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Stolper & Company, Inc.
2305 Historic Decatur, Suite 100
San Diego, California 92106
619-231-9102
www.stolperco.com
3/11/2025
FORM ADV PART 2A
BROCHURE
This brochure provides information about the qualifications and business practices of Stolper &
Company (“SCI”). If you have any questions about the contents of this brochure, please contact us
at 619-231-9102 or 2305 Historic Decatur, Suite 100, San Diego, CA 92106. The information in this
brochure has not been approved or verified by the United States Securities and Exchange
Commission or by any state securities authority.
Additional information about Stolper & Company is also available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for Stolper & Company is 6911.
Stolper & Company is a Registered Investment Adviser. Registration with the United States
Securities and Exchange Commission or any state securities authority does not imply a certain
level of skill or training.
Material Changes – Item 2
An adviser is to disclose in this Item any material changes to its business since the last
annual update of its Form ADV. In 2024, SCI added financial planning to its offerings as
outlined in Item 4. As of 2024, the Company also conducts business under the name
“Solana Investment Solutions”. Additionally, SCI had amended their fee schedule as
outlined in Item 5.
Table of Contents - Item 3
Cover Page ............................................................................................................. Item 1
Material Changes .................................................................................................... Item 2
Table of Contents .................................................................................................... Item 3
Advisory Business ................................................................................................... Item 4
Fees and Compensation ......................................................................................... Item 5
Performance-Based Fees and Side-By-Side Management ..................................... Item 6
Types of Clients ...................................................................................................... Item 7
Methods of Analysis, Investment Strategies and Risk of Loss ................................ Item 8
Disciplinary Information ........................................................................................... Item 9
Other Financial Industry Activities and Affiliations ............................................... . Item 10
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
.............................................................................................................................. Item 11
Brokerage Practices .............................................................................................. Item 12
Review of Accounts ............................................................................................... Item 13
Client Referrals and Other Compensation ............................................................. Item 14
Custody ................................................................................................................. Item 15
Investment Discretion ............................................................................................ Item 16
Voting Client Securities ......................................................................................... Item 17
Financial Information ............................................................................................. Item 18
Advisory Business – Item 4
SCI, Inc. (SCI) was founded in 1975 by Michael Stolper who retired on December 31,
2017.
The principal owner of SCI is Barbara Malone.
Generally speaking, SCI offers the following services to clients:
1. SCI assists in selecting investment managers, mutual funds and commingled products
for discretionary portfolio management. These portfolios are not managed by Stolper
& Co.
Investment management firms and mutual funds are recommended to clients
after the following factors, if applicable, are considered:
i. Quality of the investment record
ii.
Longevity of the investment record
iii.
Investment philosophy
iv.
Types of securities owned
v. Portfolio structure
vi. Educational and business background
of investment principals
vii.
Fees
viii. Availability of references
ix. Research sources
x. Number of clients
xi. Amount of assets managed
xii. Method and frequency of reporting to client
xiii. Brokerage practices
xiv.
Long-term business plan
xv. Decision-making process
.
Recommendations of investment advisors are subject to certain constraints imposed by
the client including but not limited to:
i.
Fees of investment advisory firm.
ii.
Length of time in business of investment advisory firm.
iii. Number of portfolio managers employed by investment advisory firm.
iv. Aggregate assets currently managed by investment advisory firm.
v. Performance history of investment advisory firm for funds similar
to that of the client.
vi.
Investment philosophy of investment advisory firm
vii. Minimum account accepted by investment advisory firm.
Specific recommendations are usually made after conferring with the client with regard to
client’s investment objectives. The objectives give recognition of, among other things,
tax considerations, income requirements, ultimate purpose of the fund, investment
philosophy and risk tolerance.
It is SCI’s policy to encourage funds subject to ERISA, to develop a formal, written
statement of investment objectives. The statement should establish quantitative criteria
to measure the effectiveness of the investment advisor.
SCI from time to time provides investment consulting services to various entities on a flat
fee basis.
