to the extent that the Plan Fiduciaries retain
SlateStone to act as an investment manager within the meaning of ERISA § (38), SlateStone will
provide discretionary investment management services to the Plan.
Item 8 - Methods of Analysis, Investment Strategies
and Risk of Loss
Methods of Analysis
SlateStone’s research department makes available to its professional advisory team certain
information which includes recommendations on equities, fixed income securities, mutual
funds, ETFs, alternatives, and the use of external independent managers. SlateStone’s
investment research is used by its wealth management professionals to tailor recommendations
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and design an investment portfolio to a client’s specific needs, circumstances, and objectives.
The firm’s research department uses fundamental, quantitative, technical, and cyclical analysis
in evaluating securities. Fundamental analysis involves looking at economic, financial, and other
qualitative and quantitative factors in an effort to measure a security’s value.
We use various financial databases and tools such as Barron’s, Bloomberg Professional, CAIS,
Financial Times, JP Morgan’s research, MSCI.com, Morningstar, Refinitiv, Standard &
Poors.com, the Wall Street Journal and Thompson Reuters. We also use other commercially
available technology, including research provided by custodians, financial periodicals and other
publications, SEC filings, and financial statements to assist with our analysis. The staff will also
interview fund managers, wholesalers, general partners, and staff of private investment funds,
participate in conference calls, earnings calls, and attend industry conferences. In certain
instances, we may use outside research to provide expertise in specific investment areas or for
more in-depth analysis.
Equities. SlateStone employs a top-down approach in managing client’s investment
portfolios. We begin with a detailed study of the macro-economic environment reviewing and
analyzing business trends and the economic cycles both domestically and abroad. We look at
the direction of interest rates, the influence of political policies and the general strength in
business and industries. Based on the results of our study, we determine where to focus our
efforts in finding global investment ideas. We then determine equity industry sectors in which
to concentrate and the sub-industries that we believe will benefit from our expectations of
economic growth.
SlateStone’s methods for identifying new investment ideas focuses on a four-tier approach.
1. We begin by identifying investment ideas by running a quantitative screening of
individual companies, screening for earnings growth rates, revenue growth rates,
valuations, and debt levels.
2. We then use technical analysis to review trading charts, compare the current price action
to moving averages and trend lines and review relative strength and money flow
indicators.
3. Stocks that pass our review are then compared using the same analysis to their closest
competitors in our peer to peer analysis.
4. Stocks that pass our valuation analysis will be reviewed using fundamental analysis
which involves looking at competitive advantages, the uniqueness of a company’s
products or services, barriers to entry, sustainable growth, and potential threats.
Mutual Funds and ETFs. SlateStone evaluates, selects, and monitors mutual funds and ETFs
across multiple asset classes and investment styles. SlateStone’s investment selection process for
mutual funds begins by screening potential funds using various industry sources. The firm uses
specific criteria to determine the overall investment merit of a specific fund focusing on the
fund’s historical performance in both bull and bear markets, current performance, fund purpose
and sector, price volatility, standard deviation, the fund’s returns over a specific period of time,
and overall management stability and integrity.
SlateStone’s investment process for exchange traded funds (ETFs) is based upon a quantitative
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methodology to choose ETFs that represent specific industry sectors, baskets of regional and
international stocks, fixed-income instruments, and commodities. By analyzing ETF data, our
portfolio managers seek to identify ETFs that appear to be under accumulation by investors,
particularly institutions, early in a trend, and those that appear to be out of favor.
SlateStone manages risks within our clients’ portfolios by maintaining a diversified portfolio,
limiting the number of holdings to a manageable total, calculating price targets and risk levels,
and by rigorously monitoring the market and economic trends affecting the securities we invest
in on behalf of our clients.
SlateStone adheres to the philosophy that long-term results can be achieved by adhering to
established processes built on goals-oriented objectives, an understanding of the impact
emotions have on investor behavior and factoring that knowledge into our portfolio construction
when developing a long-term financial and investment plan for our clients. This entire process is
augmented and enhanced by applying a disciplined rebalancing process to our portfolio
management that is intended to reset allocation targets, maintain appropriate portfolio risk
parameters and reduce overweighting.
SlateStone’s sell discipline involves the same procedures we employ to identify a potential
purchase candidate, simply in reverse. We carefully review the fundamentals affecting the
securities purchased for our clients. We rigorously monitor peer to peer valuations and the
valuations of our holdings and use technical indicators to inform our fundamental decision-
making and investment timing. Our sell discipline can be triggered by certain variables
including earnings deceleration, fundamental changes in a security, company or within the
industry or sector and is also informed based on interpretation of macro-economic or geo-
political conditions.
Bonds/Fixed Income. SlateStone’s fixed income securities are selected based on client objectives
for income, risk tolerance, and time horizon among other factors. Our fixed income security
selection includes taxable, tax-free, and high-yielding portfolios of investment grade quality.
Real Estate‐Related and Other Private Investment Offerings. When appropriate, and in
accordance with the client’s objectives and investment plan, SlateStone may recommend the use
of one or more alternative private investments in addition to our traditional investment
management services. For clients for whom such services are suitable, the Firm will provide
advice which includes:
• Liquid, publicly traded alternatives through mutual funds, ETFs, and REITs
• Non-liquid private investments for qualified and/or accredited investors
●Venture Capital
●Hedge Fund
● Real Estate
● Private Equity
● Private Credit
Services included within the scope of such advice include strategic research, due diligence,
investment monitoring and reporting.
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Private Non-Exchange Traded Alternative Investments are privately offered investment
vehicles, such as private equity, private credit, real estate, or hedge funds, that are not listed or
traded on public securities exchanges. When recommending these types of investments, we will
look to potential transactions sourced by offerors known to SlateStone, source new private
funds through our network, or source funds through third-party alternatives platforms. . All
such offerors or their control persons will be experienced with a verifiable track record of prior
transactions. Analysis will include evaluation and due diligence of the transaction, offerors and
related persons, performance history and experience of offerors and related persons, liquidity
of investment, current and future cash flow potential, and associated risks. Significant risk may
be associated with private non-exchange traded alternative investments, and such risk may not
necessarily be mitigated by our analysis. These investments are for sophisticated investors with
large net worth and liquid assets to cover losses if necessary.
