Farris Capital Management is an investment adviser registered with the Securities Exchange
Commission and is a corporation formed under the laws of the State of Texas.
•Justin Farris
is the Chief Compliance Officer (CCO) and Managing Member of Farris Capital
Management. Justin Farris owns 100.00% of Farris Capital Management. Full details of the
education and business background of Justin Farris are provided at
Item 19 of this Disclosure
Brochure.
•Farris Capital Management filed its initial application to become registered as an investment
adviser with the U.S. Securities Exchange Commission in February 2022, which was accepted on
March 8, 2022.
Introduction
The investment advisory services of Farris Capital Management are provided to you through an
appropriately licensed and qualified individual who is an investment adviser representative of Farris
Capital Management (referred to as your investment adviser representative throughout this brochure).
Description of Advisory Services
The following are descriptions of the primary advisory services of Farris Capital Management. Please
understand that a written agreement, which details the exact terms of the service, must be signed by you
and Farris Capital Management before we can provide you the services described below.
Financial Planning & Consulting Services
Farris Capital Management offers financial planning services, which involve preparing a written financial
plan covering specific or multiple topics. We provide full written financial plans, which typically address
the following topics: Investment Planning; Retirement Planning; Insurance Planning; Tax Planning;
Education Planning; and Asset Allocation. When providing financial planning and consulting services, the
role of your investment adviser representative is to find ways to help you understand your
overall financial
situation and help you set financi
al objectives. Written financial plans prepared by us do not include
specific recommendations of individual securities.
We also offer consultations in order to discuss financial planning issues when you do not need a written
financial plan. We offer “as-needed” consultations, which are limited to consultations in response to a
particular investment or financial planning issue raised or request made by you. Under an “as-needed”
consultation, it will be incumbent upon you to identify those particular issues for which you are seeking
our advice or consultation on.
Our financial planning and consulting services do not involve implementing any transaction on your behalf
or the active and ongoing monitoring or management of your investments or accounts. You have the sole
responsibility for determining whether to implement our financial planning and consulting
recommendations. To the extent that you would like to implement any of our investment
recommendations through Farris Capital Management or retain Farris Capital Management to actively
monitor and manage your investments, you must execute our written agreement with Farris Capital
Management for our asset management services.
Farris Capital Management Inc. Page 6 Form ADV Part 2A Disclosure Brochure
Asset Management Services via Schwab Institutional Intelligent Portfolios Platform or Zoe Wealth
Platform via Apex Clearing Corporation
We offer automated investment programs through the Zoe Wealth Platform via Apex Clearing Corporation
and by Charles Schwab & Co Inc., which clients are invested in a range of model investment strategies
we have constructed and manage, each consisting of a portfolio of exchange-traded funds, stocks, or
mutual funds and a cash allocation. The client’s portfolio is held in a brokerage account opened by the
client at Charles Schwab & Co., Inc. (“CS&Co”) or Apex Clearing Corporation.
We use the Institutional Intelligent Portfolios® platform, offered by Schwab Performance Technologies
(“SPT”), a software provider to independent investment advisors and an affiliate of CS&Co., or Zoe
Wealth Platform to operate these programs. We are independent of and not owned by, affiliated with, or
sponsored or supervised by SPT, CS&Co., Zoe Financial, or their affiliates. We are the client’s investment
advisor and primary point of contact with respect to these programs. We are responsible for determining
the appropriateness of the program for the client, choosing a suitable investment strategy and portfolio for
the client’s investment needs and goals, and managing that portfolio on an ongoing basis. We have
contracted with SPT and Zoe Financial to provide us with these platforms, which consists of technology
and related trading and account management services for the programs. These offerings enable us to
make these programs available to clients online and includes a system that automates certain key parts of
our investment process.
Based on information the client provides to us, we will recommend a portfolio model that is built via these
wealth platforms. The web platforms also include an automated investment engine through which we
manage the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting
(if the client is eligible and we elect to do so).
