Fielder offers a variety of advisory services, which include investment advisory, family office, and
retirement plan services. Prior to Fielder rendering any of the foregoing advisory services, clients are
required to enter into one or more written agreements with Fielder setting forth the relevant terms and
conditions of the advisory relationship (the “Advisory Agreement”).
Fielder is the successor entity of Fielder Management, Inc., which was formed in 2009. Frank C. Byrd III
is the Managing Member, Chief Compliance Officer and 61.66% owner of Fielder. Stephen L. Korn is the
Chief Investment Officer and 33.34% owner of Fielder. Nathan R. Frigge is Partner and 5% owner of
Fielder.
Fielder had $834,551,544 in assets under management, $790,263,139 of which is managed on a
discretionary basis and $44,288,405 of which is managed on a non-discretionary basis (as of March 7,
2024). In addition, Fielder had $ $48,418,673 in assets under advisement (as of March 7, 2024).
While this brochure generally describes the business of Fielder, certain sections also discuss the activities
of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying
a similar status or performing similar functions), employees or any other person who provides investment
advice on Fielder’s behalf and is subject to the Firm’s supervision or control.
Investment Advisory Services
Fielder manages client investment portfolios on a discretionary or non-discretionary basis.
Fielder manages portfolios on a discretionary basis based upon the client’s objectives, risk tolerance, time
horizon and other related factors. For discretionary accounts, Fielder typically constructs a strategic
allocation of assets, primarily among individual equity and debt securities, mutual funds (including interval
funds), exchange-traded funds (“ETFs”), variable annuity products and Independent Managers (as defined
below). Fielder can invest in private placement securities, which can include debt, equity, and/or pooled
investment vehicles for the clients who are “accredited investors” as defined under Rule 501 of the
Securities Act of 1933, as amended, when consistent with the clients’ investment objectives. While Fielder
does not currently employ the use of futures or options as a part of its strategy, it has the ability to do so
should circumstances warrant their use in the future. Fielder can also provide advice about any other type
of investment held in clients’ portfolios.
Fielder can also render non-discretionary investment management services to clients. This can relate to
assets held in clients’ individual employer-sponsored retirement plans, variable life/annuity products that
they own, and/or 529 plans or other products which are not held by the clients’ primary custodians. In so
doing, Fielder either directs or recommends the allocation of client assets among the various investment
options that are available within the product. Client assets are maintained at the specific insurance company
or custodian designated by the product’s provider. Fielder can also provide nondiscretionary advice about
any other type of investments otherwise held by clients. Fielder also provides specialized investment
management services on an individually-negotiated basis on behalf of certain clients.
Fielder tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a
continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives.
Fielder consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time
horizon, liquidity constraints and other related factors relevant to the management of their portfolios.
Clients are advised to promptly notify Fielder if there are changes in their financial situation or if they wish
to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions
or mandates on the management of their accounts if Fielder determines, in its sole discretion, the conditions
would not materially impact the performance of a management strategy or prove overly burdensome to the
Firm’s management efforts.
Retirement Plan Rollover Recommendations
When Fielder provides investment advice about a client’s retirement plan account or individual retirement
account (“IRA”) including whether to maintain investments and/or proceeds in the retirement plan account,
roll over such investment/proceeds from the retirement plan account to an IRA, or make a distribution from
the retirement plan account, we acknowledge that Fielder is a “fiduciary” within the meaning of Title I of
the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”) as
applicable, which are laws governing retirement accounts. Fielder operates under a special rule that requires
Fielder to act in a client’s best interest and not put Fielder’s interest ahead of a client’s.
Under this special rule’s provisions, Fielder must act as a fiduciary to a retirement plan account or IRA
under ERISA/IRC, which requires that Fielder:
• Meet a professional standard of care when making investment recommendations (e.g., give
prudent advice);
• Never put the financial interests of Fielder ahead of a client when making recommendations
(e.g., give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that Fielder gives advice that is in the
client’s best interest;
• Charge no more than is reasonable for the services of Fielder; and
• Give a client basic information about conflicts of interest.
To the extent Fielder recommends a client roll over the client’s account from a current retirement plan
account to an individual retirement account managed by Fielder, please know that Fielder and its investment
adviser representatives have a conflict of interest.
Fielder can earn increased investment advisory fees by recommending that a client roll over their account
at the retirement plan to an IRA managed by Fielder. Fielder will earn fewer investment advisory fees if a
client does not roll over the funds in the retirement plan to an IRA managed by Fielder.
