Management Responsibility
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All client accounts are reviewed on an ongoing basis by Mr. Whitcraft and Mr. Thompson to ensure that your needs and objectives are being monitored and adhering to your stated investment goals and guidelines. Cash needs will be adjusted as necessary. In addition, you will receive monthly and/or quarterly statements from the custodian brokerage firm where your securities and cash are held. Each statement will summarize the specific investments currently held, the value of your portfolio, account transactions and portfolio performance. Throughout our communication process, we strongly recommend that you periodically review your financial situation with us. Material changes in your personal circumstances, the general economy, or tax law changes could trigger adjustments to your investment objectives and it is very important that you keep us informed. |
Code of Ethics
As a fiduciary, the Company has an affirmative duty to render continuous unbiased investment advice and at all times act in your best interest. To maintain this ethical responsibility to you, the Company has adopted a Code of Ethics that establishes the fundamental principles of conduct and professionalism expected by all personnel in discharging their duties. This Code is a value-laden guide committing such persons to uphold the highest ethical standards, rooted in the most elementary maxim.
To help you understand our ethical culture and standards and how we control sensitive information, a copy of our Code of Ethics is available for your review upon request.
Client Transactions
We have a fiduciary duty to ensure that your welfare is not subordinated to any interests of ours or any of our personnel. The following disclosures are internal guidelines we have adopted to assist us in protecting all of our clientele.
Participation or Interests
It is against our policies for any owners, officers, or employees to invest with you or with a group of clients, or to advise you or a group of clients to invest in a private business interest or other non-marketable investment unless prior approval has been granted by Mr. Whitcraft and the client and such investment is not in violation of any SEC and/or State rules and regulations. Employees are permitted to personally invest their own monies in stocks (OTC and Listed), bonds, investment company products and other publicly traded securities, which may also be, from time to time, recommended to you. Such investment purchases are independent of, and are not connected in any way to, investment decisions made on behalf of the Company’s clients. Personal trading activities conducted by Company officers, directors and employees are monitored by Mr. Whitcraft to ensure that such activities do not impact upon your security or create conflicts of interest. |
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Financial Industry Activities & Affiliations
The Company has a custodial and brokerage relationship with Charles Schwab & Company, Inc. (“Schwab”), a licensed broker-dealer (member Financial Industry Regulatory Authority). Currently, all managed accounts of the Company are maintained with Schwab though clients may request other custodians.
We have selected Schwab as our custodian of choice based on Schwab’s competitive transaction charges, our familiarity with Schwab’s trading platform, and on-line services for account administration and operational support.
The Company is not a subsidiary of, or affiliated with Schwab in any manner. The Company is solely responsible for the investment advice rendered, and advisory services are provided separately and independently of the brokerage firm.
