A. Description of the Advisory Firm
Flower City Capital LLC (hereinafter “FCC”) is a Limited Liability Company organized
in the State of New York.
The firm was formed in August 2015, and the principal owners are Michael Rizzolo,
Thomas Hawks and Vincent Crane.
B. Types of Advisory Services
Portfolio Management Services
FCC offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. FCC 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
FCC evaluates the current investments of each client with respect to their risk tolerance
levels and time horizon. FCC 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.
FCC seeks to provide that investment decisions are made in accordance with the fiduciary
duties owed to its accounts and without consideration of FCC’s economic, investment or
other financial interests. To meet its fiduciary obligations, FCC attempts to avoid, among
other things, investment or trading practices that systematically advantage or
disadvantage certain client portfolios, and accordingly, FCC’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 FCC’s policy to allocate investment
opportunities and transactions it identifies as being appropriate and prudent, including
initial public offerings ("IPOs") and other investment opportunities that might have a
limited supply, among its clients on a fair and equitable basis over time.
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
FCC generally limits its investment advice to mutual funds, fixed income securities, real
estate funds (including REITs), insurance products including annuities,
equities, ETFs
(including ETFs in the gold and precious metal sectors), treasury inflation
protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds
and private placements, although FCC primarily recommends equity to a majority of its
clients. FCC may use other securities as well to help diversify a portfolio when applicable.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or
individual retirement account, we are 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. The way we make money
creates some conflicts with your interests, so we operate under a special rule that requires
us to act in your best interest and not put our interest ahead of yours. Under this special
rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put our financial interests ahead of yours when making recommendations
(give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in
your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
C. Client Tailored Services and Client Imposed Restrictions
FCC 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 FCC on behalf of the client. Concentrated positions in individual securities /
funds are also considered. Pre-existing investments such as annuities as well as retirement
plan allocations are taken into account. FCC may use “model portfolios” together with a
specific set of recommendations for each client based on their personal restrictions, needs,
and targets. Clients may not impose restrictions in investing in certain securities or types
of securities in accordance with their values or beliefs.
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. FCC does not participate in any wrap fee programs.
E. Assets Under Management
FCC has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$ 249,558,522 $ 21,233,850 December 2023