A. Description of the Advisory Firm
B. Types of Advisory Services
Sub-Advisory Services
LIM also acts as a sub-adviser to other investment firms. When serving as sub-adviser,
depending on the terms of the sub-advisory agreement, LIM may not have a direct
relationship with clients of these firms and may not have contact with those clients. These
firms are responsible for establishing the financial circumstances, investment objectives
and investment restrictions of each sub-advised client. The advisory agreement will be
between the client and the respective firm and will dictate the terms and conditions of the
relationship, including the fees paid to and services provided by or through the respective
firm.
Retirement Rollovers
A client or prospective client leaving an employer typically has four options regarding an
existing retirement plan (and may engage in a combination of these options): (i) leave the
money in the former employer’s plan, if permitted, (ii) roll over the assets to the new
employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an
Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could,
depending upon the client’s age, result in adverse tax consequences). When LIM provides
rollover advice to a client or prospect regarding a retirement plan account or individual
retirement account, LIM is acting as a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. If LIM recommends that a
client roll over their retirement plan assets or transfer an IRA into an account to be
managed by LIM, and LIM will earn an advisory fee on the rolled over assets, that
recommendation creates a conflict of interest. Accordingly, LIM operates under a special
rule that requires LIM to act in the client or prospects best interest and not put LIM’s
interest ahead of the clients or prospects. No client is under any obligation to roll over
retirement plan assets or transfer IRA assets to an account managed by LIM. LIM’s Chief
Compliance Officer, Thayne Gould, remains available to address any questions that a
client or prospective client may have regarding the conflict of interest presented by such
rollover recommendation.
When appropriate, LIM will tailor a program for an 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 LIM on behalf of the client. LIM may use “model portfolios”
together with a specific set of recommendations for each client based on their personal
restrictions, needs, and targets. Clients generally may impose restrictions in investing in
certain securities or types of securities in accordance with their values or beliefs. However,
if the restrictions prevent LIM from properly servicing the client account, or if the
restrictions would require LIM to deviate from its standard suite of services, LIM reserves
the right to end the relationship.
C. Client Tailored Services
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. LIM does not participate in any wrap fee programs.
LIM has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$601,915,331 $2,038,704 December 31, 2023
Asset-Based Fees for Portfolio Management
Total Assets Under Management Annual Fee
$0 - $10,000,000 1.00%
$10,000,001 - $30,000,000 0.90%
$30,000,001+ 0.80%
LIM utilizes a tiered billing structure wherein a client’s total assets under management
are charged the corresponding fee rate in accordance with the fee schedule above. Should
the client’s total assets under management exceed the designated range of a given tier, the
excess amount will be charged at the fee rate identified in the succeeding tier. For clients
with multiple accounts under LIM’s management, all related accounts are aggregated to
determine the fee rate and a blended rate is then applied to each account. These fees are
generally negotiable and may vary by client. The final governing fee schedule is attached
as Exhibit II of the Investment Advisory Contract for each client. Clients may terminate
the agreement without penalty for a full refund of LIM's fees within five business days of
signing the Investment Advisory Contract. Thereafter, clients may terminate the
Investment Advisory Contract immediately upon written notice.
LIM bills based on the balance, to include any margin balances which are being actively
managed, on the first day of the billing period.
Sub-Advisory Services Fees
The fee arrangement for managing assets for other investment firms will be negotiated
for each corporate relationship.