Description of Firm
Client First Investment Management LLC is a registered investment adviser based in West Bend,
Wisconsin. Our firm is organized as a Limited Liability Corporation and was formed in December 2015.
The firm provides both consulting and investment management services to a wide variety of
clients. We are owned by Rock Point Partners LLC which is owned equally by Justin Krueger, David
Zarling and Paul Zarling.
As used in this brochure, the words “we”, “our” and “us” refer to Client First Investment
Management LLC and the words “you”, “your” and “client” refer to you as either a client or prospective
client of our firm. Also, you may see the term Associated Person throughout this Brochure. As used in
this Brochure, our Associated Persons are our firm’s officers, employees, and all individuals providing
investment advice on behalf of our firm.
We offer discretionary portfolio management services through a wrap-fee program ("Client First
Investment Management Wrap Fee Program") as described in this wrap fee program brochure to
prospective and existing clients. We are the sponsor and investment adviser for the Program. A wrap-
fee program is a type of investment program that provides clients with asset management and
brokerage services for one all-inclusive fee. If you participate in our wrap fee program, you will pay our
firm a single fee, which includes money management fees, certain transaction costs, and custodial and
administrative costs. You are not charged separate fees for the respective components of the total
services. We receive a portion of the wrap fee for our services. The overall cost you will incur if you
participate in our wrap fee program may be higher or lower than you might incur by separately
purchasing the types of securities available in the Program. The Client First Investment Management
Wrap Fee Program's investment objective is growth of capital in broad equity market uptrends and
preservation of capital in broad equity market downtrends.
Prior to becoming a client under the Program, you will be required to enter into a separate written
agreement with us that sets forth the terms and conditions of the engagement and describes the scope
of the services to be provided, and the fees to be paid.
Client Investment Process
We offer discretionary portfolio management services. Our investment advice is tailored to meet our
clients' needs and investment objectives. If you participate in our discretionary portfolio management
services, we require you to grant our firm discretionary authority to manage your account.
Discretionary authorization will allow us to determine the specific securities, and the amount of
securities, to be purchased or sold for your account without your approval prior to each transaction.
Discretionary authority is typically granted by the investment advisory agreement you sign with our firm
and the appropriate trading authorization forms. We do not permit clients to impose any restrictions on
a grant of discretionary authority.
You may limit our discretionary authority (for example, limiting the types of securities that can be
purchased or sold for your account) by providing our firm with your restrictions and guidelines in
writing.
On an annualized basis, our fees for portfolio management services, subject to negotiation, are based
on the following fee schedule:
Aggregate Account Value Standard Fee Rate
<$100,000 2.50% / yr
>$100,000 - $1,000,000 2.00% / yr
>$1,000,000 - $10,000,000 1.75% / yr
>$10,000,000 - $100,000,000 1.625% / yr
>$100,000,000+ 1.5625% / yr
All fees due are established in each client's Investment Management Services Agreement.
Advisory fees are payable calendar-quarterly in advance and are calculated on the basis of the
aggregate account value of the investments in the account, including any balances held in money
market funds. The initial quarter by fee is pro-rated for the period that services are provided.
Subsequent quarterly fees are based upon the aggregate account value of the account as of the last
business day of the previous quarter.
We will deduct our fee directly from your account through the qualified custodian holding your funds
and securities. We will deduct our advisory fee only when the following requirements are met:
• You provide our firm with written authorization permitting the fees to be paid directly from your
account held by the qualified custodian.
• We send you an invoice showing the amount of the fee, the value of the assets on which the
fee is based, and the specific manner in which the fee was calculated.
• The qualified custodian agrees to send you a statement, at least quarterly, indicating all
amounts dispersed from your account including the amount of the advisory fee paid directly to
our firm.
At our discretion, we may combine the account values of family members living in the same household
to determine the applicable advisory fee. For example, we may combine account values for you and
your minor children, joint accounts with your spouse, and other types of related accounts. Combining
account values may increase the asset total, which may result in your paying a reduced advisory fee
based on the available breakpoints in our fee schedule stated above.
The wrap-fee includes all advisory and brokerage costs (including transaction costs), quarterly
performance reports, third party custodial fees, exchange fees and transfer taxes.
We may determine to invest part or all of a discretionary account in the Adaptiv™ Select ETF (the
“Fund”), an exchange-traded fund and series of Series Portfolios Trust which we manage. When we
determine to invest part or all of a discretionary account in the Fund, we will rebate back to the client
the portion of the unitary management fee payable to us from the Fund that is attributable to the
assets of the client account invested in the Fund.
Fee Differentials: In certain circumstances, and in our sole discretion, we may charge a different wrap
fee (higher or lower) based upon certain criteria (i.e., complexity of the engagement, anticipated future
earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related
accounts, account composition, services to be provided (i.e. financial planning services), negotiations
with client etc.).
Fee Calculation: The fee charged is calculated as described above and is not charged on the basis of
a share of capital gains upon or capital appreciation of the funds or any portion of the funds of your
account.
Termination of Advisory Relationship: Upon termination of the services agreement, which can occur
with ten days advance written notice from one party to the other, any pre-paid advisory fees will be
prorated and any unearned fee will be refunded within 30 days of the termination date, except for a
termination administration fee of $100 if the agreement is terminated during its first year, and $50 if
terminated any time after the first year.
We reserve the right to modify our fee schedule upon thirty days advance written notice to you.
