F/m Investments, LLC (“F/m”, the “Firm”, the “Adviser”, “we”, “us” or “our”) is a Delaware Limited Liability
Company that provides discretionary investment supervisory services and other advisory services to a wide
variety of clients. F/m does business as Genoa Asset Management, LLC (“GAM”), Integrated Alpha Investments,
LLC (“Integrated Alpha”), Oakhurst Capital Management, LLC (“OCM”) and North Slope Capital, LLC (“North
Slope”).
The Adviser was founded in 2019 and is principally owned by ZCM. ZCM is a wholly owned subsidiary of FMG, a
subsidiary of 1251 Capital Group, Inc. (“1251 Capital”), a financial services holding company.
As of March 31, 2024, F/m has statutory assets under discretionary management of $12.9. billion and non-
discretionary assets of $53.6 million.
The advisory services of F/m are described in detail below.
Investment Management Services
F/m provides investment management services to institutional and individual investors through separately
managed accounts(“SMAs”), open-end mutual funds and exchange traded funds (“ETFs”), and model-based
accounts. The services involve managing each client’s account on a continuous basis and purchasing and selling
investments in the account as F/m’s professional staff deems necessary by using discretionary authority granted
to F/m by the client. Types of securities managed include stocks, bonds, options, mutual funds, and ETFs. Some
of these positions generally are used for “hedging” purposes and are designed to reduce, but not necessarily
eliminate, the risk in various client portfolios. Clients may impose restrictions on investing in certain securities or
types of securities. We manage client portfolios in accordance with their investment policies and use reasonably
available resources to comply with investment restrictions, when applicable. At our sole discretion, we will
manage legacy portfolios within a SMA.
F/m manages portfolios not involving continuous investment supervisory services. These services are provided
when F/m is retained to perform a particular function not involving specific knowledge of other assets of the client.
An example of such a service is the management of an institution’s bond portfolio, but not other securities within
the client’s investment portfolio.
F/m also provides sub-advisory services to both affiliated and unaffiliated asset managers by furnishing its
investment strategies to the asset manager’s clients. The initial investment and asset allocation recommendations
are based on the financial information gathered from, or provided by, each client including a complete Investment
Policy Statement, investment restrictions requested by the client, or overall financial condition. Based on this
information, the client is provided with initial investment recommendations designed to provide an appropriate
asset mix consistent with the client’s objectives. The client’s portfolio and its performance are then monitored by
the client’s Client Service Representative (“Client Service Rep”), and the portfolio management team, for
consistency with the client’s stated goals and objectives. Portfolio management teams will also monitor portfolios
collectively, at the strategy level. The frequency of these reviews and transactions made for a client’s accounts
are determined by the Client Service Rep. Clients are free to contact their Client Service Rep at any time if they
have questions about their accounts.
F/m does not assure or guarantee the results of its discretionary supervisory services. Thus, losses can occur
from following F/m’s advice pertaining to any investment or investment approach, including using conservative
investment strategies.
Additionally, F/m also designs and constructs specialized portfolios and provides consulting services tailored to
meet specific client mandates. F/m also acts as a Qualified Professional Asset Manager (“QPAM”) under the
Employee Retirement Income Security Act of 1974 (“ERISA”), providing requested guidance on specific
transactions related to particular assets of employee benefit plan investors.
Services to Mutual Funds and ETFs
F/m acts as an Adviser or Sub-Adviser to unaffiliated mutual funds and ETFs (known collectively as “Managed
Funds”). Interested investors should refer to each respective fund’s prospectus and statement of additional
information (“SAI”), or other similar document, for important information regarding objectives, investments, time-
horizon, risks, fees, and additional disclosures. These documents are available on-line at each fund’s website.
Prior to making any investment in any mutual
fund or ETF, investors and prospective investors should carefully
review these documents for a comprehensive understanding of the terms and conditions applicable for investment
in that fund.
Advisory Services for Wrap Programs and Model Investment Portfolios
F/m acts as a discretionary investment manager for one or more unaffiliated broker-sponsored (the “Wrap
Sponsors”) wrap-fee programs (“Wrap Programs”). Clients participating in wrap programs may be charged
various program fees in addition to the advisory fee charged by us.
F/m provides asset management services to clients that select F/m to manage their accounts through their
respective Wrap Sponsor. We manage the program accounts in accordance with their investment policies and will
use reasonably available resources to comply with investment restrictions, when applicable. There may be
differences in the performance of wrap portfolios among F/m clients and other institutional accounts invested in
similar strategies we manage for other clients, resulting from differences in the number of securities held in the
portfolio, cash availability, investment restrictions, account sizes, tax considerations, and other factors. The Wrap
Sponsor generally pays F/m a fee based on assets managed in connection with the program. The fees we receive
in connection with Wrap Programs may vary from fees charged to other clients and between Wrap Programs. For
our services, we receive a portion of the total wrap fee charged by the Wrap Sponsor.
We also provide model investment portfolios (“Models”) to various outside financial institutions (each a “Model
Provider”) for their unified managed account programs and other model-driven investment vehicles (“Model
Programs”). The Models contain our current investment recommendations as to the composition of a portfolio that
would be purchased for an account managed in accordance with the relevant investment strategy. The
recommendations generally reflect the investment recommendations and security weightings simultaneously
being made for our discretionary institutional and high-net-worth clients within the same investment strategy. The
Model Provider may implement our Model recommendations on its own trading platform for the clients that have
chosen to participate in the program. Model Providers may choose to implement some or all of our
recommendations in terms of both the securities and/or the weightings. As securities and weightings change in
the Model, those modifications are communicated to the Model Providers, consistent with our trade rotation
practices, as referenced in Item 12 – Brokerage Practices. There is no requirement that the Models be
administered as they are provided, or at all, and we generally do not monitor or supervise the Model Programs
administered by the outside Model Provider. As a result, the performance of our discretionary accounts and those
of the Models using the same investment strategy may differ for these and other reasons.
Generally, Wrap Program and Model Program accounts using the same investment strategy may perform
similarly, however, there could be performance differences between them. Performance dispersion can occur
because F/m does not have trading discretion over the Model Program accounts.
Sweep vehicle choices are determined by each custodian and we may not have tax-exempt sweep vehicles to
choose from with every custodian. This could result in tax-exempt mandates utilizing a taxable sweep vehicle and,
thereby, generating taxable income.
Other Advisory Services
F/m also provides other advisory services to high-net-worth individuals, corporations, endowments/foundations,
retirement plans, and retirement plan participants. These advisory and consulting services include: helping
formulate client investment objectives; identifying risk tolerance characteristics; developing Investment Policy
Statements; creating asset allocation strategies driven by the client’s policy or risk profile; searching for suitable
investment managers, mutual funds and/or investment products (e.g., stocks and bonds) to implement these
strategies; and continuous monitoring, evaluation and reporting on client accounts.
Portfolio Managers of client accounts may also be Portfolio Managers to mutual funds or ETFs recommended to
clients, and thus have a conflict of interest when recommending these funds to clients. F/m intends to base
recommendations on the best interests of its clients. Although F/m believes its services are competitively priced;
clients may be able to obtain similar advisory services at lower prices if purchased elsewhere.