A. Farther Asset Management, LLC (“FAM”) is a limited liability company formed in the
state of Delaware. FAM became registered as an Investment Adviser Firm in June 2023.
FAM is solely owned by Farther, Inc., and Mr. Matthews and Mr. Genser are Farther’s
founding members.
B.
INVESTMENT ADVISORY SERVICES
FAM provides discretionary investment advisory services on a fee basis.
FAM’s algorithm is designed to keep the holdings within each client’s portfolio within a
specified range of the target asset allocation, even when the market prices fluctuate. Client
holdings are rebalanced and dividends are reinvested automatically. In general, FAM will
consider rebalancing whenever the percentage holding of one or more positions fluctuate
5% above or below its target allocation.
The rebalancing process is automated and not limited to number or frequency of
rebalances. As a result, there is a possibility that FAM may sell overrepresented positions
and use the proceeds to buy underrepresented positions to bring portfolios towards its target
allocation without taking into account individual tax consequences or market
circumstances.
It remains the client’s responsibility to promptly notify the Registrant if there is ever any
change in their financial situation or investment objectives for the purpose of reviewing,
evaluating or revising Registrant’s previous recommendations and/or services.
FAM WRAP PROGRAM
FAM sponsors the FAM Wrap Program (the “Program”) through which it offers all of its
discretionary investment management services. The services offered under, and the
corresponding terms and conditions pertaining to, the Program are discussed in the Wrap
Fee Program Brochure, a copy of which is presented to all prospective Wrap Program
participants.
Under the Program, FAM is able to offer participants discretionary investment advisor
services, for a single specified annual Program fee, inclusive of trade execution, custody,
reporting, account maintenance, investment management fees.
The current annual Program fee can generally range up to .35%, depending upon the
complexity of the account, the amount of the client assets in the Program and the
independent/separately managed accounts utilized by the client’s investment portfolio.
The terms and conditions for client participation in the Program are set forth in detail in
the Wrap Fee Program Brochure, which is presented to all prospective Program participants
in accordance with disclosure requirements. All prospective Program participants should
read both the Brochure and the Wrap Fee Program Brochure, and ask any corresponding
questions that they may have, prior to participation in the Program.
As indicated in the Wrap Fee Program Brochure, participation in the Program may cost
more or less than purchasing such services separately. When managing a client’s account
on a wrap fee basis, FAM shall receive as payment for its asset management services, the
balance of the wrap fee after all other non-excluded costs incorporated into the wrap fee
have been deducted. As also indicated in the Wrap Fee Program Brochure, the Program fee
charged by FAM for participation in the Program may be higher or lower than those
charged by other sponsors of comparable wrap fee programs.
Wrap Program-Conflict of Interest. Under FAM’s wrap program, the client generally
receives investment advisory services, the execution of securities brokerage transactions,
custody and reporting services for a single specified fee. When managing a client’s account
on a wrap fee basis, FAM shall receive as payment for its investment advisory services,
the balance of the wrap fee after all other costs incorporated into the wrap fee have been
deducted.
Because wrap program transaction fees and/or commissions are being paid by FAM to the
account custodian/broker-dealer, FAM has an economic incentive to maximize its
compensation by seeking to minimize the number of trades in the client's account.
MISCELLANEOUS
No Financial Planning or Non-Investment Consulting/Implementation Services. FAM
does not provide financial planning and related consulting services regarding non-
investment related matters, such as estate planning, tax planning, insurance, etc. FAM does
not serve as an attorney, accountant, or insurance agency, and no portion of our services
should be construed as legal, accounting, or insurance implementation services.
Accordingly, we do not prepare estate planning documents, tax returns or sell insurance
products.
The client retains absolute discretion over all such implementation decisions and is free to
accept or reject any recommendation made by Registrant or its representatives. If the client
engages any recommended professional, and a dispute arises thereafter relative to such
engagement, the client agrees to seek recourse exclusively from and against the engaged
professional.
Cash Positions. FAM continues to treat cash as an asset class. As such, unless determined
to the contrary by FAM, all cash positions (money markets, etc.) shall continue to be
included as part of assets under management for purposes of calculating FAM’s advisory
fee. At any specific point in time, depending upon perceived or anticipated market
conditions/events (there being no guarantee that such anticipated market conditions/events
will occur), FAM may maintain cash positions for defensive purposes. In addition, while
assets are maintained in cash, such amounts could miss market advances. Depending upon
current yields, at any point in time, FAM’s advisory fee could exceed the interest paid by
the client’s money market fund.
When the account is holding cash positions, those cash positions will be subject to the same
fee schedule as set forth below.
