ACP provides investment management services. Prior to engaging ACP to provide any of the
foregoing investment advisory services, the client is required to enter into one or more written
agreements with ACP setting forth the terms and conditions under which ACP renders its services
(collectively the “Agreement”).
ACP has been conducting its advisory business since June 2012 and is currently owned by Adam Scott
and Joshua Rudoy.
This Disclosure Brochure describes the business of ACP. Certain sections will also describe the
activities of Supervised Persons. Supervised Persons are any of ACP’s officers, partners, directors (or
other persons occupying a similar status or performing similar functions), or employees, or any other
person who provides investment advice on ACP’s behalf and is subject to ACP’s supervision or
control.
Investment Management Services
Clients can engage ACP to manage all or a portion of their assets on a discretionary basis. As further
discussed in response to Item 8, ACP primarily allocates clients’ investment management assets
among index funds, and individual debt and equity securities. ACP also provides advice about any
type of investment held in clients' portfolios.
ACP also may render investment management services to discretionary clients on those accounts
which are not charged an annual management fee relative to variable life/annuity products that they
may own, their individual employer-sponsored retirement plans, and/or 529 plans or other products
that may not be held by the client’s primary custodian. In so doing, ACP either directs or recommends
the allocation of client assets among the various investment options that are available with the
product. Client assets are maintained at the specific insurance company or custodian designated by
the product.
ACP tailors its advisory services to the individual needs of clients. ACP consults with clients initially
and on an ongoing basis to determine risk tolerance, time horizon and other factors that may impact
the clients’ investment needs. ACP ensures that clients’ investments are suitable for their investment
needs, goals, objectives and risk tolerance.
Clients are advised to promptly notify ACP if there are changes in their financial situation or
investment objectives or if they wish to impose any reasonable restrictions upon ACP’s management
services. Clients may impose reasonable restrictions or mandates on the management of their
account (e.g., require that a portion of their assets be invested in socially responsible funds) if, in
ACP’s sole discretion, the conditions will not materially impact the performance of a portfolio
strategy or prove overly burdensome to its management efforts.
Financial Planning & Consulting
Our firm provides a variety of standalone financial planning and consulting services to clients for the
management of financial resources based upon an analysis of current situation, goals, and objectives.
Financial planning services will typically involve preparing a financial plan or rendering a financial
consultation for clients based on the client’s financial goals and objectives. This planning or
consulting may encompass Investment Planning, Retirement Planning, Estate Planning, Charitable
Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study,
ADV Part 2A – Firm Brochure Page 5 Argyle
Capital Partners, LLC
Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of
Credit Evaluation, or Business and Personal Financial Planning.
Written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients.
Implementation of the recommendations will be at the discretion of the client. As requested by our
clients our firm provides a written summary of the clients financial situation and our observations.
Financial consultations are not typically accompanied by a written summary as the process is less
formal than the planning service. Further, it is important to note that this service is not offered on a
standalone basis and is only available on a complimentary basis when requested by our Wrap Asset
Management Clients.
Retirement Plan Consulting
Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing
basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing,
monitoring and reviewing their company's participant-directed retirement plan. As the needs of the
plan sponsor dictate, areas of advising could include: investment options, plan structure and
participant education.
Retirement Plan Consulting services typically include:
i. Establishing an Investment Policy Statement – Our firm will assist in the development a
statement that summarizes the investment goals and objectives along with the broad
strategies to be employed to meet the objectives.
ii. Investment Options – Our firm will work with the Plan Sponsor to evaluate existing
investment options and make recommendations for appropriate changes.
iii. Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation
models to aid Participants in developing strategies to meet their investment objectives, time
horizon, financial situation and tolerance for risk.
iv. Investment Monitoring – Our firm will monitor the performance of the investments and
notify the client in the event of over/underperformance and in times of market volatility.
In providing services for retirement plan consulting, our firm does not provide any advisory services
with respect to the following types of assets: employer securities, real estate (excluding real estate
funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other
illiquid investments, or brokerage window programs (collectively, “Excluded Assets”).
All retirement plan consulting services shall be in compliance with the applicable state laws
regulating retirement consulting services. This applies to client accounts that are retirement or other
employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974,
as amended (“ERISA”). If the client accounts are part of a Plan, and our firm accept appointments to
provide services to such accounts, our firm acknowledges its fiduciary standard within the meaning
of Section 3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with
respect to the provision of services described therein.
Regulatory Assets Under Management
As of December 31, 2023, our firm manages $164,109,025 on a discretionary basis.
ADV Part 2A – Firm Brochure Page 6 Argyle Capital Partners, LLC