SlateStone’s private investment recommendations to sophisticated investors may, on occasion,
be in private funds or limited partnerships where the offeror or control persons are also clients
of SlateStone. SlateStone will disclose any potential conflict to the clients that are receiving the
recommendation, and clients are free to choose said investment or seek an investment that does
not pose a potential for conflict.
SlateStone is not compensated by any means, either commission or “finders” fee, for advising a
client to invest in a private fund operated by an individual who is also a client of SlateStone.
SlateStone acts in its fiduciary capacity to represent investments suitable for and in the best
interests of all of its clients. Private investment partners or control persons that are clients of
SlateStone compensate SlateStone only as an investment client of SlateStone under an
Investment Management Agreement for the services received as a client of the Firm.
External Independent Managers. SlateStone’s discretionary authority includes the ability to
select any US registered investment adviser to manage client assets based on specific criteria,
and such managers could invest client assets in separate accounts or investment funds managed
by other advisers. These external investment managers are authorized to buy, sell and trade in
securities in accordance with client investment objectives as communicated by SlateStone.
SlateStone is authorized to terminate or change independent managers when, in our sole
discretion, we believe such a termination or change is in our clients’ best interest. SlateStone’s
research team conducts a thorough review process to select external manager strategies and
runs portfolio analytics and reviews proprietary research along with fundamental and historical
pricing and relative pricing. This review includes quantitative and qualitative analyses which
could include direct discussion with the manager to assess each manager’s likelihood of
generating future returns as well as to measure the risks associated with the generation of those
returns. The research team monitors external managers for adherence to their stated investment
process and regularly assesses whether risks are being responsibly managed. The ongoing
screening process is also designed to uncover new external investment strategies that could be
utilized for SlateStone’s clients.
Donor Advised Funds. SlateStone can facilitate a client’s interest in charitable giving by
allocating a portion of the client’s assets to a donor advised fund. In specific circumstances, a
foundation will administer the donor advised funds for clients and SlateStone will manage the
assets in these donor-advised funds.
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Derivative Investments. SlateStone could utilize derivative investments and options where
suitable for its clients to meet specific objectives for growth, risk management, and income. The
firm will determine, analyze, select, and monitor derivative securities for clients qualified to
invest in them.
Structured Notes. A structured note is a financial instrument that combines two elements, a
debt security and exposure to the underlying asset such as: equities, currencies, bonds,
commodities, or funds and one or more derivatives that are structured into one securitized
instrument. As a note, it carries counter-party risk of the issuer with the return on the note
linked to the return of an underlying asset. The most common type of structured product
utilized selectively at SlateStone is a buffered return-enhanced note which provides for some
downside market protection while leveraging market returns on the upside and is linked to a
particular market index (such as the S&P 500 Index).
Structured products could involve a high degree of risk and could be highly complex, but they
could also be used as flexible alternatives to traditional investment categories while providing
attractive additional features, such as capital protection, yield enhancement, leverage, or a
combination thereof. On a selective basis, SlateStone could employ the use of structured
products within client accounts when suitable to the client’s overall asset allocation, investment
time horizon and risk profile. Importantly, investors could receive long-term capital gains tax
treatment if certain underlying conditions are met and the note is held for more than one year.
Further, structured notes could also encounter liquidity issues, when being sold prior to
maturity.
Pledged Accounts
We have some client relationships where there is a non-purpose line of credit that is secured by
the advisory investment account. These lines are charged a floating rate of interest on any
outstanding balance based upon a spread over a Secured Overnight Financing Rate (SOFR).
When assets are pledged as collateral for a non-purpose line of credit, several risks arise. Market
volatility can impact the value of the pledged assets, potentially triggering a maintenance call if
the value falls below a certain threshold. This could lead to the forced sale of assets or additional
capital requirements. The floating interest rate, based on SOFR, introduces interest rate risk, as
an increase in SOFR would result in higher interest payments. Furthermore, the use of SOFR, a
risk-free rate, may not accurately reflect the credit risk involved. Liquidity risk is also a concern,
as access to funds in the pledged account may be limited. Lastly, there may be adverse tax
implications when selling securities to meet a maintenance call. These risks should be
thoroughly understood by clients before they pledge assets or accounts.
Investment Strategies
SlateStone’s professional CFA®-led investment team manages five in-house Foundational
Equity Strategies on both a customized basis (where we craft bespoke strategies for clients) and
individual equity portfolios with the following objectives:
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• High Quality Dividend Strategy is a dividend-income focused equity strategy designed
to provide cash flow and lower equity market volatility comparative to the S&P 500
Index. The strategy will typically hold 30 – 40 large and mid-cap individual US Equities
to achieve its objectives and is appropriate for clients seeking equity-like income and
modest growth of capital and is managed with a lower-than-average turnover to provide
tax efficiency.
• Core Equity Strategy is a diversified large and mid-cap, individual equity strategy
designed as a foundational portfolio to deliver enhanced risk-adjusted returns through
active management and diversification. This long-term growth-oriented strategy
typically holds 25 – 35 large and mid-cap global equities and is suitable for investors
with a moderate risk tolerance and a time horizon of 2-3 years or more.
• GARP Equity Strategy is a diversified large cap, individual equity strategy focused on
companies with stable and consistent earnings growth & profitability trading at
attractive relative and absolute valuations. The strategy will typically hold 30-40 large
cap domestic equities and ADRs and is appropriate for investors with a time horizon of
greater than 2 years and a moderate risk tolerance.
• Small Cap Growth Strategy is a small cap strategy that invests in individual equities
evaluated to be disruptive innovators with strong potential for long-term growth and
capital appreciation. This long-term disruptive growth strategy will typically hold 30-40
positions designed to deliver outsized returns through thematic sector allocation and
diversification. The strategy is best suited for investors with a high-risk tolerance and a
time horizon of over 3 years.