2. Stolper & Co. also provides asset allocation services to clients under an arrangement
in which SCI will allocate all or a portion of a client’s portfolio to subadvisers hired by
SCI. Under this arrangement, SCI monitors the investment activities of the subadvisers
and SCI retains the ability to terminate the subadviser or allocate more or less of the
client’s portfolio to the subadviser at any time. SCI also negotiates each subadviser’s
fees on the client’s behalf.
3. Stolper & Co. provides investment management services and individualized advice to
clients through a mutual fund selection program. SCI has full authority to purchase
and sell shares of open-end, both load and no-load funds, (load funds are selected
only if the sales charge is waived and it can be purchased at NAV and closed-end
mutual funds (including money-market funds) on behalf of each participating client.
Factors similar to those outlined above with respect to investment managers are
considered by the SCI in purchasing shares for clients’ accounts.
4. SCI, primarily under the trade name “Solana Investment Solutions”, provides financial
planning services primarily for individuals and families regarding the management of
their financial resources based on an analysis of their needs and circumstances. These
services generally include budgeting, education planning, retirement planning, estate
planning, and gifting strategies. SCI typically conducts a complimentary initial
consultation. Following the consultation, if the client decides to engage SCI for financial
planning services, detailed information about the client’s financial situation and
objectives are gathered. In performing these services, SCI is not required to verify any
information received from the client or from the client's other professionals (e.g.,
attorneys, accountants, etc.,) and is expressly authorized to rely on such information.
The company then reviews and analyzes the data with third party planning software,
including eMoney. A digital financial plan is created and presented to the client. The
primary objective of this process is to assist the client in developing a strategy for
saving, spending, and managing their assets and liabilities to meet their financial
objectives. SCI only provides financial planning services for clients that are, or expect
to become, investment management clients.
Clients should be aware that different financial planning software uses different
financial planning methodologies, and the financial plan will describe the specific
methodologies used for the particular plan and should be carefully considered in
evaluating the results presented to the client. The outputs generated by the software
utilize third-party proprietary formulas and are based on economic assumptions and
forecasts approved by SCI. In addition, clients’ financial plans may include a Monte
Carlo simulation. Monte Carlo simulations are used to show how variances in rates of
return each year can affect results. Results using Monte Carlo simulations indicate the
likelihood that an event may occur as well as the likelihood that it may not occur. SCI
may change the software, third- party provider, or the methodologies it uses when
creating your financial plan. Your financial plan will provide details on the software and
methodologies used.
SCI does not participate in wrap fee programs.
SCI manages $466,313,099 on a discretionary basis and $118,932,370 on a non-
discretionary basis. These numbers are as of December 31, 2024.
Fees and Compensation – Item 5
As of 2024, SCI fees for asset management and financial planning will be computed at
an annual rate of:
• 0.70% of the assets under management for equity and balanced accounts
on the first $5 million.
•
0.35% on assets under management above $5 million.
• The minimum annual fee is $3,500.
For clients that only engage SCI for financial planning services, we charge a flat fee of
$250 per month and we request a one-year commitment.
SCI also provides asset allocation services to clients under an arrangement in which SCI
will allocate all or a portion of a client’s portfolio to subadvisers hired by SCI. Under this
arrangement, SCI monitors the investment activities of the subadvisers and SCI retains
the ability to terminate the subadviser or allocate more or less of the client’s portfolio to
the subadviser at any time. SCI also negotiates each subadviser’s fees on the client’s
behalf.
SCI may charge lower fees for some clients based upon the amount of assets under SCI’s
management, the length and nature of SCI’s relationship with the client and other factors.
SCI’s fee does not include the services of any subadviser selected for the account,
custodial expenses or brokerage expenses in connection with the account. When
authorized by client, SCI will direct the client’s custodian to pay SCI’s and the subadviser’s
fees directly from the client’s account. Alternatively, the client may elect to be billed
directly for management fees. The manner in which fees are deducted is detailed in the
signed agreement with the client.
