A. Description of the Advisory Firm
Cornermen Financial, LLC (hereinafter “Cornermen”) is a Limited Liability Company
organized in the State of Texas. The firm was formed in April 2013, and the principal
owners are Jay Howard and Logan W. Dietel.
B. Types of Advisory Services
Portfolio Management Services
Cornermen offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. Cornermen creates an
Investment Policy Statement for each client, which outlines the client’s current situation
(income, tax levels, and risk tolerance levels). 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
Cornermen evaluates the current investments of each client with respect to their risk
tolerance levels and time horizon. Cornermen will request 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.
Cornermen seeks to provide that investment decisions are made in accordance with the
fiduciary duties owed to its accounts and without consideration of Cornermen’s
economic, investment or other financial interests. To meet its fiduciary obligations,
Cornermen attempts to avoid, among other things, investment or trading practices that
systematically advantage or disadvantage certain client portfolios, and accordingly,
Cornermen’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 Cornermen’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.
Cornermen provides portfolio management services to clients using model asset
allocation portfolios or customized portfolios tailored to the individual needs and
objectives of the client. Clients will retain individual ownership of all securities. The
implementation of these portfolios is accomplished by using either the SEI Asset
Management Program or through Individual Portfolio Management.
SEI's Asset Management Program:
Cornermen may choose to invest its clients’ assets into model portfolios of mutual funds
and exchange-traded funds (“ETFs”) created by SIMC. This includes the SEI Asset
Allocation Models (“SEI Asset Allocation Models”) that consist of allocations to SEI Funds
and SEI ETFs and the Independent Funds Models Program (“Independent Funds Models
Program”) which consists of model portfolios of allocations to certain families of third-
party mutual funds or ETFs. Under the SEI Asset Allocation Models and the Independent
Funds Models Program, SIMC provides non-discretionary services to Cornermen through
the publication of investment models consisting of allocations to these different funds (i.e.,
SEI Funds, SEI ETFs, third-party funds, or third-party ETFs) allocated to the models.
Specifically, SIMC: (1) makes available the models, developed and periodically updated
by SIMC designed to achieve the model’s stated investment objective or goal based upon
SIMC’s capital market assumptions and any other criteria that SIMC, in its sole discretion,
determines is relevant; and (2) periodically publishes for consideration by firm revisions
to a model’s percentage asset allocations among the underlying SEI Funds, SEI ETFs,
third-party funds, or third-party ETFs, or adds, removes, or otherwise changes the
individual SEI Funds, SEI ETFs, third-party funds, or third-party ETFs underlying an
existing model.
SIMC and its affiliates earns fees from the SEI Funds and SEI ETFs, which costs are
indirectly
borne by Clients invested in these models. As a result, SIMC does not charge
Cornermen or its clients a direct fee for the use of the SEI Asset Allocation Models,
although SEI Private Trust Company (“SPTC”), the custodian to the Client and an affiliate
of SIMC, will charge a custodial platform fee on Client assets invested in SEI ETF
products. In the Independent Funds Model Program, SIMC and its affiliates (including
SPTC) charge direct fees that will be assessed to Clients.
In the Sub-Advised Program, Cornermen has hired SEI Investments Management
Corporation (“SIMC”), an SEC-registered investment advisor, to act as the sub-advisor
when using the SIMC Managed Account Solutions. The fundamental difference from
SIMC “standard” Managed Account Solutions program is that under this program SIMC
makes available the various managed account strategies to Cornermen directly and SIMC
does not act as co-advisor to the Client. In other words, SIMC has no contractual
relationship with the Client, which SIMC does when working with Advisors in the
standard co-advised managed accounts program model. Accordingly, in the Sub-Advised
Program, SIMC does not: (1) review client-level suitability of the Managed Account
Solutions selections with the Clients, and (2) does not require end-client (investor)
signatures for investment strategy changes. In order to participate in the Sub-Advised
Program, Cornermen must either have discretionary authority with Clients or have
Clients’ prior agreement to execute all investment selections.
Financial Life Planning
Financial plans and financial planning may include, but are not limited to: investment
planning; life insurance; tax concerns; retirement planning; college planning; and
debt/credit planning.
Services Limited to Specific Types of Investments
Cornermen generally limits its investment advice to mutual funds, hedge funds, private
equity funds and ETFs, stocks, and bonds. Cornermen may use other securities as well to
help diversify a portfolio when applicable.
Written Acknowledgement of Fiduciary Status
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.
C. Client Tailored Services and Client Imposed Restrictions
Cornermen offers the same suite of services to all of its clients. However, specific client
investment strategies and their implementation are dependent upon the client’s current
situation (income, tax levels, and risk tolerance levels). Clients may not impose restrictions
in investing in certain securities or types of securities in accordance with their values or
beliefs.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees and transaction costs. Cornermen does not participate in wrap
fee programs.
E. Assets Under Management
Cornermen has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$ 125,187,989 $0 March 2024