A. Description of Firm
Vault Capital, ("Vault" or the "Firm") is a Malibu, California based investment management firm and
registering broker-dealer founded in 2023. Vault provides customized investment management services
to individuals, high net worth clients, small businesses, and profit-sharing plans. As discussed more fully
below, Vault assists clients in investment management and consultation, determination of financial
objectives, identification of financial problems, cash flow management, tax planning, insurance review,
education funding, retirement planning, and estate planning. Some of the investment instruments Vault
offers its clientele include, among other things, mutual funds, exchange traded funds ("ETFs"), equities,
bonds, treasuries, options and/or limited partnership interests. Additionally, some of the mutual funds,
ETFs or limited partnership interests the Firm recommends to clients may invest in real estate.
Vault is currently registered with the Securities and Exchange Commission ("SEC") as an investment
adviser and is registered with the State of Delaware as a C-Corporation. The Firm intends to conduct
business primarily in California. Vault is 60% owned by Thor Visher (a firm Principal and Partner),
20% owned by Terry Au (a firm Partner) and 20% owned by Valentine Gonzalez (a firm Partner).
B. Types of Advisory Services Offered
Vault primarily provides Portfolio Modeling and Investment Management Services exclusively by an
online website. The combination of these services is called Wealth Management Services. Each of these
services is described more fully below. All customers may login and access their account online at
https://www.interactivebrokers.com/en/home.php, Vault’s primary clearing/custodial firm for advisory
accounts, offering access to trade in 150 markets.
1. Portfolio Modeling
Vault offers clients Portfolio Modeling services that encompass the traditional asset classes of fixed
income, domestic equities, and foreign securities, but can also include alternative asset classes as
well. The Firm may manage a client's investment portfolio on a discretionary basis and may assist the
client in the establishment of the necessary custodial account(s). When exercising its discretionary
authority, Vault will make appropriate "buy, sell, hold" decisions as it believes they are needed using
the Firm's asset allocation methodology and based on a program that analyses the client's financial
circumstances, risk tolerance and investment objectives. Using an asset allocation approach, the Firm
provides Portfolio modeling based on a personalized understanding of each client's independent
investment objectives. These services are provided exclusively by Interactive Brokers online portal.
The Portfolio Modeling services typically begin through the gathering of information vis-a-vis a
new Investment Policy Statement, or other similar documentation process. Based upon this
information, the Firm programs select the appropriate allocation for the client's assets.
2. Investment Management Services
Vault offers clients Investment Management Services that encompass the traditional asset classes of
fixed income, domestic equities, and foreign securities, but can also include alternative asset classes
as well. The Firm may manage a client's investment portfolio on a discretionary basis and may assist
the client in the establishment of the necessary custodial account(s). When exercising its
discretionary authority, Vault will make appropriate "buy, sell, hold" decisions as it believes they are
needed using the Firm's asset allocation methodology. Using an asset allocation approach, the Firm
provides Investment Management Services based on a personalized understanding of each client's
independent investment objectives. These services are provided exclusively by Interactive Brokers
online portal.
The Firm's Investment Management Services typically begin through the gathering of information
vis-a-vis a new Investment Policy Statement, or other similar documentation process. Based upon
this information, the Firm selects the appropriate allocation for the client's assets.
The Firm employs a defined process for each step in the investment management cycle including goal
setting and risk/return profiling, asset allocation modeling, investment selection and implementation,
and ongoing monitoring and reporting. This approach helps to provide a robust process to provide
long-term investment solutions. Depending upon the strategy selected by the Firm and the client,
Vault may invest client assets in various sectors and securities, including but not limited to mutual
funds, ETFs, stocks, bonds, treasuries, private funds and/or real estate investment trusts ("REITs").
Please refer to Item 8 for more information on Vault's investment strategies, methods of analysis and
their associated risks of loss.
As noted above, Vault may manage client assets on a fully discretionary basis. In exercising full
discretionary authority, Vault or its trading program selects, without first obtaining client's
permission, (1) the securities to be bought and sold; and (2) the amounts of securities to be
transacted and whether it will be individually, or block traded. Vault's discretionary authority may
be subject to conditions imposed by a client. This may occur when a client restricts or prohibits
transactions in a security for a specific company or for an industry sector, or requests that
the Firm
place trades with a specific broker-dealer (aka "directed brokerage"). For more information on the
Firm's discretionary authority and brokerage practices please refer to Items 12 and 16.