Clients do not pay brokerage commissions or any other fees to CS&Co. as part of their Program. Schwab
does receive other revenues, including (i) the profit earned by the cash position in Charles Schwab Bank,
SSB, a Schwab affiliate, on the allocation to the Schwab Intelligent Portfolios Sweep Program described
in the Schwab Intelligent Portfolios Sweep Program Disclosure Statement; (ii) investment advisory and/or
administrative service fees (or unitary fees) received by Charles Schwab Investment Management, Inc., a
Schwab affiliate, from Schwab ETFs™ Schwab Funds® and Laudus Funds® that we select to buy and
hold in the client’s brokerage account; (iii) fees received by Schwab from mutual funds in the Schwab
Mutual Fund Marketplace® (including certain Schwab Funds and Laudus Funds) in the client’s brokerage
account for services Schwab provides; and (iv) remuneration Schwab receives from the market centers
where it routes ETF trade orders for execution.
Clients do not pay brokerage commissions to Zoe Financial or Apex however platform fees are paid to
Zoe Financial/Apex depending on assets under management which are included in each client's fee
schedule and potential remuneration paid to Apex from market centers where it routes trade orders for
execution as part of their program.
Asset Management Services via Fidelity Institutional Wealth Services Platform, or Charles
Schwab & Co., Inc.
Farris Capital Management offers asset management services on the Fidelity Institutional Wealth
Services Platform or Charles Schwab & Co., Inc., which involves Farris Capital Management providing
you with continuous and ongoing supervision over your specified accounts.
You must appoint our firm as your investment adviser of record on specified accounts (collectively, the
“Account”) on Charles Schwab and Co., Inc. or the Fidelity Institutional Wealth Services Platform. The
Account consists only of separate account(s) held by Charles Schwab and Co., Inc, National Financial
Services, LLC or Fidelity Brokerage Services, LLC, which are qualified custodians under your name. The
qualified custodians maintain physical custody of all funds and securities of the Account, and you retain all
rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and
receive transaction confirmations) of the Account.
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The Account is managed by us based on your financial situation, investment objectives and risk
tolerance. We actively monitor the Account and provide advice regarding buying, selling, reinvesting or
holding securities, cash or other investments of the Account.
We will need to obtain certain information from you to determine your financial situation and investment
objectives. You will be responsible for notifying us of any updates regarding your financial situation, risk
tolerance or investment objective and whether you wish to impose or modify existing investment
restrictions; however, we will contact you at least annually to discuss any changes or updates regarding
your financial situation, risk tolerance or investment objectives. We are always reasonably available to
consult with you relative to the status of your Account. You have the ability to impose reasonable
restrictions on the management of your accounts, including the ability to instruct us not to purchase
certain securities.
It is important that you understand that we manage investments for other clients and can give them
advice or take actions for them or for our personal accounts that is different from the advice we provide to
you or actions taken for you. We are not obligated to buy, sell or recommend to you any security or other
investment that we can buy, sell or recommend for any other clients or for our own accounts.
Conflicts can arise in the allocation of investment opportunities among accounts that we manage. We
strive to allocate investment opportunities believed to be appropriate for your account(s) and other
accounts advised by our firm among such accounts equitably and consistent with the best interests of all
accounts involved. However, there can be no assurance that a particular investment opportunity that
comes to our attention will be allocated in any particular manner. If we obtain material, non-public
information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no
obligation to disclose the information to any client or use it for any client’s benefit.
Retirement Plan Rollover Recommendations
When Farris Capital provides investment advice about your retirement plan account or individual
retirement account (“IRA”) including whether to maintain investments and/or proceeds in the retirement
plan account, roll over such investment/proceeds from the retirement plan account to a IRA or make a
distribution from the retirement plan account, we acknowledge that Farris Capital is a “fiduciary” within
the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal
Revenue Code (“IRC”) as applicable, which are laws governing retirement accounts. The way Farris
Capital makes money creates conflicts with your interests so Farris Capital operates under a special rule
that requires Farris Capital to act in your best interest and not put our interest ahead of you.
Under this special rule’s provisions, Farris Capital must act as a fiduciary to a retirement plan account or
IRA under ERISA/IRC:
•Meet a professional standard of care when making investment recommendations (e.g.,
give prudent advice);
•Never put the financial interests of Farris Capital ahead of you when making
recommendations (e.g., give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that Farris Capital gives advice that is
in your best interest;
•Charge no more than is reasonable for the services of Farris Capital; and
•Give Client basic information about conflicts of interest
Page 8 Form ADV Part 2A Disclosure Brochure
To the extent we recommend you roll over your account from a current retirement plan account to an
individual retirement account managed by Farris Capital, please know that Farris Capital and our
investment adviser representatives have a conflict of interest.
