Overview
A. Description of the Advisory Firm
Front Row Advisors LLC d/b/a GenCap Portfolio Management (hereinafter “FRA
LLC”) is a Limited Liability Company organized in the State of California.
The firm was formed in July 2015, and the principal owner is GenCap Partners LLC.
B. Types of Advisory Services
Portfolio Management Services
FRA LLC offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. FRA LLC creates an Investment
Policy Statement for each client, which outlines the client’s current situation (income, tax
levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a
portfolio that matches each client's specific situation. Portfolio management services
include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring
FRA LLC evaluates the current investments of each client with respect to their risk
tolerance levels and time horizon. FRA LLC will request discretionary authority from
clients in order to select securities and execute transactions without permission from the
client prior to each transaction. Risk tolerance levels are documented in the Investment
Policy Statement, which is given to each client.
FRA LLC seeks to provide that investment decisions are made in accordance with the
fiduciary duties owed to its accounts and without consideration of FRA LLC’s economic,
investment or other financial interests. To meet its fiduciary obligations, FRA LLC
attempts to avoid, among other things, investment or trading practices that systematically
advantage or disadvantage certain client portfolios, and accordingly, FRA LLC’s policy is
to seek fair and equitable allocation of investment opportunities/transactions among its
clients to avoid favoring one client over another over time. It is FRA LLC’s policy to
allocate investment opportunities and transactions it identifies as being appropriate and
prudent among its clients on a fair and equitable basis over time.
Subadviser Services
FRA LLC may also act as a subadviser to advisers unaffiliated
with FRA LLC. These third-
party advisers would outsource portfolio management services to FRA LLC. This
relationship will be memorialized in each contact between FRA LLC and the third-party
adviser.
Financial Planning
Financial plans and financial planning may include, but are not limited to: investment
planning; life insurance; tax concerns; retirement planning; college planning; and
debt/credit planning.
Services Limited to Specific Types of Investments
FRA LLC generally limits its investment advice to mutual funds, fixed income securities,
real estate funds (including REITs), insurance products including annuities, equities,
ETFs, treasury inflation protected/inflation linked bonds, commodities and non-U.S.
securities, although FRA LLC primarily recommends equities to a majority of its clients.
FRA LLC may use other securities as well to help diversify a portfolio when applicable.
C. Client Tailored Services and Client Imposed Restrictions
FRA LLC will tailor a program for each individual client. This will include an interview
session to get to know the client’s specific needs and requirements as well as a plan that
will be executed by FRA LLC on behalf of the client. FRA LLC may use “model portfolios”
together with a specific set of recommendations for each client based on their personal
restrictions, needs, and targets. Clients may impose restrictions in investing in certain
securities or types of securities in accordance with their values or beliefs. However, if the
restrictions prevent FRA LLC from properly servicing the client account, or if the
restrictions would require FRA LLC to deviate from its standard suite of services, FRA
LLC reserves the right to end the relationship.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, fund expenses, and other administrative
fees. FRA LLC does not participate in any wrap fee programs.
E. Assets Under Management
FRA LLC has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$276,667,677.00 $32,553,614.00 December 2023