This Disclosure document is being offered to you by Uncommon Cents Investing, LLC (“UCI”
or “Firm”) about the investment advisory services we provide. It discloses information
about our services and the way those services are made available to you, the client.
We are an investment management firm located in Janesville, Wisconsin. We specialize in
investment advisory services for individuals, high net worth individuals, employee
sponsored retirement plans, trusts and estates. Our Firm became a registered investment
adviser in September 2017. Sheena Hanson is the sole Managing Member.
We are committed to helping clients build, manage, and preserve their wealth, and to
provide assistance that helps clients to achieve their stated financial goals. We will offer an
initial complimentary meeting upon our discretion; however, investment advisory services
are initiated only after you and UCI execute an Investment Management Agreement.
Investment and Wealth Management and Supervision Services
We manage advisory accounts on a discretionary basis. For discretionary accounts, once
we have determined a profile and investment plan with a client, we will execute the day to
day transactions without seeking prior client consent. Account supervision is guided by the
written profile and investment plan of the client. Clients have the ability to place
reasonable restrictions on the types of investments that may be purchased in an account,
however we retain the right to decline to enter into a management agreement with any
clients whose investment are contrary to the firm’s investment strategies. (Please see Item
16, Investment Discretion for additional information concerning discretionary authority.)
We primarily allocate client assets among various mutual funds, ETFs, equities and debt
securities in accordance with their stated investment objectives.
During personal discussions with clients, we determine the client’s objectives, time
horizons, risk tolerance and liquidity needs. As appropriate, we also review a client’s prior
investment history, as well as family composition and background. Based on client needs,
we develop a client’s personal profile and investment plan. We then create and manage
the client’s investments based on that policy and plan.
It is the client’s obligation to notify us immediately if circumstances have changed with
respect to their goals.
Once we have determined the types of investments to be included in your portfolio and
allocated them, we will provide ongoing investment review and management services.
This approach requires us to periodically review your portfolio.
With our discretionary relationship, we will make changes to the portfolio, as we deem
appropriate, to meet your financial objectives. We trade these portfolios based on the
combination of our market views and your objectives, using our investment process. We
tailor our advisory services to meet the needs of our clients and seek to ensure that your
portfolio is managed in a manner consistent with those needs and objectives. Note there
may be periods of low trading frequency based on market conditions, tax considerations
and client objectives. You will have the ability to leave standing instructions with us to
refrain from investing in particular industries or invest in limited amounts of securities.
In all cases, you have a direct and beneficial interest in your securities, rather than an
undivided interest in a pool of securities. We do have limited authority to direct the
Custodian to deduct our investment advisory fees from your accounts, but only with the
appropriate written authorization from you.
Where appropriate, we provide advice about any type of legacy position held in client
portfolios. Typically, these are assets that are ineligible to be custodied at our primary
custodian. Clients will engage us to advise on certain investment products that are not
maintained at their primary custodian, such as variable life insurance, annuity contracts
and assets held in employer sponsored retirement plans and qualified tuition plans (i.e.,
529 plans).
You are advised and are expected to understand that our past performance is not a
guarantee of future results. Certain market and economic risks exist that adversely affect
an account’s performance. This could result in capital losses in your account.
ERISA Section 3(21) Investment Advisory Services
For employer-sponsored retirement plans with participant-directed investments, UCI
provides its advisory services as an investment advisor as defined under Section 3(21) of
the Employee Retirement Income Security Act of 1974, as amended (“ERISA”).
When serving as an ERISA 3(21) investment advisor, the plan sponsor and UCI share
fiduciary responsibility. The plan sponsor retains ultimate decision-making authority for
the investments and may accept or reject the recommendations in accordance with the
terms of a separate ERISA 3(21) Investment Advisor Agreement between UCI and the plan
sponsor. UCI can provide the following services to the plan sponsor:
• Screen investments and make ongoing recommendations.
• Monitor the investments and suggest replacement investments when appropriate.
• Assisting with identifying the Qualified Default Investment Alterative (“QDIA”)
• Provide an investment monitoring report
• Recommending Non-Discretionary Model Portfolios – asset allocation target date
or risk-based model portfolios
• Acting as a Service Liaison between
the Plan and its service providers
• Assisting with Plan Education to Plan Participants
• Conducting Plan Search or Plan Service Vendor Analysis
• Benchmarking the Plan and its fees with similar Plans in their benchmark group
Our goal in identifying the plan’s investment options is to provide a range of options that
will enable plan participants to invest according to varying risk tolerances, savings time
horizons or other financial goals. The plan's investment options may consist of mutual
funds, model portfolios, or other similar investment funds. The investment funds from
which our Firm will select from will be those that are available on the plan record-keeper’s
investment platform.
We will perform on-going monitoring of the investment options within the plan. The
ongoing monitoring of investments is a regular and disciplined process. Monitoring
confirms that the criteria remain satisfied and that an investment option continues to be
appropriate. The process of monitoring investment performance relative to specified
guidelines will be consistently applied.
We may provide periodic educational support and investment workshops designed for the
plan participants, if provided for in our Agreement with the Plan Sponsor. Topics to be
discussed will be determined in conjunction with the Plan Sponsor and in accordance with
guidelines established in ERISA 404(c). The educational support or investment workshops
will not provide plan participants with individualized, tailored investment advice or
individualized, tailored asset allocation recommendations.
Disclosure Regarding Rollover Recommendations
A client or prospect 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) rollover 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). Our Firm may recommend an investor
roll over plan assets to an IRA for which our Firm provides investment advisory services.
As a result, our Firm and its representatives may earn an asset-based fee. In contrast, a
recommendation that a client or prospective client leave their plan assets with their
previous employer or roll over the assets to a plan sponsored by a new employer will
generally result in no compensation to our Firm. Our Firm therefore has an economic
incentive to encourage a client to roll plan assets into an IRA that our Firm will manage,
which presents a conflict of interest. To mitigate the conflict of interest, there are various
factors that our Firm will consider before recommending a rollover, including but not
limited to: (i) the investment options available in the plan versus the investment options
available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an
IRA, (iii) the services and responsiveness of the plan’s investment professionals versus
those of our Firm, (iv) protection of assets from creditors and legal judgments, (v) required
minimum distributions and age considerations, and (vi) employer stock tax consequences,
if any. All rollover recommendations are reviewed by our Firm’s Chief Compliance Officer
and remains available to address any questions that a client or prospective client has
regarding the oversight.
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide
investment advice to you regarding your retirement plan account or individual retirement
account, we are also fiduciaries 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. We have to act in your best interest and not put our
interest ahead of yours. At the same time, the way we make money creates some conflicts
with your interests.
Consulting Services
We also provide clients investment advice on a more-limited basis on one-or-more isolated
areas of concern such as estate planning, real estate, retirement planning, or any other
specific topic. Additionally, we provide advice on non-securities matters about the
rendering of estate planning, insurance, real estate, and/or annuity advice or any other
business advisory / consulting services for equity or debt investments in privately held
businesses. In these cases, you will be required to select your own investment managers,
custodian and/or insurance companies for the implementation of consulting
recommendations. If your needs include brokerage and/or other financial services, we will
recommend the use of one of several investment managers, brokers, banks, custodians,
insurance companies or other financial professionals ("Firms"). You must independently
evaluate these Firms before opening an account or transacting business and have the right
to effect business through any firm you choose. You have the right to choose whether to
follow the consulting advice that we provide.
Wrap Fee Program
We do not participate in a Wrap Fee Program.
Assets
As of December 31, 2022, our firm managed $310,031,088 in assets under discretionary
management and $4,385,904 in assets under non-discretionary management.