• Enhanced Dividend Growth Equity Strategy is a dividend growth focused equity
strategy that invests exclusively in S&P 500 Index companies that have increased their
annual dividend payments for at least 25 consecutive years. The strategy will typically
hold 50- 65 individual equities and will seek to provide a growing stream of dividend
income and long-term capital appreciation. The dividend growth strategy is suitable for
investors with a moderate risk tolerance and a time horizon of greater than 2 years.
As part of the firm’s Strategic Asset Allocation Portfolio Management Service, SlateStone has
developed asset allocation strategies and processes to manage client portfolios. These strategies
could be combined, as appropriate, for each client’s personal financial condition and
investment objectives. SlateStone offers five asset allocation strategies to align with overall
client objectives and risk tolerances and which invest primarily in exchange traded funds or
mutual funds:
• Appreciation
• Conservative
• Moderate
Conservative
• Balanced
• Moderate
Appreciation
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Based upon market conditions and the firm’s investment outlook, the composition of the above
portfolios could include, at varying percentage allocations, the following asset classes:
• Equities including domestic, global, international, large, mid-cap and small cap,
sector, and diversified funds
• Fixed income including short and long-term high quality, mortgage back, strategic
income, bank loans, high-yield
• Alternatives including tactical, hedging, real estate, credit, venture capital and multi-
asset. Some alternatives are liquid and others are illiquid (subject to accreditor investor
qualifications).
Furthermore, the portfolios percentage asset allocation ranges (across cash, equities, fixed
income, alternatives) can be modified upon approval of the firm’s Investment Policy Committee
to align closely with our investment thesis in different market environments.
In certain sized portfolios and based upon client objectives and suitability, and where
appropriate, structured notes will be utilized as well.
Accounts managed in SlateStone’s Strategic Asset Allocation Portfolio strategies are designed to
meet the specific needs of a common group of clients.
Risk of Loss
All investments involve the risk of loss of your principal (invested amount) and any profits that
have not been realized (the securities have not been sold to “lock in” the profit). Markets can be
volatile, and prices of stocks, bonds, and other investments can fluctuate substantially over time.
Other factors such as economic and political events can also affect the performance of your
investments. There is no guarantee, despite our due diligence review and monitoring, that you
will not lose money or that you will meet your investment objectives. We encourage you to
discuss any questions that may arise regarding our investment philosophy and your portfolios
throughout the course of our relationship.
Equity-Related Securities and Instruments. The firm could take long positions in common
stocks of U.S. and non-U.S. issuers traded on national securities exchanges and over-the-
counter markets. The value of equity securities varies in response to many factors. These factors
include, without limitation, factors specific to an issuer and factors specific to the industry in
which the issuer participates. Individual companies could report poor results or be negatively
affected by industry and/or economic trends and developments, and the stock prices of such
companies could suffer a decline in response. Equity securities are subject to stock risk, which is
the risk that stock prices historically rise and fall in periodic cycles. U.S. and non-U.S. stock
markets have experienced periods of substantial price volatility in the past and could do so again
in the future. Investments in small-capitalization, mid-capitalization and financially distressed
companies could be subject to more abrupt or erratic price movements and could lack sufficient
market liquidity, and these issuers often face greater business risks.
Fixed Income Securities. Fixed income securities are subject to the risk of the issuer or a
guarantor’s inability to meet principal and interest payments on its obligations and to price
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volatility.
Mutual Funds and ETFs. Shareholders are liable for taxes on any fund-level capital gains, as
mutual funds and ETFs are required by law to distribute capital gains in the event the fund sells
securities for a profit that cannot be offset by a corresponding loss. The trading price at which a
share is transacted is equal to a fund’s stated daily per share net asset value “NAV” plus any
shareholders’ fees (e.g., sales loads, purchase fees, redemption fees). The trading prices of a
mutual fund’s shares could differ significantly from the NAV during periods of market volatility,
which could, among other factors, lead to the mutual fund’s shares trading at a premium or
discount to actual NAV.
Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the
secondary market. Generally, ETF shares trade at or near their most recent NAV, which is
generally calculated at least once daily for indexed based ETFs and potentially more frequently
for actively managed ETFs. However, certain inefficiencies could cause the shares to trade at a
premium or discount to their pro rata NAV. There is also no guarantee that an active secondary
market for such shares will develop or continue to exist. Generally, an ETF only redeems shares
when aggregated as creation units (usually 20,000 shares or more). Therefore, if a liquid
secondary market ceases to exist for shares of a particular ETF, a shareholder could have no way
to dispose of such shares.
Alternative Private Investment Risk. (non-traded securities and limited partnerships)
Alternative private investments are investments with companies or in sectors that are not
publicly traded. These investments are normally very illiquid and can be volatile; therefore, they
are not ideal for clients with frequent or unknown cash needs. There is normally no public
market for alternative investments. As a result, if investors need to sell their shares, they will
most likely do so at a substantial discount. Further, depending on the terms of the investment,
the investor may not be able to transfer or sell their shares. The risk of investing in alternative
private investments is a substantial or complete loss of invested funds. In addition, investors
may not see any return on investment for some time depending on the type of investment and
its expected time horizon and as a result, these investments should be seen as a long-term
investment subject to a high risk of loss. Note that investors must typically meet income and net
worth thresholds to invest in these investments.
Listed below are some potential risks with any investment:
Cash Management Risks. The firm will invest some of a client’s assets temporarily in money
market funds or other similar types of investments, during which time an advisory account
could be prevented from achieving its investment objective.
Cybersecurity Risk. The technology software and systems used by SlateStone and its respective
service providers could be vulnerable to inadvertent interruption. In addition to natural
catastrophes, service outages or security breaches could result in disruption and theft of data,
including investor information. SlateStone has implemented cybersecurity procedures meant to
address these risks. Additionally, there are inherent limitations in cybersecurity policies,
procedures and controls including the possibility that certain risks have not been identified.
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SlateStone has conducted due diligence and risk assessments of our third-party providers.
However, SlateStone is not able to control the cybersecurity plans, breach notifications, incident
response plans and controls put in place by these service providers. It is in the client’s best
interest to monitor all of their accounts on a regular basis and stay informed of cybersecurity
best practices for their personal devices.
