A. Description of the Advisory Firm
Impact Capital, LLC (hereinafter “IC”) is a Limited Liability Company organized in the
State of Maryland. The firm was formed in May 2018, and the principal owners are
William D. Bancroft and ECDC Investments, LLC, which in turn is owned by Eric Cohen
and Daniel Cohen.
B. Types of Advisory Services
Portfolio Management Services
IC offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. IC creates an Investment Policy
Statement for each client, which outlines the client’s current situation (income, tax levels,
and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio
that matches each client's specific situation. Portfolio management services include, but
are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring
IC evaluates the current investments of each client with respect to their risk tolerance
levels and time horizon. IC will require discretionary authority from clients in order to
select securities and execute transactions without permission from the client prior to each
transaction. Risk tolerance levels are documented in the Investment Policy Statement,
which is given to each client.
IC seeks to provide that investment decisions are made in accordance with the fiduciary
duties owed to its accounts and without consideration of IC’s economic, investment or
other financial interests. To meet its fiduciary obligations, IC attempts to avoid, among
other things, investment or trading practices that systematically advantage or
disadvantage certain client portfolios, and accordingly, IC’s policy is to seek fair and
equitable allocation of investment opportunities/transactions among its clients to avoid
favoring one client over another over time. It is IC’s policy to allocate investment
opportunities and transactions it identifies as being appropriate and prudent among its
clients on a fair and equitable basis over time.
Pension Consulting Services
IC offers consulting services to pension or other employee benefit plans (including but
not limited to 401(k) plans). Pension consulting may include, but is not limited to:
o identifying investment objectives and restrictions
o providing guidance on various assets classes and investment options
o recommending money managers to manage plan
assets in ways designed to
achieve objectives
o monitoring performance of money managers and investment options and making
recommendations for changes
o recommending other service providers, such as custodians, administrators and
broker-dealers
o creating a written pension consulting plan
These services are based on the goals, objectives, demographics, time horizon, and/or risk
tolerance of the plan and its participants.
Financial Planning
Financial plans and financial planning may include, but are not limited to: investment
planning; life insurance; tax concerns; retirement planning; education planning; and
debt/credit planning, executive compensation, charitable giving and risk management.
The goal of offering this service is to provide clients with a comprehensive financial plan
designed to show them where they are and get them where they want to go.
Services Limited to Specific Types of Investments
IC generally limits its investment advice to mutual funds, fixed income securities, real
estate funds (including REITs), equities, ETFs (including ETFs in the gold and precious
metal sectors), treasury inflation protected/inflation linked bonds, commodities and non-
U.S. securities. IC may use other securities as well to help diversify a portfolio when
applicable.
C. Client Tailored Services and Client Imposed Restrictions
IC will tailor a program for each individual client. This will include an interview session
to get to know the client’s specific needs and requirements as well as a plan that will be
executed by IC on behalf of the client. IC may use model allocations together with a
specific set of recommendations for each client based on their personal restrictions, needs,
and targets. Clients may impose restrictions in investing in certain securities or types of
securities in accordance with their values or beliefs. However, if the restrictions prevent
IC from properly servicing the client account, or if the restrictions would require IC to
deviate from its standard suite of services, IC reserves the right to end the relationship.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, and certain other administrative fees. IC
does not participate in wrap fee programs.
E. Assets Under Management
IC has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$188,079,548.00 $0.00 December 2023