Cash Sweep Accounts. Certain account custodians can require that cash proceeds from
account transactions or new deposits, be swept to and/or initially maintained in a
specific custodian designated sweep account. The yield on the sweep account will
generally be lower than those available for other money market accounts. When this
occurs, to help mitigate the corresponding yield dispersion FAM shall (usually within 30
days thereafter) generally (with exceptions) purchase a higher yielding money market fund
(or other type security) available on the custodian’s platform, unless FAM reasonably
anticipates that it will utilize the cash proceeds during the subsequent 30-day period to
purchase additional investments for the client’s account. Exceptions and/or modifications
can and will occur with respect to all or a portion of the cash balances for various reasons,
including, but not limited to the amount of dispersion between the sweep account and a
money market fund, the size of the cash balance, an indication from the client of an
imminent need for such cash, or the client has a demonstrated history of writing checks
from the account.
The above does not apply to the cash component maintained within a FAM actively
managed investment strategy (the cash balances for which shall generally remain in the
custodian designated cash sweep account), an indication from the client of a need for access
to such cash, assets allocated to an unaffiliated investment manager and cash balances
maintained for fee billing purposes.
The client shall remain exclusively responsible for yield dispersion/cash balance decisions
and corresponding transactions for cash balances maintained in any FAM unmanaged
accounts.
Unaffiliated Private Investment Funds. FAM also provides investment advice regarding
private investment funds. FAM, on a non-discretionary basis, may recommend that certain
qualified clients consider an investment in private investment funds, the description of
which (the terms, conditions, risks, conflicts and fees, including incentive compensation)
is set forth in the fund’s offering documents. FAM’s role relative to unaffiliated private
investment funds shall be limited to its initial and ongoing due diligence and investment
monitoring services. If a client determines to become an unaffiliated private fund investor,
the amount of assets invested in the fund(s) shall be included as part of “assets under
management” for purposes of FAM calculating its investment advisory fee. FAM’s fee
shall be in addition to the fund’s fees. FAM’s clients are under absolutely no obligation to
consider or make an investment in any private investment fund(s).
Private investment funds generally involve various risk factors, including, but not limited
to, potential for complete loss of principal, liquidity constraints and lack of transparency,
a complete discussion of which is set forth in each fund’s offering documents, which will
be provided to each client for review and consideration. Unlike liquid investments that a
client may own, private investment funds do not provide daily liquidity or pricing. Each
prospective client investor will be required to complete a Subscription Agreement,
pursuant to which the client shall establish
that he/she is qualified for investment in the
fund, and acknowledges and accepts the various risk factors that are associated with such
an investment.
Valuation. In the event that FAM references private investment funds owned by the client
on any supplemental account reports prepared by FAM, the value(s) for all private
investment funds owned by the client shall reflect the most recent valuation provided by
the fund sponsor. However, if subsequent to purchase, the fund has not provided an
updated valuation, the valuation shall reflect the initial purchase price. If subsequent to
purchase, the fund provides an updated valuation, then the statement will reflect that
updated value. The updated value will continue to be reflected on the report until the fund
provides a further updated value.
As result of the valuation process, if the valuation reflects initial purchase price or an
updated value subsequent to purchase price, the current value(s) of an investor’s fund
holding(s) could be significantly more or less than the value reflected on the report. Unless
otherwise indicated, FAM shall calculate its fee based upon the latest value provided by
the fund sponsor.
Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client
leaving an employer typically has four options regarding an existing retirement plan (and
may engage in a combination of these options): (i) leave the money in the former
employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is
available and rollovers are permitted, (iii) roll over to an Individual Retirement Account
(“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age,
result in adverse tax consequences). If FAM recommends that a client roll over their
retirement plan assets into an account to be managed by FAM, such a recommendation
creates a conflict of interest if FAM will earn new (or increase its current) compensation
as a result of the rollover. If FAM provides a recommendation as to whether a client should
engage in a rollover or not, FAM is acting as a fiduciary 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. No client is under any
obligation to roll over retirement plan assets to an account managed by FAM.
Account Aggregation Reporting Services. FAM uses account aggregation software,
which can incorporate client investment assets that are not part of the assets that FAM
manages (the “Excluded Assets”). Unless agreed to otherwise, in writing, the client and/or
their other advisors that maintain trading authority, and not FAM, shall be exclusively
responsible for the investment performance of the Excluded Assets. Unless also agreed to
otherwise, in writing, FAM does not provide investment management, monitoring or
implementation services for the Excluded Assets. The client can engage FAM to provide
investment management services for the Excluded Assets pursuant to the terms and
conditions of the Investment Advisory Agreement between FAM and the client.