Event Risk. An adverse event affecting a specific company or that company’s industry could
depress the price of a client’s investments in that company’s stocks or bonds. The issuer could
become unable to handle its debt service or receive a downgraded credit rating by a rating
agency.
Fund Manager Risk: There is the risk that the investment, despite our due diligence review and
monitoring, becomes threatened due to unknown circumstances, actions or decisions of the
Fund Company and its employees resulting in a negative impact on shareholders.
Inflation Risk. Inflation is a general upward movement of prices reducing your purchasing
power, which is a risk for investors receiving a fixed rate of interest. The concern for individuals
is that inflation will erode returns.
Interest Rate Risk. An increase in interest rates could depress the prices of bonds and other
fixed income securities in a client’s portfolio.
Liquidity Risk. Securities that are normally liquid could become difficult or impossible to sell at
an acceptable price during periods of economic instability or other emergency conditions. Some
securities could be infrequently or thinly traded even under normal market conditions.
Margin Risk. Some of our investment strategies require that you maintain a margin account.
Clients who purchase securities could pay for them in full or could borrow part of the purchase
price from the broker-dealer that holds his/her account. Clients generally use margin to
leverage their investments and increase their purchasing power. At the same time, clients who
trade securities on margin incur the potential for higher losses. We will discuss the risks of
using margin with clients to determine if it is appropriate.
Market Risk. Investing involves risk, including the potential loss of principal, and investors
should be guided accordingly. The profitability of a significant portion of SlateStone’s
recommendations and/or investment decisions could depend, to a great extent, upon correctly
assessing the future course of price movements of stocks, bonds, and other asset classes. In
addition, investments could be adversely affected by financial markets and economic conditions
throughout the world. There can be no assurance that SlateStone will be able to predict these
price movements accurately or capitalize on any such assumptions.
Pandemic Risk. Pandemic risk may have long-term effects on causing extreme volatility and
disruption in both the U.S. and global markets leading to uncertainty and risks to economic
growth, etc. SSW cannot predict the effects of significant future events on the global economy
and securities markets. A similar disruption of the financial markets could impact interest rates,
credit risk, inflation, and other factors.
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Political Risk. The events that occur in the home country of the foreign company could impact
valuations. Events such as revolutions, nationalization, currency collapse or other types of
events can have a negative impact on the security.
REIT Risk. Real Estate Investment Trust (REIT) share prices could decline because of adverse
developments affecting the real estate industry and real property values. In general, real estate
values can be affected by a variety of factors, including supply and demand for properties, the
economic health of the country or different regions, and the strength of specific industries that
rent properties. REITs are subject to heavy cash flow dependency, default by borrowers and self-
liquidation. REITs, especially mortgage REITs, are also subject to interest rate risk (i.e., as
interest rates rise, the value of the REIT may decline).
Tax Harvesting Risk. Efficient tax-loss harvesting is an important component of a customized
portfolio approach. Tax harvesting is a strategy where an ETF or mutual fund is sold at a taxable
loss and replaced with a security whose historical performance and expected future performance
are similar, thereby having little impact on the overall strategic allocation, but capturing the tax
loss. Because past performance is no indication of future performance, there is potential for the
future performance of the replacement position to deviate from that of the initial holding. This
type of strategy could also incur an increase in the frequency of trading and amount of
transaction costs.
Volatility Risk. The prices and values of investments can be highly volatile, and are influenced
by, among other things, interest rates, general economic conditions, the condition of the
financial markets, the financial condition of the issuers of such assets, changing supply and
demand relationships, and the programs and policies of governments.
Derivative Risk. Investing and engaging in derivative instruments or derivative transactions
such as options, commodity funds and commodity exchange traded funds, could involve
different types of risk and possibly greater levels of risk such as those listed below.
• Leverage Risk. A derivative instrument or transaction could disproportionately increase
an account’s exposure to the market for the assets underlying the derivative position and
the sensitivity of an account’s portfolio to changes in market prices for those assets.
• Counterparty Credit Risk. An account’s ability to profit from a derivative contract
depends on the ability and willingness of the other party to the contract “counterparty,”
to perform its obligations under the contract. If the counterparty to an over-the-counter
contract fails to perform its obligations, an account could lose the benefit of the contract
and could have difficulty reclaiming any collateral that an account could have deposited
with the counterparty.
•
• Lack of Correlation. The market value of a derivative position could correlate imperfectly
with the market price of the asset underlying the derivative position. If a derivative
position is being used to hedge against changes in the value of assets in an account, a
lack of price correlation between the derivative position and the hedged asset could
result in an account’s assets being incompletely hedged or not completely offset price
changes in the derivative position.
Illiquidity. Over-the-counter derivative contracts are usually subject to restrictions on
transfer, and there is generally no liquid market for these contracts. Although it is often
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possible to negotiate the termination of an over-the-counter contract or enter into an
offsetting contract, a counterparty could be unable or unwilling to terminate a contract
with an account, especially during times of market instability or disruption.
• Less Accurate Valuation. The absence of a liquid market for over-the-counter derivatives
increases the likelihood that SlateStone will be able to correctly value these interests.
Cash Interest Rate Risk. A portion of client assets may be held in cash or cash equivalents to meet
liquidity needs, manage risk based on market conditions, or as part of the overall portfolio strategy.
These holdings may include money market funds or other cash vehicles available through the
custodian. Factors such as yield, liquidity, and investment timing are considered when selecting
among available options. While higher-yielding cash alternatives may exist outside of custodial
platforms, use of those alternatives could delay the availability of funds for investment or reduce
flexibility for portfolio adjustments.
Definition of Liquid Assets and Cash Equivalents
We classify liquid assets as those that can be easily converted into cash without a notable loss of
value. These encompass short-term, highly liquid investments such as Treasury bills, CDs, and
money market funds. Additionally, these may include short-term bonds, commercial paper, and
highly liquid securities as cash equivalents.
Item 9 - Disciplinary Information
SlateStone does not have any disciplinary matters to disclose regarding its advisory business.