Withdrawal of Assets
You may withdraw account assets on notice to our firm, and subject to the usual and customary
securities settlement procedures. However, we design our portfolios as long-term investments and
asset withdrawals may impair the achievement of your specific investment objectives.
Assets Under Management
As
of December 31, 2023, we provide continuous management services for $126,177,235 in client
assets on a discretionary basis.
Wrap Fee Program Disclosures
• The benefits under a wrap fee program depend, in part, upon the size of the Account, the
management fee charged, and the number of transactions likely to be generated in the
Account. For example, a wrap fee program may not be suitable for Accounts with little trading
activity. In order to evaluate whether a wrap fee program is suitable for you, you should
compare the Program Fee and any other costs of the Program with the amounts that would be
charged by other advisers, broker-dealers, and custodians, for advisory fees, brokerage and
other execution costs, and custodial services comparable to those provided under the Program.
• In considering the investment programs described in this brochure, you should be aware that
participating in a wrap fee program may cost more or less than the cost of purchasing advisory,
brokerage, and custodial services separately from other advisers or broker-dealers.
• Our firm and Associated Persons receive compensation as a result of your participation in the
Program. This compensation may be more than the amount our firm or the Associated Persons
would receive if you paid separately for investment advice, brokerage, and other services.
Accordingly, a conflict of interest exists because our firm and our Associated Persons have a
financial incentive to recommend the Program.
• Similar advisory services may be available from other registered investment advisers for lower
fees.
Additional Fees And Expenses
The Program Fee includes the costs of brokerage commissions for transactions executed through the
Qualified Custodian (or a broker-dealer designated by the Qualified Custodian), and charges relating to
the settlement, clearance, or custody of securities in the Account. The Program Fee does not include
mark-ups and mark-downs, dealer spreads or other costs associated with the purchase or sale of
securities, interest, taxes, or other costs, such as national securities exchange fees, charges for
transactions not executed through the Qualified Custodian, costs associated with exchanging
currencies, wire transfer fees, or other fees required by law or imposed by third parties. The Account
will be responsible for these additional fees and expenses.
The wrap program fees that you pay to our firm for portfolio management services are separate and
distinct from the fees and expenses charged by mutual funds or exchange traded funds (described in
each fund's prospectus) to their shareholders. These fees will generally include a management fee and
other fund expenses. To fully understand the total cost you will incur, you should review all the fees
charged by mutual funds, exchange traded funds, our firm, and others.
If you participate in the Program, you will be required to use the custodial services of Schwab
Financial, a securities broker-dealer and a member of the Financial Industry Regulatory Authority and
the Securities Investor Protection Corporation. Schwab is not affiliated with our firm and is not a
sponsor of this Program. Since we require you to use Schwab, we may be unable to achieve the most
favorable execution of your transactions and you may pay higher brokerage commissions than you
might otherwise pay through another broker-dealer that offers the same types of services. Not all
advisers require their clients to direct brokerage. We believe that Schwab provides quality execution
services for you at competitive prices. Price is not the sole factor we consider in evaluating best
execution. We also consider the quality of the brokerage services provided by Schwab, including the
value of research received, Schwab's reputation, execution capabilities, commission rates, and
responsiveness to our clients and our firm. In recognition of the value of research services and
additional brokerage products and services Schwab provides, you may pay higher commissions
and/or trading costs than those that may be available elsewhere.
We participate in Schwab's institutional customer program. There is no direct link between our
participation in the program and the investment advice we gives to you, although we receives
economic benefits through our participation in the program that are typically not available to Schwab's
retail investors. These benefits include the following products and services (provided without cost or at
a discount): receipt of duplicate client statements and confirmations; research related products and
tools; consulting services; access to a trading desk serving our participants; access to block trading
(which provides the ability to aggregate securities transactions for execution and then allocate the
appropriate shares to client accounts); the ability to have our fees deducted directly from client
accounts; access to an electronic communications network for client order entry and account
information; access to mutual funds with no transaction fees and discounts on compliance, marketing,
research, technology, and practice management products or services provided to us by third party
vendors. Schwab may also have paid for business consulting and professional services received by
us and may also pay or reimburse expenses (including travel, lodging, meals and entertainment),
expenses for our personnel to attend conferences or meetings relating to the program or to Schwab's
advisor custody and brokerage services generally. Some of the products and services made available
by Schwab through the program may benefit us but may not benefit your account(s). These products
or services may assist us in managing and administering your accounts, including accounts not
maintained at Schwab. Other services made available by Schwab are intended to help us manage and
further develop its business enterprise.
The benefits received by us or our personnel through our participation in the program do not depend
on the amount of brokerage transactions directed to Schwab. As part of its fiduciary duties to our
clients, we endeavor at all times to put the interests of our clients first. You should be aware,
however, that the receipt of economic benefits by us or our related persons in and of itself creates a
potential conflict of interest and may indirectly influence our choice of Schwab for custody and
brokerage services.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers in exchange for cash or other compensation,
such as brokerage services or research.
Block Trades
We combine multiple orders for shares of the same securities purchased for advisory accounts we
manage (this practice is commonly referred to as "block trading"). We will then distribute a portion of
the shares to participating accounts in a fair and equitable manner. The distribution of the shares
purchased is typically proportionate to the size of the account, but it is not based on account
performance or the amount or structure of management fees. Subject to our discretion regarding
factual and market conditions, when we combine orders, each participating account pays an average
price per share for all transactions and pays a proportionate share of all transaction costs. Accounts
owned by our firm or persons associated with our firm may participate in block trading with your
accounts; however, they will not be given preferential treatment.