Clients pay management fees in advance. If the contract is terminated before the end of
a quarter for which the quarterly fee has been paid, the fee will be pro-rated and refunded
to the client.
SCI from time to time provides investment consulting services to various entities on a flat
fee basis.
In addition to the management fees payable to SCI, each mutual fund in which the assets
of the account are invested also pays its own investment advisory fees to its own
investment advisor, administrative expenses, and in some cases 12B-1 fees. Also, the
broker may be paid commissions and/or ticket charges for effecting purchases and sales
of funds.
SCI does not receive any referral fees or compensation from investment advisors for
recommending their firms to SCI’s advised clients. In the past, SCI’s clients may have
instructed an investment advisor to credit a portion of the advisor’s fee to SCI to
compensate SCI at its usual rates for the provision of its consulting and performance
measurement services. Any payments that SCI received under this arrangement were at
the convenience and request of the client. This payment option is not available for new
clients.
Performance Based Fees and Side-by-Side Management – Item 6
SCI does not charge any performance fees. Some investment advisors experience
conflicts of interest in connection with the side-by-side management of accounts with
different fee structures. However, these conflicts of interest are not applicable to SCI.
Types of Clients – Item 7
SCI provides services to individuals, trusts, estates, charitable organizations, pension and
profit-sharing plans, corporations or business entities other than those previously listed.
Accounts of $500,000 or more will be accepted, however smaller accounts may be
accepted when part of a household with more than $3,000,000 total value.
Methods of Analysis, Investment Strategies and Risk of Loss – Item 8
Methods of Analysis stated in Item 4.
The firm does not advocate the use of margin for clients.
All investing involves a risk of loss, and the investment strategies offered by SCI could
lose money over short or even long periods. Past performance is not a guarantee of
future results and individual account performance will vary. Performance could be hurt
by a number of different risks including but not limited to:
Stock Market Risk. Stock markets tend to move in cycles, with periods of rising prices
and periods of falling prices. There is a chance that stock prices overall will decline.
Sector Risk. There is a chance that significant problems will affect a particular sector, or
that returns from that sector will trail returns from the overall stock market. Daily
fluctuations in specific market sectors are often more extreme than fluctuations in the
overall stock market.
Bankruptcy of a broker or custodian could cause excessive costs or loss of
investor funds. If a broker with whom SCI has an account becomes insolvent or
bankrupt, SCI may be unable to recover all or even a portion of the assets maintained by
clients with that broker. Similarly, if a custodian housing a client’s securities or other
assets becomes bankrupt or insolvent, the client may be unable to recover all or even a
portion of the assets held by the custodian.
SCI may rely on information that turns out to be wrong. SCI selects investments
based, in part, on information provided by issuers to regulators or made directly available
to SCI by the issuers or other sources. SCI is not always able to confirm the
completeness or accuracy of such information, and in some cases, complete and
accurate information is not available. Incorrect or incomplete information increases risk
and may result in losses.
SCI may fail to identify successful companies. Identifying successful companies is
difficult, and there are no assurances that such a strategy will succeed. Furthermore,
clients may be forced to hold such investments for a substantial period of time before
realizing any anticipated value.
Investing in securities entails risks associated with the underlying business
including reliance on a company’s managers and their ability to execute business
strategies. In addition, all businesses face risks such as adverse changes in regulatory
requirements, interest rate and currency fluctuations, general economic downturns,
changes in political situations, market competitions and other factors. SCI will not have
day-to-day control over any company in which it invests for clients.
Fixed Income Securities. Risks associated with investing in fixed income securities (i.e.
bonds) include:
• The bond issuer’s inability to pay interest or repay the bond.
• Changes in market interest rates cause the bond’s value to fall.
•
Illiquidity in the bond market may make the bond difficult or impossible to
sell.
• The bond issuer may repay the bond prior to maturity; or
•
Inflation may reduce the effective yield on the bond’s interest payments.
Bonds- Call Provisions. Many bonds, including agency, corporate and municipal bonds,
and all mortgage-backed securities, contain a provision that allows the issuer to “call” all
or part of the issue before the bond’s maturity date. The issuer usually retains this right
to refinance the bond in the future if market interest rates decline below the coupon rate.