Item 10 - Other Financial Industry Activities and
Affiliations
SlateStone is not and does not have a related person that is a broker/dealer, municipal securities
dealer, government securities dealer or broker, an investment company or other pooled
investment vehicle (including a mutual fund, closed-end investment company, unit investment
trust, private investments company or hedge fund, and offshore fund), a futures commission
merchant, commodity pool operation, or commodity trading advisor, or a banking or thrift
institution.
We are not engaged in any other business activities and offer no other services except those
described in this Disclosure Brochure. Certain SlateStone employees serve on corporate boards;
however, such board participation requires approval by SlateStone’s CEO and does not create
any material conflict for SlateStone or the employee/principals involved.
Emerald Planning is an outside business owned by one of our Investment Adviser
Representatives, Joshua Rudolph. Emerald Planning is not affiliated with SlateStone. Joshua’s
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ownership of Emerald Planning represents an outside business activity and additional
compensation situation, which is disclosed on his Form ADV Part 2 B and on
https://adviserinfo.sec.gov/.
SlateStone’s advisers who hold separate insurance licenses recommend certain insurance
products, such as disability and life insurance and fixed or variable annuities, among others, to
meet a client’s financial goals. These recommendations could earn the advisers commissions,
potentially influencing their advice.
In some instances, your adviser may refer you to an independent, non-affiliated insurance agent
for guidance or to purchase insurance products. You are not obligated to follow any insurance or
annuity recommendations made by your adviser or the referred agent. SlateStone does not
receive any compensation from insurance or annuity sales, nor does it reduce its advisory fee to
offset any related commissions.
Please note that some insurance recommendations may not be subject to the same fiduciary
standard as investment advice.
Item 11 - Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading
SlateStone has adopted a Code of Ethics (the Code), which serves a number of purposes. First,
the Code is designed to assist SlateStone in complying with applicable laws and regulations
governing its investment advisory business. Under the Investment Advisers Act of 1940,
SlateStone owes fiduciary duties to its clients. Pursuant to these fiduciary duties, the Code
requires persons associated with SlateStone to deal fairly with clients putting the interests of its
clients ahead of personal interests. In addition, the Code prohibits such associated persons from
trading or otherwise acting on insider information. In this regard, SlateStone’s associated
persons are not to take inappropriate advantage of their positions relative to SlateStone clients.
The Code sets forth policies and procedures to monitor and review the personal trading
activities of associated persons, including procedures for reporting and review of such trading.
SSW utilizes technology to monitor employee trading activities.
Employees may buy or sell for themselves a security being recommended to a client. Employees
are asked to fill client trades prior to entering their personal trades. Due to market conditions,
this practice may create a situation where the employee receives a better price than the client.
A number of our employees are practicing Chartered Financial Analysts (CFAs®) and are
required to subscribe to the CFA Institute Code of Ethics and Standards of Professional
Conduct. The Code and Standards are accepted in writing and adherence affirmed on an annual
basis by the employee holding the designation. A written copy of the CFA Institute Code of
Ethics and Standards of Professional Conduct can be provided upon request.
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Item 12 - Brokerage Practices
Best Execution and Benefits of Brokerage Selection
SlateStone seeks “best execution” for client trades, which is a combination of a number of
factors, including, without limitation, quality of execution, services provided and commission
rates. Best execution means the most favorable terms for a transaction based on all relevant
factors. Therefore, SlateStone could use or recommend the use of brokers who do not charge
the lowest available commission in recognition of research and securities transaction services,
or quality of execution. Research services received with transactions may include proprietary or
third‐party research (or any combination) and could be used in servicing any or all of
SlateStone’s clients. Therefore, research services received is not solely used for the account for
which the particular transaction was affected.
SlateStone has established brokerage arrangement with Charles Schwab & Co., Inc. (Schwab)
and Fidelity Brokerage Services LLC (Fidelity) . We will recommend that clients establish a
brokerage account with one of these non-affiliated custodians. Although we may recommend
that clients establish accounts at one of these custodians, it is ultimately the client’s decision as
to where to custody their assets. We are independently owned and operated and are not
affiliated with Schwab or Fidelity. They will hold your assets in a brokerage account and buy
and sell securities when we instruct them to in accordance with our investment management
agreement. The Custodians’ products and services that assist SlateStone in managing and
administering clients’ accounts include software and other technology that (i) provide access to
client account data (such as trade confirmations and account statements); (ii) facilitate trade
execution and allocate aggregated trade orders for multiple client accounts; (iii) provide pricing
and other market data; (iv) facilitate payment of fees from its clients’ accounts; and (v) assist
with back-office functions, recordkeeping and client reporting.
The Custodians offer other services intended to help SlateStone manage and further develop its
business enterprise. Some of these services include (i) technology, compliance, legal and
business consulting (ii) publications and conferences on practice management and business
succession (iii) access to employee benefits providers, human capital consultants, and
insurance providers (iv) make available, arrange, and/or pay third‐party vendors for the types
of services rendered to SlateStone (v) discount or waive fees it would otherwise charge for some
of these services or pay all or a part of the fees of a third‐party providing these services to
SlateStone.
The Custodians also provide other benefits such as educational events or occasional business
entertainment for SlateStone personnel. In evaluating whether to recommend that client’s
custody their assets at the Custodians, SlateStone takes into account the availability of some of
these foregoing products and services and not just the nature, cost or quality of custody and
brokerage services provided by the Custodians, which could create a potential conflict of
interest. See item 14 for more information on the conflicts of interest associated with these
arrangements.
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The firm will conduct, at least annually, a Best Execution Review which shall be summarized to
include the overall effectiveness of the Brokers’ overall performance for the clients of the firm.
Schwab and Fidelity charge brokerage commissions and/or transaction fees for effecting certain
securities transactions (i.e., transaction fees are charged for certain no-load mutual funds,
commissions are charged for fixed income securities transactions).
