Description of Firm
Vines Capital Management, LLC is a registered investment adviser primarily based in Monroe,
Louisiana. We are organized as a limited liability company ("LLC") under the laws of the State of
Louisiana. We have been providing investment advisory services since October 2018. We are owned
by Kenneth G. Vines through KENNETH G. VINES, INC.
The following paragraphs describe our services and fees. Refer to the description of each investment
advisory service listed below for information on how we tailor our advisory services to your individual
needs. As used in this brochure, the words "we," "our," and "us" refer to Vines Capital Management,
LLC and the words "you," "your," and "client" refer to you as either a client or prospective client of our
firm.
Portfolio Management Services
We offer discretionary portfolio management services. Our investment advice is tailored to meet our
clients' needs and investment objectives. If you retain our firm for portfolio management services, we
will meet with you to determine your investment objectives, risk tolerance, and other relevant
information at the beginning of our advisory relationship. We will use the information we gather to
develop a strategy that enables our firm to give you focused investment advice and/or to make
investments on your behalf.
In order to provide 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. In limited
circumstances, and only upon our approval, we may accept client-imposed restrictions on investing in
certain securities or types of securities.
As part of our portfolio management services, in addition to other types of investments (see
disclosures below in this section), we may invest your assets according to one or more
model portfolios developed by our firm. These models are designed for investors with varying degrees
of risk tolerance ranging from a more aggressive investment strategy to a more conservative
investment approach. Clients whose assets are invested in model portfolios may not set restrictions on
the specific holdings or allocations within the model, nor the types of securities that can be purchased
in the model. Nonetheless, clients may impose restrictions on investing in certain securities or types of
securities in their account. In such cases, this may prevent a client from investing in certain models
that are managed by our firm.
Financial Planning Services
We offer financial planning services which typically involve providing a variety of advisory services to
clients regarding the management of their financial resources based upon an analysis of their
individual needs. These services can range from broad-based financial planning to consultative or
single subject planning. If you retain our firm for financial planning services, we will meet with you to
gather information about your financial circumstances and objectives. We may also use financial
planning software to determine your current financial position and to define and quantify your long-term
goals and objectives. Once we specify those long-term objectives (both financial and non-financial), we
will develop shorter-term, targeted objectives. Once we review and analyze the information you provide
to our firm and the data derived from our financial planning software, we will deliver a written plan to
you, designed to help you achieve your stated financial goals and objectives.
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Financial plans are based on your financial situation at the time we present the plan to you, and on the
financial information you provide to us. You must promptly notify our firm if your financial situation,
goals, objectives, or needs change.
You are under no obligation to act on our financial planning recommendations. Should you choose to
act on any of our recommendations, you are not obligated to implement the financial plan through any
of our other investment advisory services. Moreover, you may act on our recommendations by placing
securities transactions with any brokerage firm.
Pension Consulting Services
We offer pension consulting services to employee benefit plans and their fiduciaries
based upon the
needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these
services may include an existing plan review and analysis, plan-level advice regarding fund selection
and investment options, education services to plan participants, investment performance monitoring,
and/or ongoing consulting. These pension consulting services will generally be non-discretionary and
advisory in nature. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor
or other named fiduciary.
We may also assist with participant enrollment meetings and provide investment-related educational
seminars to plan participants on such topics as:
•Diversification
•Asset allocation
•Risk tolerance
•Time horizon
Our educational seminars may include other investment-related topics specific to the particular plan.
We may also provide additional types of pension consulting services to plans on an individually
negotiated basis. All services, whether discussed above or customized for the plan based upon
requirements from the plan fiduciaries (which may include additional plan-level or participant-level
services) shall be detailed in a written agreement and be consistent with the parameters set forth in the
plan documents.
Selection of Other Advisers
We may recommend that you use the services of a third party money manager ("TPMM") to manage
all, or a portion of, your investment portfolio. After gathering information about your financial situation
and objectives, we may recommend that you engage a specific TPMM or investment program. Factors
that we take into consideration when making our recommendation(s) include, but are not limited to, the
following: the TPMM's performance, methods of analysis, fees, your financial needs, investment goals,
risk tolerance, and investment objectives. We will monitor the TPMM(s)' performance to ensure its
management and investment style remains aligned with your investment goals and objectives.
Wrap Fee Programs
We do not participate in any wrap fee program.
Types of Investments
We primarily offer advice on Mutual Funds, and Exchange Traded Funds. Refer to the Methods of
Analysis, Investment Strategies and Risk of Loss below for additional disclosures on this topic.
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Additionally, we may advise you on various types of investments based on your stated goals and
objectives. We may also provide advice on any type of investment held in your portfolio at the inception
of our advisory relationship.
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field
Assistance Bulletin 2018-02 ceases to be in effect), 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.
We benefit financially from the rollover of your assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our assets under management
and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in
your best interest.
Assets Under Management
As of December 31, 2023, we provide continuous management services for $123,244,018 in client
assets on a discretionary basis, and $0 in client assets on a non-discretionary basis.