A. Firm Information
Catalyst Investment Management, LLC (“CIM” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”)
under the laws of the State of New Hampshire. CIM was founded in April 2018 and became a registered investment
advisor in October 2018. CIM is owned and operated by Nicholas J. Shea (Managing Member and Chief
Compliance Officer), and Kimberly Quinn (Partner)).
This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by CIM. Information regarding Mr. Shea and Mrs. Quinn’s backgrounds are included in their Form
ADV 2B – Brochure Supplement, which is included with this Disclosure Brochure.
B. Advisory Services Offered
CIM offers investment advisory services to individuals, high net worth, individuals, trusts, and estates (each referred
to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. CIM’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more
information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
Investment Management Services
CIM provides customized investment management solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management and related advisory
services. CIM works closely with each Client to identify their investment goals and objectives as well as risk
tolerance and financial situation in order to create a portfolio strategy. CIM will then construct an investment
portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the
Client’s investment goals. The Advisor may also utilize individual stocks and individual bonds in constructing Client
portfolios. In limited circumstances, the Advisor may utilize covered options contracts as a risk mitigation strategy or
recommend the use of real estate investment trusts (“REITs”) and other limited partnerships, such as oil & gas
partnerships, where necessary and appropriate the Client’s investment portfolio. The Advisor may retain certain
legacy investments based on the merit of the investment, portfolio alignment and/or the tax implications.
CIM’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that
have been held for less than one year to meet the objectives of the Client or due to market conditions. CIM will
construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk
tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types
of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
CIM evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence
process. CIM may recommend, on occasion, redistributing investment allocations to diversify the portfolio. CIM may
recommend specific positions to increase sector or asset class weightings. The Advisor may recommend
employing cash positions as a possible hedge against market movement. CIM may recommend selling positions for
reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a
specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in
risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s
risk tolerance. The Advisor’s investment process is intended to have a low portfolio turnover and focus on a well-
diversified portfolio designed to meet the Client’s investment goals, time horizon and attitude towards investment
risk. The Advisor does not recommend leveraged or inverse ETFs or similar leveraged or short securities.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor 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. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the
assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account
to fee-based account). Such a recommendation
creates a conflict of interest if the Advisor will earn a new (or
increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a
retirement account to an account managed by the Advisor.
At no time will CIM accept or maintain custody of a Client’s funds or securities, except for the limited authority as
outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian,
pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Financial Planning Services
CIM will provide a variety of financial planning and consulting services to Clients, either as a component of
investment management services or pursuant to a written financial planning agreement. Services are offered in
several areas of a Client’s financial situation, depending on their goals and objectives.
Generally, such financial planning services involve preparing a formal financial plan, existing portfolio review or
rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or
consulting may encompass one or more areas of need, including but not limited to, investment planning, personal
savings, education savings, insurance needs, business planning, estate planning, net worth analysis, risk analysis
and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
CIM may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation.
For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial
situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide
a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming
all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for
investment management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to
act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
C. Client Account Management
Prior to engaging CIM to provide investment advisory services, each Client is required to enter into one or more
agreements with the Advisor which may include an investment advice agreement and/or financial planning
agreement. The agreements define the terms, conditions, authority and responsibilities of the Advisor and the
Client. These services may include:
● Establishing an Investment Strategy – CIM, in connection with the Client, will develop a strategy that seeks
to achieve the Client’s goals and objectives.
● Asset Allocation – CIM will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
● Investment Management and Supervision – CIM will provide investment management and ongoing
oversight of the Client’s investment portfolio.
● Financial Planning – If engaged by the Client for financial planning services, the Advisor will provide one-
time and/or ongoing planning services which are tailored to the needs of the Client.
D. Wrap Fee Programs
CIM includes securities transaction fees and other fees and expenses as outlined in Appendix 1 (“Wrap Fee
Program Brochure”) together with its investment advisory fees. Including these fees into a single asset-based fee is
considered a “Wrap Fee Program”. The Advisor customizes its investment management services for its Clients.
The Advisor sponsors the CIM Wrap Fee Program solely as a supplemental disclosure regarding the combination
of fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the Client may pay
more or less in total fees than if the Client paid its own transaction fees. Please see the Wrap Fee Program
Brochure, which is included as a supplement to this Disclosure Brochure.
E. Assets Under Management
As of December 31, 2023, CIM manages $124,000,000 in Client assets, all of which are managed on a
discretionary basis. Clients may request more current information at any time by contacting the Advisor.