A. Firm Information
Vanquour LLC (“Vanquour” or the “Adviser”) is a registered investment adviser with the U.S. Securities and Exchange
Commission (“SEC”). Vanquour is organized under the laws of the State of New York. Vanquour was founded in
November 2021. Vanquour is owned and operated by Lu Zhou, who is the President and Chief Compliance Officer
of Vanquour.
B. Advisory Services Offered
Vanquour offers investment management services to individuals, high net worth individuals, families, trusts, estates,
businesses and retirement plans (each referred to as a “Client”).
Investment Management Services
Vanquour provides customized investment management solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management and related advisory
services. Vanquour works closely with each Client to identify their investment goals and objectives as well as risk
tolerance and financial situation in order to create a portfolio strategy. Vanquour will then construct an investment
portfolio, primarily consisting of diversified mutual funds, exchange-traded funds (“ETFs”), individual stocks, and
individual bonds to achieve the Client’s investment goals. Vanquour may also utilize covered options, managed
account programs offered by the Client’s custodian (“Custodian”) (please see Independent Managers disclosure
below) and/or other types of investments, as appropriate to meet the needs of the Client. Vanquour may retain certain
types of investments based on a Client’s legacy investments based on portfolio fit and/or tax considerations.
Vanquour’s investment strategies are primarily long-term focused, but Vanquour may buy, sell or re-allocate positions
that have been held for less than one year to meet the objectives of the Client or due to market conditions. Vanquour
will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk
tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types
of investments to be held in their respective portfolio, subject to acceptance by Vanquour.
Vanquour evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. Vanquour may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. Vanquour may recommend specific positions to increase sector or asset class weightings. Vanquour may
recommend employing cash positions as a possible hedge against market movement. Vanquour may recommend
selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector
risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the
portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed
unacceptable for the Client’s risk tolerance.
All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the
advisory agreement. Please see Item 12 – Brokerage Practices.
Use of Independent Managers - Vanquour may recommend that a Client allocate a portion of their investments to
one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”)
available through the Custodian’s platform. The Client may be required to authorize and enter into an investment
management agreement with the Independent Manager[s] that defines the terms in which the Independent
Manager[s] will provide its services, including discretionary management and fee billing. Vanquour will perform initial
and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned
with Clients investment objectives and overall best interests. Vanquour will also assist the Client in the development
of the initial policy recommendations and managing the ongoing Client relationship.
Financial Planning Services
Vanquour will typically provide a variety of financial planning and consulting services to Clients. Services are offered
in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial
planning services involve preparing a formal financial
plan or rendering a specific financial consultation based on the
Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need,
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including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance
needs, and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations
may be made that the Client start or revise their investment programs, commence or alter retirement savings,
establish education savings and/or charitable giving programs.
Vanquour may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique
situation. For certain financial planning engagements, Vanquour will provide a written summary of the Client’s
financial situation, observations, and recommendations. For consulting or ad-hoc engagements, Vanquour may not
provide a written summary. Plans or consultations are typically completed within six (6) months of contract date,
assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of Vanquour and the
interests of the Client. For example, Vanquour has an incentive to recommend that Clients engage Vanquour for
investment management services or to increase the level of investment assets with Vanquour, as it would increase
the amount of advisory fees paid to Vanquour. Clients are not obligated to implement any recommendations made
by Vanquour or maintain an ongoing relationship with Vanquour. If the Client elects to act on any of the
recommendations made by Vanquour, the Client is under no obligation to implement the transaction through
Vanquour.
Retirement Plan Advisory Services
Vanquour provides 3(21) retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the
company (the “Plan Sponsor”). Vanquour’s retirement plan advisory services are designed to assist the Plan Sponsor
in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs
of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
These services are provided by Vanquour serving in the capacity as a fiduciary under the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor
is provided with a written description of Vanquour’s fiduciary status, the specific services to be rendered and all direct
and indirect compensation Vanquour reasonably expects under the engagement.
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C. Client Account Management
Prior to engaging Vanquour to provide investment management services, each Client is required to enter into one or
more agreements with Vanquour that define the terms, conditions, authority and responsibilities of Vanquour and the
Client. These services may include:
• Establishing an Investment Strategy – Vanquour, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Vanquour will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – Vanquour will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
• Investment Management and Supervision – Vanquour will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Vanquour does not manage or place Client assets into a wrap fee program.
E. Assets Under Management
As of March 31, 2024, Vanquour had $66,400,000 in regulatory assets under management, all of which are managed
on a discretionary basis.