There are three disadvantages to the call provision. First, the cash flow pattern of a
callable bond is not known with certainty. Second, because the issuer will call the bond
when interest rates have dropped, clients are exposed to reinvestment rate risk – clients
will have to reinvest the proceeds received when the bond is called at lower interest rates.
Finally, the capital appreciation potential of a bond will be reduced because the price of
a callable bond may not rise much above the price at which the issuer may call the bond.
Bonds – Yield Curves. Bond portfolios typically include bonds with a range of maturity
dates. In assembling a bond portfolio, the Advisor generally assumes that changes in the
yield curve will occur at roughly parallel rates, that is, that interest rates on long-term
bonds will move up or down in the same direction as interest rates on short-term bond
yields. To the extent that the yield curve movements deviate from this assumption, the
bond portfolio may generate results different from those intended by SCI.
Bonds – Inflation. Inflation risk results from the variation in the value of cash flows from
a security due to inflation, as measured in terms of purchasing power. For example, if a
client purchases a 5-year bond in which it can realize a coupon rate of 5%, but the rate
of inflation is 6%, then the purchasing power of the cash flow has declined. For all but
inflation linked bonds, adjustable bonds or floating rate bonds, clients are exposed to
inflation risk because the interest rate the issuer promises to make is fixed for the life of
the security. To the extent that interest rates reflect the expected inflation rate, floating
rate bonds have a lower level of inflation risk.
At times SCI may invest other entities to which SCI’s principal may have a business
relationship (See Item 10 for more detail). No such investments are made unless
investments are in the best interest of clients and SCI has ensured that such investments
are made in compliance with its Insider Trading Policy.
Disciplinary Information – Item 9
SCI has not been involved in any legal or disciplinary events in the past ten years that
would be material to a client’s evaluation of the company or its personnel.
Other Financial Industry Activities and Affiliations – Item 10
SCI’s principal, Barbara Malone was a managing partner and part owner of Windowpane
Advisors, LLC. Windowpane was the advisor to Jordan Opportunity Fund. On June 13,
2015 Windowpane Advisors sold Jordan Opportunity Fund to Arrowmark Partners, the
advisor to the Meridian Funds. Jordan Opportunity was merged with Meridian Enhanced
Equity Fund. Windowpane is no longer a registered advisor. Windowpane is a Limited
Partnership that receives monthly tail payments for the 2015 sale. Other than the tail
payments, Windowpane has no ongoing interest in Arrowmark or the Meridian Funds
SCI may recommend to its clients the Meridian funds referred to above, with which SCI
had a relationship. These relationships are fully disclosed to the client.
Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading – Item 11
SCI has adopted a Code of Ethics (the “Code”) pursuant to Rule 204A-1 under the
Investment Advisers Act of 1040 that details its commitment to the principle that SCI owes
a fiduciary duty to its clients. To avoid any potential conflicts of interest involving personal
trades, the Code requires, among other things, that employees:
• Act with integrity, competence, diligence, respect, and in an ethical manner
with the public, clients, prospective clients, employers, employees,
colleagues in the investment profession, and other participants in the global
capital markets.
• Place the integrity of the investment profession, the interests of clients, and
the interests of SCI above one’s own personal interests.
• Adhere to the fundamental standard that they should not take inappropriate
advantage of their position.
• Avoid or disclose any actual or potential conflict of interest.
• Conduct all personal securities transactions in a manner consistent with the
policy.
• Use reasonable care and exercise independent professional judgment
when
conducting
investment
analysis, making
investment
recommendations, taking investment actions, and engaging in other
professional activities.
• Practice and encourage others to practice in a professional and ethical
manner that will reflect credit on yourself and the profession.
• Promote the integrity of, and uphold the rules governing, capital markets.
• Maintain and improve their professional competence and strive to maintain
and improve the competence of other investment professionals.
• Comply with applicable provisions of the federal securities laws.