We can earn increased investment advisory fees by recommending that you roll over your account at the
retirement plan to an IRA managed by Farris Capital. We will earn fewer investment advisory fees if you
do not roll over the funds in the retirement plan to an IRA managed by Farris Capital.
Thus, our investment adviser representatives have an economic incentive to recommend a rollover of
funds from a retirement plan to an IRA which is a conflict of interest because our recommendation that
you open an IRA account to be managed by our firm can be based on our economic incentive and not
based exclusively on whether or not moving the IRA to our management program is in your overall best
interest.
We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard
whereby our investment adviser representatives will (i) provide investment advice to a retirement plan
participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status
described below, (ii) not recommend investments which result in Farris Capital receiving unreasonable
compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose
compensation received by Farris Capital and our supervised persons and any material conflicts of interest
related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making
any materially misleading statements regarding such rollover.
When providing advice to your regarding a retirement plan account or IRA, our investment advisor
representatives will act with the care, skill, prudence, and diligence under the circumstances then
prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the
conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk,
tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests
of Farris Capital or our affiliated personnel.
Participation in Wrap Fee Programs (Asset Management Services)
Farris Capital Management does not sponsor or manage a wrap fee program.
Newsletters
Farris Capital Management occasionally prepares general, educational and informational newsletters.
Newsletters are always offered on an impersonal basis and do not focus on the needs of a specific
individual.
Seminars
Farris Capital Management will occasionally provide seminars in areas such as financial planning,
retirement planning, estate planning, college planning and charitable planning. Seminars are always
offered on an impersonal basis and do not focus on the individual needs of participants.
Farris Capital Management Inc. Page 9 Form ADV Part 2A Disclosure Brochure
Workshops
Farris Capital Management can offer educational, informative and motivational workshops to the public as
well as to associations, family foundations and employers. Workshops are always offered on an
impersonal basis and do not focus on the individual needs of the participants.
Limits Advice to Certain Types of Investments
Farris Capital Management provides investment advice on the following types of investments:
•Mutual Funds
•Exchange-listed Securities
•Securities Traded Over-the-Counter
•Warrants
•Corporate Debt Securities
•Municipal Securities
•Variable Annuities
•Variable Life Insurance
•US Government Securities
•Options Contracts on Securities
•Interests in Partnerships Investing in Real Estate
•Interests in Partnerships Investing in Oil and Gas Interests
Although we generally provide advice only on the products previously listed, we reserve the right to offer
advice on any investment product that may be suitable for each client’s specific circumstances, needs,
goals and objectives.
It is not our typical investment strategy to attempt to time the market, but we may increase cash holdings
modestly as deemed appropriate based on your risk tolerance and our expectations of market behavior.
We may modify our investment strategy to accommodate special situations such as low basis stock, stock
options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations.
(Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more
information.)
Tailored Advisory Services to Individual Needs of Clients
Farris Capital Management’s advisory services are always provided based on your individual needs. This
means, for example, that when we provide asset management services, you are given the ability to
impose restrictions on the accounts we manage for you, including specific investment selections and
sectors. We work with you on a one-on-one basis through interviews and questionnaires to determine
your investment objectives and suitability information. Our financial planning and consulting services are
always provided based on your individual needs. When providing financial planning and consulting
services, we work with you on a one-on-one basis through interviews and questionnaires to determine
your investment objectives and suitability information.
We will not enter into an investment adviser relationship with a prospective client whose investment
objectives are considered incompatible with our investment philosophy or strategies or where the
prospective client seeks to impose unduly restrictive investment guidelines.
Page 10 Form ADV Part 2A Disclosure Brochure
Client Assets Managed by Farris Capital Management
The amount of client assests managed by Farris Capital Management totaled $102,845,018 as of
December 31, 2022, with $100,961,325 managed on a discretionary basis and $1,883,963 managed on a
non-discretionary basis.