Description of Services and Fees Granite Value Capital, LLC is a fee-only registered investment adviser based in Hanover, New Hampshire. Our firm is organized as a limited liability company under the laws of the State of New Hampshire. We have been providing investment advisory services since 2009. Anthony J. Abbate is our principal owner.
Portfolio Management Services We generally limit our services to discretionary management of investment portfolios in accordance with your individual investment objectives. We may, however, provide financial planning services as part of an all-inclusive service, and that are included as part of the overall management fee (as described below). If you retain our firm for portfolio management services, we will enter into an agreement for services.
If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow our firm 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, a power of attorney, and/or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing.
You may make additions to and withdrawals from your account at any time, subject our right to terminate an account. You may withdraw account assets on notice to our firm, and subject to the usual and customary securities settlement procedures. However, we design our portfolios as long-term investments and asset withdrawals may impair the achievement of your specific investment objectives.
Our annual fee for portfolio management services varies (between 0.60% and 1.00%) depending upon the market value of the assets we manage on your behalf, and the type of investment management services we provide, as follows: PORTFOLIO VALUE ANNUAL FEE Up to $2,500,000.................................................................. 1.00% 2,500,001 to $5,000,000....................................................... 0.85% 5,000,001 to $7,500,000....................................................... 0.75% 7,500,001 to $10,000,000..................................................... 0.65% Over $10,000,000 ……......................................................... 0.60% Our annual portfolio management fee is billed and payable quarterly in arrears based on the value of your account on the last day of the previous quarter. If the agreement for services is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which you are a client.
4 We offer a discount of 20% to non-profit organizations. Certain pre-existing clients may be subject to a different fee schedule. In our sole discretion, we may negotiate to charge a lesser management fee based upon certain criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing client, account retention, pro bono activities, etc.).
Our Agreement and/or the separate agreement you sign with the Financial Institution(s) for custodial and brokerage services may authorize our firm through the Financial Institution(s) to debit your account for the amount of our management fee and to directly remit that management fee to our firm in accordance with applicable custody rules. The Financial Institution(s) we recommend have agreed to send a statement to you, at least quarterly, indicating all amounts disbursed from your account including the amount of management fees paid directly to our firm. You should review all statements for accuracy. We will also receive a duplicate copy of your account statements. Please refer to the Brokerage Practices section below for additional disclosures on the Financial Institutions we recommend.
The Agreement for services will continue in effect until terminated by either party pursuant to the terms of the Agreement. You will incur a pro rata charge for services rendered prior to the termination of the Agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a client. Refunds are not applicable as our fees are payable quarterly in arrears.
Additions to your account may be in cash or securities; however, we expressly reserve the right to liquidate any transferred securities, or decline to accept particular securities into your account. We may consult with you about the options and ramifications of transferring securities. However, you are advised that when transferred securities are liquidated, they are subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or tax ramifications. You are also advised to promptly notify our firm if there are ever any changes in your financial situation or investment objectives or if you wish to impose any reasonable restrictions upon our the management services.
Advisory Services to Retirement Plans and Plan Participants We offer various levels of advisory and consulting services to employee benefit plans ("Plan") and to the participants of such plans ("Participants"). The services are designed to assist plan sponsors in meeting their management and fiduciary obligations to Participants under the Employee Retirement Income Securities Act ("ERISA"). Pursuant to adopted regulations of the U.S. Department of Labor, we are required to provide the Plan's responsible plan fiduciary (the person who has the authority to engage us as an investment adviser to the Plan) with a written statement of the services we provide to the Plan, the compensation we receive for providing those services, and our status.
The services we provide to your Plan are described in the paragraphs above and in the advisory agreement that you sign. Our compensation for these services is described is based on the fee Portfolio Management fee schedule, but may be negotiated at the Plan level based on the size and complexity of the plan and services required. The final negotiated fee will be detailed in the advisory agreement.

We do not reasonably expect to receive any other compensation, direct or indirect, for the services we provide to the Plan or Participants, unless the plan sponsor directs us to deduct our fee from the plan or directs the plan record-keeper to issue payment for our fee out of the plan. If we receive any other compensation for such services, we will (i) offset the compensation against our stated fees, and (ii) we will promptly disclose the amount of such compensation, the services rendered for such compensation and the payer of such compensation to you. 5 Granite Value Capital, LLC is a state registered investment adviser and represents that it is not subject to any disqualification as set forth in Section 411 of ERISA. In performing fiduciary services, we are acting either as a non-discretionary fiduciary of the Plan as defined in Section 3(21) under ERISA, or as a discretionary fiduciary of the plan as defined in Section 3(38) under ERISA, as set forth in the arrangement with each Plan sponsor. Types of Investments We primarily offer advice and allocate your assets among individual equity and debt securities, mutual funds, and exchange traded funds; however, we will also recommend other types of investments as appropriate for you since each client has different needs and different tolerance for risk. We may advise you on any type of investment that we deem appropriate 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. Each type of security has its own unique set of risks associated with it and it would not be possible to list here all of the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with it.
There are numerous ways of measuring the risk of equity securities (also known simply as "equities" or "stock"). In very broad terms, the value of a stock depends on the financial health of the company issuing it. However, stock prices can be affected by many other factors including, but not limited to: the class of stock (for example, preferred or common); the health of the market sector of the issuing company; and, the overall health of the economy. In general, larger, better established companies ("large cap") tend to be safer than smaller start-up companies ("small cap") but the mere size of an issuer is not, by itself, an indicator of the safety of the investment.
Corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same interest rate.
Mutual funds and exchange traded funds (ETFS) are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no load" and charge no fee to buy into, or sell out of, the fund other types of mutual funds do charge such fees which can also reduce returns. Mutual funds can also be "closed end" or "open end". So-called "open end" mutual funds continue to allow in new investors indefinitely which can dilute other investors' interests.
You may request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to our firm in writing. 6 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 an ERISA account to an account that we manage or provide investment advice to, because the assets increase our Assets Under Management and, in turn, our advisory fees. In contrast, we receive less, or no, compensation if assets remain in the current plan or are rolled over to another Company's plan in which you may participate. Assets Under Management As of December 31, 2022, we provide continuous management services for $111,263,085 in client assets on a discretionary basis. We are not currently providing services on a non-discretionary basis.