Clients are allowed to impose reasonable restrictions on the types of securities, sectors and/or
industries they do not want to be included in their portfolio. Such restrictions must be communicated
to the Firm in advance and documented in writing. Once this information is gathered initially, each
client is responsible for informing Vault in writing of any
changes to these restrictions or to their overall investment objectives. The Firm does not assume any
responsibility for the accuracy of the information provided directly by its clients or the failure of clients
to inform the Firm of changes to their investment or financial objectives.
3. Wealth Management Services
Wealth Management Services refers to the combination of Brokerage and Investment Management
Services, as each is described above. Fees for Wealth Management Services are defined below under
Item 5: Fees and Compensation. Any implementation of the recommendations made by the Firm
during rendering its Wealth Management Services is entirely at the client's discretion. Clients are
advised that a potential conflict of interest exists if Vault recommends its own Investment Management
Services for the implementation of the recommendations contained in the model portfolio.
4. Educational Seminars
From time to time, Vault may offer educational workshops to clients and their guests, providing general
information on the market and the risks/benefits of investing in different asset classes.
C. General Information About Vault's Advisory Services
1. Gathering Individual Client Information
As explained above, Investment Management Services provided by Vault are customizable based
upon the individual needs, objectives, and other financial goals of the client. Early in the
relationship, Vault will typically memorialize each client's investment objectives, risk tolerance, time
horizons and other important and necessary information, including any investment guidelines, in the
client's Investment Policy Statement. This information, together with any other information relating
to the client's overall financial circumstances, will be used by the Firm to determine the most
appropriate asset allocation and investment strategy to best meet the client's financial goals. There
may be times when certain restrictions are placed by a client which prevent the Firm from accepting
or continuing to service the client's account. Vault reserves the right to not accept and/or terminate a
client's account if it feels that the client-imposed restrictions would limit or prevent it from meeting
and/ or maintaining its objectives.
Vault will not assume any responsibility for the accuracy of the information provided by the client.
The Firm is not obligated to verify any information received from the client or from the client's other
professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such
information. Under all circumstances, clients are responsible for promptly notifying the Finn in
writing of any material changes to the client's financial situation, investment objectives, time
horizon, or risk tolerance. If a client notifies the Firm of changes in the client's financial
circumstances, Vault will review such changes and may recommend revisions to the client's
portfolio.
2. Advisory Agreements
Prior to engaging Vault to provide investment advisory services, the client will be required to enter into a
written agreement ("Client Agreement") with the Firm setting forth the fees to be charged and the terms
and conditions under which it will render its services. Vault will provide a Brochure and one or more
Brochure Supplements to each client or prospective client prior to or contemporaneously with the
execution of a Client Agreement. The advisory relationship will continue until terminated by the client or
Vault in accordance with the provisions of the Client Agreement, including that 1) the investment
advisor, or an affiliate person of the investment advisor, may receive commissions from the sale of
insurance or will receive fees or compensation from the sale or securities or other products or services
recommended by the model portfolio or otherwise has a conflict of interest; 2) the client is under no
obligation to act on the investment adviser’s or associated person’s investment program; 3) if the client
elects to act on any of the recommendations, the client is under no obligation to effect the transaction
through the investment advisor or the associated person when such person is employed as an agent with a
licensed broker-dealer or is licensed as a broker-dealer or through any associate or affiliate of such
person.
D. Wrap-Fee Programs
Vault may provide portfolio management services to wrap fee programs for qualified
customers, as that term is defined the instructions to Form ADV Part 2.
• As an investment advisor Vault may offer scaled fees and wrap fee programs.
• Asset-based fees (1-5%) associated with the wrap fee program will include most transaction costs.
E. Assets Under Management
As of December 31, 2022, the following represents the amount of client assets under management by
Vault on a discretionary and non-discretionary basis:
Type of Account Assets Under Management
("AUM")
Discretionary NIA
Non-Discretionary NIA
Total: NIA