Thus, Fielder’s investment adviser representatives have an economic incentive to recommend a rollover of
funds from a retirement plan to an IRA. This is a conflict of interest because Fielder’s recommendation that
a client open an IRA account to be managed by Fielder can be based on Fielder’s economic incentive and
not based exclusively on whether or not moving the IRA to Fielder’s management program is in the client’s
overall best interest.
Fielder has taken steps to manage this conflict of interest. Fielder has adopted an impartial conduct standard
whereby the investment adviser representatives will (i) provide investment advice to a retirement plan
participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status
described below, (ii) not recommend investments which result in Fielder receiving unreasonable
compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose
compensation received by Fielder and Fielder’s supervised persons and any material conflicts of interest
related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making
any materially misleading statements regarding such rollover.
When providing advice to a client regarding a retirement plan account or IRA, Fielder investment advisor
representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing
that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of
an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance,
financial circumstances, and a client’s needs, without regard to the financial or other interests of Fielder or
its affiliated personnel.
Use of Independent Managers
As mentioned above, Fielder selects certain Independent Managers to actively manage a portion of its
clients’ assets. The specific terms and conditions under ©h a client engages an Independent Manager may
be set forth in a separate written agreement with the designated Independent Manager. In addition to this
brochure, clients can also receive the written disclosure documents of the respective Independent Managers
engaged to manage their assets.
Fielder evaluates a variety of information about Independent Managers, ©h ©es the Independent Managers’
public disclosure documents, materials supplied by the Independent Managers themselves, and other third-
party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent
Managers’ investment strategies, past performance, and risk results in relation to its clients’ individual
portfolio allocations and risk exposure. Fielder also takes into consideration each Independent Manager’s
management style, returns, reputation, financial strength, reporting, pricing and research capabilities,
among other factors.
Fielder continues to provide services relative to the discretionary or non-discretionary selection
of the
Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being
managed by Independent Managers. Fielder seeks to ensure the Independent Managers’ strategies and
target allocations remain aligned with its clients’ investment objectives and overall best interests.
Family Office Services
Fielder can provide clients with financial planning, investment advisory, reporting, and administration
services under the firm’s Family Office Services, which address any or all of the following:
• Financial planning:
o Guide proactive planning for client’s family (cash flow, tax, risk, estate, legacy, philanthropy,
etc.)
o Facilitating and coordinating client’s team of experts (such as attorney, CPA, insurance agent,
etc.)
• Investment advisory:
o Portfolio management and investment counseling
o Sourcing, vetting, and facilitating public and private investments
• Reporting:
o Consolidated reporting on client’s accounts and private funds (including performance, cash
flows, attribution, and asset allocation)
• Administration:
o Tracking, collecting, and facilitating delivery of K1’s and 1099’s to client’s tax professional
o Facilitating wire transfers or ACH for bill payment, capital calls, charitable donations, etc.
o Providing centralized, secure archiving and organization of clients’ important documents
(wills, trusts, deeds, titles, etc.)
Fielder’s recommendations are based upon each client’s individual objectives, time horizon, risk tolerance,
and other related factors. In performing these services, Fielder is under no obligation to verify any
information provided by the client or by the client’s other professionals (such as attorney or accountant).
Fielder is expressly authorized to rely on such information. Fielder can recommend its own services as well
as those of other professionals to implement its recommendations. Clients are advised that a conflict of
interest exists if Fielder recommends its own services. The client is under no obligation to act upon any of
the recommendations made by Fielder under a financial planning or consulting engagement, nor is the client
obliged to engage the services of any recommended professional, including Fielder itself. The client is free
to accept or reject any of Fielder’s recommendations and has complete discretion regarding the
implementation of such recommendations. It is the client’s responsibility to promptly notify Fielder of any
changes in their financial situation or financial objectives so that Fielder can review and revise its prior
recommendations and/or current services.
Retirement Plan Services
Fielder offers retirement plan services to retirement plan sponsors and to individual participants in
retirement plans. For a corporate sponsor of a retirement plan, our retirement plan services can include, but
are not limited to, the following services:
Fiduciary Management Services
Fielder provides clients with the following Fiduciary Retirement Plan Management Services:
• Discretionary Management Services. Fielder will provide the client with continuous and ongoing
supervision over the designated retirement plan assets. Fielder will actively monitor the designated
retirement plan assets and provide advice regarding buying, selling, reinvesting or holding
securities, cash or other investments of the Plan. We have discretionary authority to make all
decisions to buy, sell or hold securities, cash or other investments for the designated retirement
plan assets in our sole discretion without first consulting with the client. We also have the power
and authority to carry out these decisions by giving instructions, on a client’s behalf, to brokers and
dealers and the qualified custodian(s) of the Plan for our management of the designated retirement
plan assets.