In addition to SlateStone’s investment management fee, clients will also be subject to brokerage
commissions and/or transaction fees. Furthermore, when transactions of mutual funds or
exchange-traded funds are made, they will incur charges at the fund level. These charges include
fund management fees and other fund-related expenses. Please note that SlateStone does not
receive any of these additional charges. SlateStone’s only compensation is our investment
management fee. For more information related to the fees of mutual funds or ETFs, please refer
to the respective fund’s prospectus. Information about brokerage commissions and transaction
costs can typically be found in the broker’s or custodian’s fee schedule or service agreement.
Directed Brokerage
Clients can direct SlateStone to use a particular broker for custodial or transaction services on
behalf of the client’s portfolio. In directed brokerage arrangements, the client is responsible for
negotiating the commission rates and other fees to be paid to the broker. Accordingly, a client
who directs brokerage should consider whether such designation can result in certain
disadvantages to the client, such as higher commissions or less favorable execution.
When accepting a client-directed brokerage arrangement, we may be unable to seek best
execution for your trades. This means we might not be able to obtain the most favorable terms
available, including price, execution speed, and transaction costs. As a result, the execution and
price of your trades could be negatively impacted, potentially leading to higher costs or less
favorable pricing compared to trades executed through our preferred brokers. As a matter of
practice, we will trade your account with your broker of record.
We have established a relationship with Schwab and Fidelity for the custody of client assets.
Both provide us the ease of transacting client requests. We feel that the services and fees
charged by these brokers meet our best execution best efforts.
By directing SlateStone to use a specific custodian, clients who are subject to ERISA confirm
that they have the authority to make the direction, that there are no provisions in any client or
plan document which are inconsistent with the direction, that the brokerage and other goods
and services provided by the custodian through the brokerage transactions are provided solely
to and for the benefit of the client’s plan, plan participants and their beneficiaries, that the
amount paid for the brokerage and other services have been determined by the client and the
plan to be reasonable, that any expenses paid to the broker on behalf of the plan are expenses
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that the plan would otherwise be obligated to pay, and that the specific custodian is not a party
in interest of the client or the plan as defined under applicable ERISA regulations.
Investment Allocation and Trade Aggregation
The overriding principle governing SlateStone’s allocation and aggregation process is the fair
and equitable treatment of all clients in the allocation of investment opportunities, the
aggregation of client orders and resulting allocation of securities or transaction proceeds. The
Investment Policy Committee and the firm’s CCO monitors the trading allocation procedures on
a regular basis, as does the firm’s trader. SlateStone’s trading department prioritizes the release
of trading orders with respect to its advised separate accounts as follows:
• Discretionary accounts that do not have restrictions
• Accounts with restrictions that require manual intervention to process trades
(Restrictions include deviations due to specific cash needs or liquidity, tax-
implications, security-restrictions, unsupervised holdings, etc.)
• Accounts with directed brokerage arrangements
• Non‐discretionary accounts that require a client’s pre‐approval of trades
Due to the sequence of placing trades for accounts, it is possible that accounts that are traded
first receive more favorable pricing than accounts that are traded last.
Trade Aggregation & Order Handling
As previously noted in our Strategic Portfolio Management services, we offer model asset
allocation strategies, and through our Customized Investment Management services, we
provide individually customized investment portfolios. Clients in our model asset allocation
strategies typically hold the same securities as other clients in the same strategy with variations
depending on the time of purchase of securities in the strategy and initial allocation.
When possible, we block or aggregate orders when buying and selling securities held in our asset
allocation strategies and distribute or allocate the shares to the respective clients’ accounts. We
block or aggregate orders with each custodian, resulting in several block trades in one security at
one time. This practice could result in more favorable pricing than would occur with individual
trades. When securities are distributed to more than one client, the execution price will be the
average of the price of the securities within each block. This will result in the same trade price
for all clients within the block, but there can be differences between accounts due to commission
charges.
Securities purchased or sold in a block transaction are allocated pro rata, when possible, to the
participating client accounts in proportion to the size of the order for the respective accounts. In
all cases, we distribute the securities equitably across the accounts. If circumstances are such
that it is impractical for us to allocate a small number of securities across accounts, then we
would allocate in a manner that we believe is fair to all clients.
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Clients with individual custom portfolios, do not always hold the same securities as other clients
in custom portfolios. Typically, the variations among these portfolios can be substantial between
one client and the next and are therefore difficult to aggregate for block trading purposes.
Generally, we place trades on a client-by-client basis for our customized portfolios unless we
decide to purchase or sell the same securities for several clients at approximately the same time.
In these instances, we could, but are not obligated to, block these orders to obtain best
execution. Similar to the process with the model asset allocation strategies, we average the price
of the transaction and allocate the positions on a pro-rata basis across the participating clients’
accounts. SlateStone does not receive any additional compensation as a result of aggregating or
blocking trades.
Employee Participation in Aggregated Trades.
At times, accounts for clients and related persons, who have engaged the firm as an adviser, will
be rebalanced to account for changes in the strategy or to account for the change in ratio of
assets that results from contributions and withdrawals to or from the accounts. The purpose of
these rebalancing transactions is to bring each account’s exposure to a commonly held
investment in line with the account’s percentage of total assets under management. Trades will
be aggregated for all clients and related persons. If the entire block order is not filled, then the
trader will allocate the fills on a pro rata basis across client and related persons accounts.
Trade Rotation
Generally, trades will be aggregated for each group of participating client accounts that share a
common custodian. SlateStone places the orders for aggregated block trades through a rotation
of the executing custodians so that no group is disadvantaged over time by the timing of the
executions.
Agency Cross Transactions
The Firm does not engage in agency cross transactions.
Cross Transactions
It is the Firm’s policy to engage in cross trade transactions only in accordance with its fiduciary
duty to seek to receive the best available execution on behalf of its clients. All cross trades must
receive the prior written approval of the Firm’s Chief Compliance Officer. The firm does not
generally engage in cross transactions.
Self-directed/Unsolicited Trades
On occasion, a client may request that we buy or sell a security on their behalf. These self-
directed/unsolicited trades will be accommodated on a ‘best efforts’ basis meaning we use
reasonable efforts to accommodate a client request. In periods of increased market volatility,
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there can be delays in trading and prices can swing dramatically, although we expect these
situations to be exceptions.
