Herr Investment Group LLC (“we”, “us” or the “Firm”) was established in 2021. The managing
member and principal owner of Herr Investment Group LLC, Daniel Herr, has been providing
investment guidance and portfolio management services to individuals, professionals, business
owners, businesses/corporations, retirement plans, and charitable organizations since 2005.
As a registered investment adviser subject to Section 206 of the Investment Advisers Act of 1940,
Herr Investment Group LLC acts as a fiduciary in the conduct of its investment advisory services. As
such, Herr Investment Group LLC has an obligation to act in the best interest of its clients, guided by
its core fiduciary duties of loyalty and care.
Advisory Services to clients in Separately Managed Accounts and a Private Fund
Investment Portfolio Management Services – Separately Managed Accounts
Herr Investment Group LLC provides continuous and regular portfolio management services
primarily on a discretionary basis. This means that you grant us authority to supervise and direct
the trading of the securities in your account(s) without us needing to contact you before trades are
executed. Herr Investment Group LLC will recommend an investment strategy and individually
design a portfolio of investments which can include one or a combination of: equities, bonds (Gov’t
& Corporate), mutual funds, Exchange Traded Funds (ETFs), Closed-End Funds, Options, Currencies
(incl. exposure to digital forms), Private Offerings, Alternative Investments, and other securities
including short-term money market instruments. We monitor the holdings and percentage
allocations in your account(s) no less frequently than quarterly. If and when non-discretionary
services are provided, Herr Investment Group LLC will make recommendations while you make the
ultimate decisions and take responsibility for the final selection of securities bought or sold.
We strongly encourage clients to inform us promptly in the event of any significant life changes,
such as setting a retirement date, having a child, receiving an inheritance, etc., so we can perform a
re-assessment to determine the proper investment strategy from that point forward. It is our policy to
review/discuss accounts with our clients no less frequently than annually, at which time we
discuss/confirm any account limitations or restrictions.
Herr Investment Group LLC’s investment strategies are primarily long-term focused, but from time
to time, we buy, sell or reallocate positions that have been held less than one year to meet the
objectives of a particular strategy or due to market conditions. (See Item #8 below for a more
detailed description of our forms of analysis and our investment strategies.)
Customization of Client Accounts
Before we begin managing a client portfolio, we engage a new or potential client in a pre-advisory
consultation to better understand the client’s financial situation and expectations. During this
consultation, we:
• Review the client’s investment goals and objectives, tax situation, financial needs (e.g.,
income, liquidity, etc.), and any limitations
• Gauge the client’s tolerance for risk
• Analyze current investment strategies and asset allocation
By understanding each of these financial characteristics and communicating our investment
philosophy, we then develop an investment portfolio for the client and set the expectations for our
client-adviser relationship.
Typical client Investment Objectives include Income, Balanced/Conservative Growth, Growth,
Aggressive Growth, and Speculation. Typical client Risk Tolerances include Low, Moderate, High, Very
High, and Highest. With Herr Investment Group’s active management approach which forgoes limiting
allocation ranges, accounts will from time-to-time hold a mix of securities that will appear out of
synch with clients’ stated Investment Objectives and Risk Tolerances.
We will take into consideration special situations such as restrictions on certain securities or asset
classes, liquidity needs, and tax situations when managing portfolios. Each client will have the
opportunity to place reasonable restrictions on the types of investments
to be held in their respective
portfolio. However, Herr Investment Group LLC reserves the right to decline to accept certain client
restrictions that, in our judgement, would prevent us from employing our strategy to pursue the
client’s objective or if the restriction would unreasonably add to costs (e.g., research).
Investment Portfolio Management Services – Private Fund
Herr Investment Group LLC also provides investment management services to Pointillist Partners,
LLC, a privately offered pooled investment vehicle (i.e., the “Private Fund” or “Fund”) exempt from
registration under the Investment Company Act of 1940, as amended. Herr Investment Group LLC
manages the Fund in a manner consistent with the investment strategy described in the Fund’s
offering documents. Mr. Herr shares portfolio management responsibilities for the Fund with Jorey
Chernett.
Herr Investment Group LLC does not generally provide specifically tailored advice to investors in the
Fund unless the investors have also engaged Herr Investment Group LLC to provide portfolio
management services through a separately executed investment management agreement.
The Private Fund and separately managed account clients are collectively referred to herein as
“Clients”. Mr. Herr and Mr. Chernett are significant investors in the Fund.
Differences in Advisory Services between Separately Managed Accounts and the Private Fund
Herr Investment Group generally invests the assets of the private fund more aggressively than for
clients with separately managed accounts. Examples of more aggressive measures employed for
the fund include significant leverage, position concentration, short-term trading and investing a
larger percentage of assets in short sales, microcap and foreign securities, and in
private/limited/secondary offerings which are typically illiquid. Fund assets will also occasionally be
invested in commodities and futures but not in such weightings or volume that would necessitate
the fund registering with the Commodities Futures Trading Commission (CFTC) as a Commodity Pool
Operator (CPO). (Refer to Item 8 for a more complete description of the strategy and techniques
used in the Private Fund.)
These differences in investment strategies and trading techniques are expected to cause the fund
to, at times, experience meaningfully different performance, including achieving higher rates of
return and exhibiting higher volatility than for separately managed account clients, even for those
clients who have selected the highest risk tolerance as part of their Investment Guidelines/suitability
profile.
Wrap Fee Programs
Herr Investment Group LLC does not participate directly or indirectly in any wrap fee programs.
Regulatory Assets Under Management
Herr Investment Group LLC last reported Regulatory Assets Under Management of $ 747,598,094 as
of December 31, 2023. All client assets are managed on a discretionary basis.
IRA Rollover Recommendations
For purposes of complying with the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”)
where applicable, we are providing the following acknowledgment to you.
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.