SCI’s code also requires Employees to 1) pre-clear certain personal securities
transactions, 2) report personal securities transactions on at least a quarterly basis, and
3) provide SCI with a detailed summary of certain holdings (both initially upon
commencement of employment and annually thereafter) over which such Employees
have a direct or indirect beneficial interest.
A copy of SCI’s Code of Ethics shall be provided to any client or prospective client upon
request.
Brokerage Practices – Item 12
Your assets must be maintained in an account at a “qualified custodian,” generally a
broker-dealer or bank. We recommend that our clients use Charles Schwab &Co., Inc.
(Schwab), a registered broker-dealer, member SIPC, as the qualified custodian. We are
independently owned and operated and are not affiliated with Schwab. Schwab will hold
your assets in a brokerage account and buy and sell securities when we instruct them to.
While we recommend that you use Schwab as custodian/broker, you will decide whether
to do so and will open your account with Schwab by entering into an account agreement
directly with them. You may choose to use another custodian.
Schwab Institutional provides services intended to help SCI manage our business,
including publications, practice management conferences, information technology,
regulatory compliance, client account data, electronic duplicate statement and
confirmations that assists in managing your account. Most trades will be executed
through Schwab, although other brokers can be selected to execute trades. SCI does not
receive any economic benefit from these trades. Schwab does not charge custody fees.
Schwab is compensated by charging you commissions or other fees on trades that it
executes and is also compensated by earning interest on the uninvested cash in your
account in Schwab’s Cash Features Program.
Our recommendation that clients maintain their assets in accounts at Schwab is based
solely on the nature, cost or quality of custody and brokerage services provided by
Schwab regardless of any other products or services which may be provided to SCI.
Review of Accounts – Item 13
Each account is reviewed statistically, at least once each calendar or fiscal quarter by
senior staff. A time-weighted return is computed and compared to stock market and bond
market indices. Portfolios are reviewed as to composition (cash equivalents/fixed
income/equities). Consideration is given as to the adequacy of diversification relative to
the client’s objectives. The sequence of review is the order in which copies of reports
sent to clients by the investment management firms and mutual funds are received by
SCI.
Additionally, an effort is made to review client holdings at least once per calendar or fiscal
quarter in addition to the formal quarterly review. Dramatic changes in market conditions
trigger more frequent review.
Clients are provided with written performance evaluations once each calendar or fiscal
quarter. The quarterly performance evaluation states the time-weighted rate-of-return for
the most recent calendar or fiscal quarter, the calendar or fiscal year-to-date, and the
cumulative return since the inception of the counseling relationship.
If appropriate, stock and bond market indices, as well as the change in the Consumer
Price Index are scheduled to facilitate comparisons.
Client Referrals and Other Compensation – Item 14
SCI does not directly or indirectly compensate any person for client referrals.
Custody – Item 15
All clients’ accounts are held in custody by unaffiliated broker/dealers or banks, but SCI
can access many clients’ accounts through its ability to debit advisory fees. For this
reason, SCI is considered to have custody of client assets. Account custodians send
statements directly to the account owners on at least a quarterly basis. Clients should
carefully review these statements and should compare these statements to any account
information provided by SCI.
Investment Discretion – Item 16
SCI has been granted the authority by a substantial majority of its clients to determine,
without specific consent, the securities to be bought or sold and the amounts of those
securities. Any limitations which might be placed on SCI are “client specific” and, to the
extent that they exist, are detailed at the opening of the client’s account.
Voting Client Securities – Item 17
Stolper & Co. does not vote client proxies. Clients will receive proxy material directly from
the custodian holding the client’s account. Under circumstances where the SCI receives
proxy material on behalf of a client involving any security held in the client’s account, SCI
will promptly forward such material to the client’s attention. It is the client’s responsibility
to vote his/her proxy(ies). Upon client request, SCI will provide advice regarding proxy
voting.
Financial Information – Item 18
SCI has never filed for bankruptcy and is not aware of any financial condition that is
expected to affect its ability to manage client accounts.