A. Business Commencement Date
Phraction was organized in August of 2018 to offer investment management services.
B. Ownership
Mapfair LLC owns a majority membership interest in Phraction. Mr. Jason Stollman is the sole
member and manager of Mapfair LLC.
C. Services
DISCRETIONARY ACCOUNTS. We provide personalized discretionary investment
management services. Clients are asked to provide us with information with respect to their
financial and investment profile, including current financial holdings, investment preferences and
objectives, risk tolerance, present and long-term liquidity needs, investment time horizon(s), wealth
planning needs and objectives, insurance coverage requirements, and tax status. We will also
inquire as to the restrictions, if any, the client wishes to impose on the management of the advisory
account. From the information supplied by the client, we formulate and pursue a customized asset
allocation and investment strategy that we believe is suitable and will help the client achieve the
stated investment objectives. We actively manage the discretionary account on an ongoing basis
in accordance with the account’s objective(s) and in consideration of the client’s investment time
frame and risk tolerance. Account monitoring is performed on a continual basis. See Item 8A for
information about our analysis method. See Item 13 for additional information about account
monitoring and reviews. As dictated by the client, we will also provide advisory services regarding
family governance, estate planning, and intergenerational wealth transfer. We do not provide legal
or tax advice. Clients are encouraged to consult with their legal or tax attorneys or advisers
regarding legal and tax matters.
LIMITED DISCRETIONARY ACCOUNTS. We also offer limited-discretionary advisory services
tailored to the client’s needs. As with the discretionary accounts, clients are asked to provide us
with information regarding their financial profile (as detailed above) and any restrictions the client
wishes to impose on the management of the accounts. For limited-discretionary accounts, we will
recommend and investment strategy, allocation mix, or changes to the client’s existing portfolio
that we believe is suitable for that client. Account monitoring is performed on a continual basis. See
ITEM 13 for additional information about account monitoring and reviews. On an ongoing basis,
we made buy/sell recommendations to the client as appropriate, based on the clients financial and
investment profile and investment objectives. Where the client approves of a recommendation, we
will arrange to the effect the recommended transaction(s) in the clients account using a limited
power of attorney granted to us by the client. We will prove advice regarding family governance,
estate planning, and intergenerational wealth transfer as requested by the client. We do not provide
legal or tax advice. Clients are encouraged to consult with their legal or tax attorneys or advisers
regarding legal and tax matters.
MANAGER SELECTION. We offer ongoing portfolio manager evaluation and selection services
where we obtain the authority from the client to retain and terminate the services of third-party
portfolio managers on a discretionary basis and reallocate assets between or among portfolio
managers. At the inception of the advisory relationship, we perform a comprehensive review of
the portfolio managers managing the client assets. We evaluate, among other things, each
manager’s investment style and style consistency, tenure and expertise, risk philosophy, and track
record in each specific investment strategy followed. We routinely communicate with the portfolio
managers regarding the client’s account. We undertake a formal evaluation of the manager (or
manager’s team) at least quarterly, or more often if significant economic events or market volatility
dictates. Upon the conclusion of each review, we determine whether to terminate the services of
the portfolio manager(s), retain new portfolio manager(s),
and/or reallocate assets among managers.
We immediately communicate to the client when a change is determined and prepare the necessary
documents to effect the change.
CONSOLIDATED REPORTS. We provide consolidated report services to clients upon request.
Although we do not charge a separate fee for this service, where the client pays a fixed fee for the
advisory services, the determination of the fixed fee to be charged will be based, in part, upon the
number of accounts that will be included in the consolidated reports as well as the work involved
in obtaining valuations for the assets. The client determines which assets will be included in the
consolidated reports and can request that we include information about accounts or assets for which
we do not provide investment management services. The consolidated reports are provided on
intervals mutually agreed to by the client and us.
SUB-ADVISORY SERVICES. We provide advice and investment recommendation services to
certain other investment advisors in connection with the management of their client portfolios. The
investment advisor furnishes to us their clients’ information such as investment objectives, risk
tolerances, time horizons, liquidity needs, investment restrictions and management expectations. If
the sub-advisory arrangement is discretionary in nature, we manage their clients’ assets directly
consistent with the client profiles. Otherwise, we provide to the investment advisor advice and
recommendations regarding the investments and investment strategies consistent with the
information provided. For non-discretionary arrangements, the investment advisor determines
whether to implement our advice and recommendations and we do not have the authority to place
orders for the account assets or otherwise manage the accounts directly.
CONSULTING. We provide non-discretionary services to one or more entities, which services
may include (1) periodically providing research and/or reports concerning general economic
conditions and/or types of securities, (2) making investment buy/sell suggestions or
recommendations, (3) suggesting asset allocation mixes, and/or (4) non-discretionary portfolio
management advice regarding the selection of investment securities and/or investment vehicles and
the quantities or amounts of securities or other interests to be purchased, leveraged, transferred,
exchanged, traded and/or sold by certain customers of the entity consistent with and based on our
analyses of the investment requirements and objectives adopted by the customer and communicated
to us by the entity/individual (either directly or through a reporting system to which the entity gives
us access). We also provide similar non-discretionary services for individual (natural person)
accounts which may include advice regarding family governance, estate/financial planning, and
intergenerational wealth transfer as requested by the client. The client is free to implement or
disregard in whole or in part any recommendations, advice or suggestions we make. We do not
arrange for or effect any transactions for any of the entity’s accounts or its customers’ accounts or
for the individual client.
INVESTMENT PRODUCT TYPES. Generally, the Firm’s investment advice is confined to the
following universe of securities and products:
▪ Exchange listed securities;
▪ Securities traded over-the-counter;
▪ Securities issued by foreign issuers, including foreign sovereign debt instruments;
▪ Preferred stock;
▪ Emerging market securities;
▪ Corporate debt securities;
▪ U.S. government securities;
▪ Open-end mutual funds (foreign and domestic);
▪ Closed-end funds;
▪ Exchange-traded funds;
▪ Private equity funds and hedge funds;
▪ Options contracts;
▪ Futures contracts;
▪ Interests in REITs; and
▪ Interests in private placements.
D. Wrap Fee Program
We do not participate in any wrap fee programs.
E. Assets Under Management
As of December 2023, we were managing approximately US $ 450,985,988.00 on a discretionary
basis.