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Code of Conduct

Advisor shall treat clients, as he would want to be treated if the roles were reversed. This practice shall include but not be limited to the following:

  • Advisor shall be honest and deal fairly with clients and prospects.
    • Advisor must act with reasonable care and exercise prudent judgment.
    • Advisor must not engage in any professional conduct involving dishonesty, fraud, or deceit.
    • Advisor must not knowingly misrepresent any analysis, recommendation, action or other professional activity.
  • Advisor must act in the financial interest of clients before his own.
    • When Advisor buys or sells the same securities for clients and his own account, he shall make client transactions first, or if transactions are made simultaneously clients shall get the same price or a better price than Advisor.
    • Advisor shall not place client funds in any investment where Advisor receives income or benefit that does not come directly from client and with client’s prior knowledge.
    • Advisor shall not cause client’s account to be charged higher fees or commissions by custodian in order to receive services, products or research from custodian.
    • Advisor shall not take any investment position where a move in a security’s price benefits him while harming a client.
  • Advisor shall disclose all fees, potential conflicts of interest and any other material information appropriate for clients or prospects to know.
  • Advisor shall strive to remain independent and objective.
    • Advisor shall not offer, solicit, or accept any gift, benefit, compensation, or consideration that reasonably could be expected to compromise his or another’s independence and objectivity.
    • Advisor shall perform independent analysis aimed at keeping investment recommendations based on fact and not swayed by fads or the opinions of others who may have undisclosed objectives that conflict with client’s interest.
  • Advisor shall deal with a reputable custodian with adequate insurance to hold the assets of client’s account.
  • Advisor shall strive to be aware of and in compliance with relevant Federal and state law.
  • If Advisor possesses material nonpublic i.e. inside information that could affect the value of an investment he shall not act or cause others to act on the information.

Disclosure Brochure

Money Management Agreement