• Discretionary Investment Selection Services. Fielder will monitor the investment options of the
Plan and add or remove investment options for the Plan. Fielder will have discretionary authority
to make all decisions regarding the investment options that will be made available to Plan
participants.
When a client elects to utilize any of Fielder’s Fiduciary Management Services, then Fielder will be acting
as an Investment Manager to the Plan, as defined by ERISA section 3(38), with respect to our Fiduciary
Management Services, and Fielder hereby acknowledges that it is a fiduciary with respect to its Fiduciary
Management Services.
Securities and other types of investments all bear different types and levels of risk. Those risks are typically
discussed with clients in defining the investment policies and objectives that will guide investment
decisions for their qualified plan accounts. Upon request, as part of our retirement plan services, we can
discuss those investments and investment strategies that we believe tend to reduce these risks for a particular
client’s circumstances or for plan participants.
Clients and plan participants must realize that obtaining higher rates of return on investments entails
accepting higher levels of risk. Based upon discussions with the client, we will attempt to identify the
balance of risks and rewards that is appropriate and comfortable for the client and other employees. It is
still the clients’ responsibility to ask questions if the client does not fully understand the risks associated
with any investment. All plan participants are strongly encouraged to read prospectuses, when applicable,
and ask questions prior to investing.
We strive to render our best judgment for clients. Still, Fielder cannot assure that investments will be
profitable or assure that no losses will occur in their portfolios. Past performance is an important
consideration with respect to any investment or investment advisor, but it is not necessarily an accurate
predictor of future performance.
Fielder will disclose, to the extent required by ERISA Regulation Section 2550.408b-2©, to the client any
change to the information that we are required to disclose under ERISA Regulation Section 2550.408b-
2©(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which we are informed
of the change (unless such disclosure is precluded due to extraordinary circumstances beyond our control,
in which case the information will be disclosed as soon as practicable).
In accordance with ERISA Regulation Section 2550.408b-2©(vi)(A), we will disclose within thirty (30)
days following receipt of a written request from the responsible plan fiduciary or Plan Administrator (unless
such disclose is precluded due to extraordinary circumstances beyond our control, in which case the
information will be disclosed as soon as practicable) all information related to the Qualified Retirement
Plan Agreement and any compensation or fees received in connection with the Agreement that is required
for the Plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the
regulations, forms and schedules issued thereunder.
If we make an unintentional error or omission in disclosing the information required under ERISA
Regulation Section 2550.408b-2©(1)(iv) or (vi), we will disclose to the client the correct information as
soon as practicable, but no later than thirty (30) days from the date on which we learned of such error or
omission.
Retirement Plan Participant Services
We provide an additional service directly to participants of retirement plan accounts where Fielder has
discretion and may leverage an Order Management System to implement tax-efficient asset location and
opportunistic rebalancing strategies on behalf of the client. These are primarily 401(k) accounts. We
regularly review the available investment options in these accounts, monitor them, and rebalance and
implement our strategies in the same way we do other accounts, though using different tools as necessary.
Through an arrangement with Pontera Solutions Inc. (formerly known as “FeeX, Inc.”), an unaffiliated
third-party, Fielder is able to gain access to clients’ accounts not held at one of our primary brokerage
platforms using the Pontera Order Management System software, to facilitate discretionary investment
management of and execute trade orders for retirement plan participant accounts such as 401k or 403b
accounts). If clients choose to grant Pontera Solutions Inc. access to these accounts, Fielder can regularly
review the investment options in the accounts, as well as monitor, rebalance, and trade them to implement
investment strategies the same way we do for their other accounts under our management.
Administrative Services Provided by Orion Advisor Services, LLC
Fielder has contracted with Orion Advisor Services, LLC (referred to as “Orion”) to utilize its technology
platforms to support data reconciliation, performance reporting, fee calculation and billing, client database
maintenance, quarterly performance evaluations, and other functions related to the administrative tasks of
managing client accounts. Due to this arrangement, Orion will have access to client accounts, but Orion
will not serve as an investment adviser to Fielder clients. Clients will not incur additional fees with the
firm’s use of Orion.