If this is a purchase of a security, we will be available to execute a closing transaction on future
instructions received from a client, but we will not be managing this holding on a discretionary
basis and the position will be marked as ‘non-discretionary’ or ‘unsupervised.’ Further, as a self-
directed holding outside of our discretionary management, it is the client’s responsibility to
monitor and direct us when to sell the holding.
We will periodically discuss the overall portfolio including self-directed holdings in relation to
the client’s overall financial objectives, however, we will not be able to accept liability for any
performance results or lack thereof on self-directed holdings.
Client Participation in Transactions
A particular account may or may not participate in a specific transaction or may receive
allocations of securities or investments that differ from that provided to other accounts, based
on a number of factors including, but not limited to, the trade rotation policy, previous
transactions, account restrictions, account size, tax status, risk tolerance, cash, and liquidity.
Although SlateStone generally will seek to be consistent in its investment approach for all
accounts with similar investment objectives and strategies, the act of purchasing, selling, or
holding a security for one account does not mean it will be purchased, sold, or held for another
account. Due to differing market conditions and factors previously cited, SlateStone could
purchase (or sell) a security on behalf of some accounts that SlateStone has sold (or purchased)
on behalf of other accounts and could do so at varying prices.
Item 13 - Review of Accounts
SlateStone strongly believes that ongoing client account reviews are an integral part of a
proactive investment advisory process. The firm has developed a process to conduct regular
client portfolio reviews and ongoing monitoring of client accounts.
SlateStone’s wealth advisors, supported by the portfolio management team, and with oversight
by SlateStone’s Investment Policy Committee are responsible for clients’ investment plans and
positioning of accounts based on market conditions and risk tolerances. In addition to our
ongoing monitoring of managed clients, the client advisors will conduct an in-depth review of
client portfolios at a minimum annually and more frequently based on a determination with
individual clients or the complexity of the strategy. Part of the review process includes a careful
review of the client objectives to confirm nothing has changed as well as a review of the asset
allocation to determine it is in line with stated objectives and is being managed in accordance
with SlateStone’s stated strategy objective, policies, and procedures.
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SlateStone’s Chief Compliance Officer or designee will also conduct a review of the services
selected and the suitability of those selections based on the information provided as part of the
new account documentation. At a minimum, accounts are reviewed by senior management on
an annual basis to ensure that current investments remain consistent with stated objectives.
Significant changes in the market, as well as any changes in a client’s financial circumstances
that have been communicated to SlateStone, could also trigger a more frequent review of client
portfolios. Furthermore, client accounts are reviewed when a major event or shift in market
conditions are expected to impact portfolios or holdings. SlateStone’s CCO will also conduct
periodic reviews of client portfolios to determine the suitability of the strategy being employed
and that it remains in line with client’s stated objectives as detailed on the client’s respective
documents.
Financial planning and consulting services clients are reviewed by our financial planning team
on an ongoing basis and in accordance with the terms entered into with the client in our
Financial Planning and Consulting Agreement. We may provide these clients with summaries
of our analyses and related conclusions as well as special reports that we mutually agree are
necessary. The frequency of these reviews will be determined with the client and their respective
wealth advisor. We encourage our clients to discuss their needs, goals and objectives and keep
us informed of any material changes.
Diminished Capacity/Suspected Fraud
In the event the advisor believes the client is acting in a state of diminished capacity or suspects
a third party is fraudulently directing the client in such a way that would financially harm the
client, the advisor reserves the right not to transact an investment, withdrawal, or deposit. The
advisor will then report the incident to the proper authorities. Clients are encouraged to
designate a trusted contact that the advisor can contact on the client’s behalf in case of
diminished capacity or suspected fraud.
Item 14 - Client Referrals and Other Compensation
Client Referral Arrangements
SlateStone has a policy that allows us to accept clients referred by affiliated and unaffiliated
promoters and to pay these promoters a percentage of our collected investment advisory fees
without any additional charge to the client. This arrangement is not exclusive between
SlateStone and the promoter, and we will accept only clients that are suitable for our
management and where we can help meet the client’s objectives.
We have entered into a referral agreement with each promoter and we require each promoter to
disclose to each prospective client the terms of the referral arrangement between SlateStone and
the promoter, including the compensation to be received by the promoter from SlateStone.
SlateStone will prepare and send each client a promoter disclosure statement which discloses
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The compensation being paid to the promoter. When a promoter refers a prospective client,
it presents a conflict of interest since the promoter is compensated if the prospect becomes
a client. Promoter fees under referral arrangements are paid from the fees SlateStone
receives from the client and do not result in any additional charges to the client. At least
annually, the firm will review all third‐party referral arrangements.
SlateStone may be paid a referral fee by other advisers when it refers individuals and other
entities to those advisers. Such referrals might be provided when the individual or entity does
not meet the minimums to become a SlateStone client, or SlateStone does not provide the type
of services requested. The individual or entity is not charged an additional fee for the outside
adviser’s compensation to SlateStone.
Clients refer prospective clients to SSW; however, SSW does not have any arrangements where we
compensate a client, directly or indirectly, for such referrals.
Other Professional referral sources
SlateStone’s highly customized, integrated approach to wealth management includes working
closely with accounting, legal and insurance firms. We have arrangements with these and other
professional referral sources to pay them referral fees. This in no way increases the investment
advisory fees the client is charged. All applicable Federal and or State laws are observed, and
appropriate disclosures are made.
SlateStone receives referrals from the public accounting firm, King & Lenson, CPAs. P.A, “K&L.”
Terri King, CPA is a minority equity member of SlateStone and a majority equity member of
K&L. Ms. King is a full-time employee of K&L but does attend scheduled partner meetings of
SlateStone. The K&L website is www.kinglensoncpas.com. Each company is owned and
operated independently from the other. As a result, there is never any obligation on behalf of
the client referred to either firm to use one or both companies. K&L and its employees are
compensated for referring clients to SlateStone for investment advisory services. As such, all
applicable Federal and/or State laws will be observed, and appropriate disclosures made.