Socially Responsible (ESG) Investing Limitations. Socially Responsible Investing
involves the incorporation of Environmental, Social and Governance (“ESG”)
considerations into the investment due diligence process. ESG investing incorporates a set
of criteria/factors used in evaluating potential investments: Environmental (i.e., considers
how a company safeguards the environment); Social (i.e., the manner in which a company
manages relationships with its employees, customers, and the communities in which it
operates); and Governance (i.e., company management considerations). The number of
companies that meet an acceptable ESG mandate can be limited when compared to those
that do not and could underperform broad market indices. Investors must accept these
limitations, including potential for underperformance. Correspondingly, the number of
ESG mutual funds and exchange-traded funds are limited when compared to those that do
not maintain such a mandate. As with any type of investment (including any investment
and/or investment strategies recommended and/or undertaken by FAM), there can be no
assurance that investment in ESG securities or funds will be profitable or prove
successful. FAM does not maintain or advocate an ESG investment strategy but will seek
to employ ESG if directed by a client to do so. If implemented, FAM shall rely upon the
assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate
account portfolio manager to determine that the fund’s or portfolio’s underlying company
securities meet a socially responsible mandate.
Use Mutual Funds and Exchange Traded Funds. FAM may recommend that clients
allocate investment assets to publicly available mutual funds and/or ETFs that the client
could obtain without engaging FAM as an investment adviser. However, if a client or
prospective client determines to allocate investment assets to publicly available mutual
funds or ETFs without engaging FAM as an investment adviser, the client or prospective
client would not receive the benefit of FAM’s initial and ongoing investment advisory
services.
Portfolio Activity. FAM has a fiduciary duty to provide services consistent with the
client’s best interest. As part of its investment advisory services, FAM will review client
portfolios on an ongoing basis to determine if any changes are necessary based upon
various factors, including, but not limited to, investment performance, fund manager
tenure, style drift, account additions/withdrawals, and/or a change in the client’s
investment objective. Based upon these factors, there may be extended periods of time
when FAM determines that changes to a client’s portfolio are neither necessary nor
prudent. Clients nonetheless remain subject to the fees described in Item 5 below during
periods of account inactivity.
Client Obligations. In performing its services, FAM shall not be required to verify any
information received from the client or from the client’s other professionals, and is
expressly authorized to rely thereon. Moreover, each client is advised that it remains their
responsibility to promptly notify FAM if there is ever any change in their financial situation
or investment objectives for the purpose of reviewing, evaluating or revising FAM’s
previous recommendations and/or services.
Cybersecurity Risk. The information technology systems and networks that FAM and its
third-party service providers use to provide services to FAM’s clients employ various
controls, which are designed to prevent cybersecurity incidents stemming from intentional
or unintentional actions that could cause significant interruptions in FAM’s operations and
result in the unauthorized acquisition or use of clients’ confidential or non-public personal
information. Clients and FAM are nonetheless subject to the risk of cybersecurity incidents
that could ultimately cause them to incur losses, including for example: financial losses,
cost and reputational damage to respond to regulatory obligations, other costs associated
with corrective measures, and loss from damage or interruption to systems. Although FAM
has established procedures to reduce the risk of cybersecurity incidents, there is no
guarantee that these efforts will always be successful, especially considering that FAM
does not directly control the cybersecurity measures and policies employed by third-party
service providers. Clients could incur similar adverse consequences resulting from
cybersecurity incidents that more directly affect issuers of securities in which those clients
invest, broker-dealers, qualified custodians, governmental and other regulatory authorities,
exchange and other financial market operators, or other financial institutions.
Disclosure Statement. A copy of FAM’s written Brochure as set forth on Part 2 of Form
ADV and Client Relationship Summary as set forth in Form CRS shall be provided to each
client prior to, or contemporaneously with, the execution of the Investment Advisory
Agreement.
C. FAM shall provide investment advisory services specific to the needs of each client. Prior
to providing investment advisory services, an investment adviser representative will
ascertain each client’s investment objective(s).
D. As discussed above, FAM only provides its investment management services on a wrap
fee basis. If a client determines to engage FAM, the client will pay a single fee for bundled
services (i.e., investment advisory, brokerage, custody) (See Item 4.B). The services
included in a wrap fee agreement will depend upon each client’s particular need.
When managing a client’s account on a wrap fee basis, FAM shall receive as payment for
its investment advisory services, the balance of the wrap fee after all other costs
incorporated into the wrap fee have been deducted.
E. As of December 31, 2023, FAM had $40,218,511 in assets under management on a
discretionary basis.