Schwab Advisor Network
Slatestone receives client referrals from Charles Schwab & Co., Inc. (Schwab) through our
participation in Schwab Advisor Network® (the Service). The Service is designed to help
investors find an independent investment advisor. Schwab is a broker-dealer independent of
and unaffiliated with SlateStone. Schwab does not supervise SlateStone and has no
responsibility over the management of Clients’ portfolios or its advice or services. SlateStone
pays Schwab fees to receive client referrals through the Service. SlateStone’s participation in the
Service raises potential conflicts of interest described below.
SlateStone pays Schwab a Participation Fee on all referred clients’ accounts that are maintained
in custody at Schwab and a separate one-time Transfer Fee on all accounts that are transferred
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to another custodian. The Transfer Fee creates a conflict of interest that encourages SlateStone
to recommend that client accounts be held in custody at Schwab. The Participation Fee paid by
SlateStone is a percentage of the value of the assets in the client’s account. SlateStone pays
Schwab the Participation Fee for so long as the referred client’s account remains in custody at
Schwab. The Participation Fee is paid by SlateStone and not by the client. SlateStone has agreed
not to charge clients referred through the Service any fees or costs that are greater than the fees or
expenses SSW charges clients with similar portfolios who were not referred through the Service.
We receive an economic benefit from Schwab in the form of the support products and services
that Schwab makes available to us and other independent investment advisers whose clients
maintain their accounts at Schwab. In addition, Schwab has also agreed to pay for certain
products and services for which we would otherwise have to pay once the value of our clients’
assets in accounts at Schwab reaches a certain level. Clients do not pay more for assets
maintained at Schwab as a result of these arrangements. However, we benefit from the
arrangement because the cost of these services would otherwise be borne directly by us.
Because of these combined benefits, we are offering these referred clients a discount to our fee
schedule. You should consider these conflicts of interest when selecting a custodian.
Other Compensation
SlateStone’s compensation structure allows for its wealth advisory professionals to be
compensated with a percentage of revenue based upon the net fee revenue generated by clients
serviced by said advisor. This practice presents a potential conflict of interest for SlateStone
because an incentive exists for the advisor to recommend that client deposit additional assets or
transfer outside assets to our management based upon compensation rather than client needs.
As a fiduciary, SlateStone is required to act solely in the best interest of its clients. SlateStone
continuously seeks to address these conflicts through disclosures to its clients and through
internal policies and procedures that require all investment advice to be suitable for advisory
clients based upon the information provided by the client.
One of our employees, Joshua Rudolph, owns an insurance business. For further details, please
consult Mr. Rudolph’s Form ADV Part 2 B (specifically, Item 4 and Item 5) and item 10 of this
Form ADV Part 2 A. Our firm does not receive any share of the insurance commissions earned
through the employee’s insurance business.
Item 15 - Custody
SlateStone has established procedures to ensure all client funds and securities are held at an
unaffiliated qualified custodian in a separate account for each client under that client’s name.
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Account statements are delivered directly from the qualified custodian to each client at least
quarterly. Clients should carefully review those statements and are urged to compare their
custodial statements against reports received from SlateStone. On occasion our reports can vary
slightly from custodial statements based on accounting procedures, reporting dates or valuation
methodologies of certain securities. When clients have questions about their account
statements, or do not receive an account statement, they should contact SlateStone or the
custodian preparing the statement.
SlateStone is deemed to have custody of your assets, not requiring an annual surprise audit, if
you have instructed your custodian to deduct our advisory fees directly from your account or
granted us authority to move money to another person’s account. Your custodian maintains
actual custody of your assets.
One of our advisory representatives is a trustee on several accounts. Due to that relationship,
we do have custody on several accounts and are required to undergo an annual surprise audit
and file form ADV-E. We have arranged for this audit.
Item 16 - Investment Discretion
SlateStone will accept clients on either a discretionary or non‐ discretionary basis. For
discretionary accounts, a Limited Power of Attorney (“LPOA”) is executed by the client, giving
SlateStone the authority to carry out various activities including the following: trade execution,
request checks on behalf of the client and the withdrawal of advisory fees from the account. The
client can limit the terms of the LPOA to the extent consistent with the client’s Investment
Management Agreement with SlateStone and the requirements of the client’s custodian.
For non‐discretionary accounts, the client also generally executes an LPOA, which allows
SlateStone to carry out trade recommendations and approved actions in the portfolio.
However, in accordance with the Investment Management Agreement between SlateStone and
the client, SlateStone does not implement trading recommendations or other actions in the
account unless and until the client has approved the recommendation or action. As with
discretionary accounts, clients can limit the terms of the LPOA, subject to SlateStone ’s
agreement with the client and the requirements of the client’s custodian.
Class Action Suits
A class action lawsuit is a lawsuit brought by one party on behalf of a group of shareholders all
having the same grievance with a company in an effort to obtain monetary compensation.
The client (or client’s agent) will have the responsibility for class actions or bankruptcies,
involving securities purchased for, or held in, the client’s account. The Adviser is not responsible
for processing, documenting, or monitoring class actions on behalf of the client. However, if
requested and as a courtesy to the Client, the firm may assist in preparing the paperwork to file
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the class action. The decision of whether to participate in the recovery, or opt‐out, may be a
legal one that the Firm is not qualified to make for the client. Therefore, the Firm generally will
not file “Class Actions” on behalf of any client.
Item 17 - Voting Client Securities
SlateStone will not vote client proxies. SlateStone may, but is not required to, authorize external
separate account managers to vote any proxies relating to the externally managed, or sub-
advised assets, in accordance with the external separate account manager’s proxy voting policy.
When the client retains the right to vote proxies, the client’s authorization and instruction will
be provided to the custodian, who will then instruct the issuer to deliver proxy materials directly
to the client.
Item 18 - Financial Information
Registered investment advisers are required to report certain financial information or
disclosures about our financial condition. We have no financial situation that impairs our ability
to meet our contractual and fiduciary commitment to our clients.
We do not collect advance fees of $1,200 or more for services to be performed six months or
more in the future.
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