Crews is an SEC-registered investment adviser and is a wholly-owned subsidiary of Crews Core
Holding Company, a non-bank subsidiary of First Security Bancorp of Searcy, Arkansas. Crews
is an affiliate of First Security Bank of Searcy, Arkansas. Crews is also a Securities and Exchange
Commission (“SEC”) registered broker-dealer that is a member of the Financial Industry
Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). In
addition, Crews is registered as a Municipal Advisor with the SEC and Municipal Securities
Rulemaking Board (MSRB).
Crews offers several advisory programs and services to individuals, trusts, non-profits,
businesses, and other client types. These programs include non-discretionary and discretionary
separately managed accounts. This Brochure describes the services, fees and other
compensation, conflicts of interest, and other information clients should consider prior to
becoming a client of one or more of Crews’ investment advisory wrap fee programs (each, a
“Program” and collectively, the “Programs”).
As a registered investment adviser, Crews is a fiduciary to the firm’s investment advisory clients
and has an obligation to act in good faith, and in the best interest of the client and to place the
client's interests first and foremost. This would include a duty of care, which requires among other
things for advisers to ensure that its investment advice is suitable based on the client’s investment
profile or mandate. As part of a duty of loyalty to clients, advisers must also attempt to eliminate
or make full and fair disclosure of all material facts of any conflicts of interest so a client, or
prospective client, can make an informed decision in each particular circumstance. The structure
of each Program and other internal controls described in this brochure are designed to support
Crews’ ongoing efforts to fulfill its fiduciary duties. This includes actions to either avoid or mitigate
material conflicts of interest which may exist between Crews and its clients, and to provide clients
with required disclosure of these conflicts of interest. Clients and prospective clients should
carefully consider the information set forth in this Brochure in evaluating each of the Programs.
Crews’ Financial Advisers (each, a “Financial Adviser,” and collectively, “Financial Advisers”)
serve as the primary point of contact for Program clients. Clients are encouraged to carefully read
this Brochure in its entirety and contact their Financial Adviser with any questions.
Clients are also encouraged to carefully consider the differences between brokerage and
investment advisory services including our obligations, costs, and the need for the services
provided. For additional information please review the Firm’s Form Client Relationship Summary
(“Form CRS”), which provides information about the differences between Brokerage Accounts
and advisory accounts (including Program accounts). Generally, the Firm and its Financial
Advisers have an incentive to recommend investment advisory services over brokerage services
because the Firm and Financial Adviser could receive higher fees for advisory services than
brokerage services, and higher fees for some advisory programs than others.
Crews Form ADV Parts 2A & B (2023) 5
Level of Services Provided to Clients
Crews sponsors various Programs. The Programs described in this Brochure are provided to clients
in a “wrap fee” arrangement. A wrap fee arrangement is one in which a single fee is charged based
on the market value of assets in the client’s account, rather than on the transactions in the account
as in a commission account (a “Brokerage Account”). In a Brokerage Account, the total costs will
generally increase or decrease as a result of the frequency of transactions in the account and the
type of securities purchased. The wrap fee covers advisory services related to the Programs.
Advisory services generally include investment advice or counsel provided by Crews investment
professionals and/or the client’s financial adviser, portfolio management services provided by one
or more persons or firms who may or may not be affiliated with Crews (each, a “Portfolio Manager”
and, collectively, “Portfolio Managers”), the execution of client transactions, custody services,
account servicing, reporting, and other services. The Programs are either (1) discretionary
(collectively, “Discretionary Programs”), in which a client appoints and authorizes Crews or a third-
party to make investment decisions with respect to the assets in the client’s account (including
authority to buy, sell, or hold securities, as Crews or the third-party manager determines, in its
discretion and without notice to the client); or (2) non-discretionary, in which a client appoints Crews
to provide investment advice and recommendations relating to the assets in the client’s account,
but in which the client retains full authority over the decisions regarding which securities to purchase
or sell, and the timing of those transactions. When working with our clients, we discuss and advise
you of investment options based on your goals, needs, objectives, risk tolerances, and specific
economic situation. Clients have the opportunity to impose restrictions on certain securities or types
of securities.
Crews offers the following three advisory programs:
Individual Investment Services
Crews Investment Advisory - a client-directed, non-discretionary program where you
and your adviser work together on your portfolio using equities, bonds, mutual funds,
exchange traded funds (“ETFs”), and unit investment trusts. Investment recommendations
are based on your goals, needs, objectives, risk tolerances, and specific economic
situation. While the client ultimately makes the investment decisions regarding what to
buy, sell and hold within the account, your financial adviser is there along the way to
provide professional investment advice based on objective research as well as profiling,
asset allocation, investment selection, ongoing monitoring and rebalancing, in
coordination with clients.
Model Portfolio Program
Crews Model Portfolios Advisory - a client-directed, non-discretionary program, in
which you and your adviser work together on your portfolio using model portfolios
consisting of mutual funds and ETFs. Investment recommendations are based on your
goals, needs, objectives, risk tolerances, and specific economic situation. After reviewing
these topics with you, your financial adviser will recommend a Crews Model Portfolio
Crews Form ADV Parts 2A & B (2023) 6
allocation ranging from Aggressive Growth to Capital Preservation. You have the option
of accepting our recommendations, or selecting an alternative model to specifically fit your
needs. Crews will implement your investment decisions, and will not have investment
discretion over your account. We will periodically rebalance your account to maintain your
target asset allocation, but only after discussion with you.
Crews Asset Management Program
CAM assists
clients in developing their investment objectives and creating an Investment
Policy Statement (“IPS”) upon which CAM’s recommendations are based. The main output
of the IPS is the client’s asset allocation strategy, or strategic asset allocation, which
includes identifying the right mix of investments designed to (1) meet the clients’ return
objective and (2) address that the appropriate amount of risk has been assumed. Through
the implementation of the strategic asset allocation, CAM seeks to position clients to
achieve the highest return per unit of risk that is appropriate for their unique circumstances.
CAM selects funds and individual securities for inclusion in client portfolios, and buys and
sells the funds and individual securities to maintain the appropriate investment allocation
for its clients. For more information on discretionary authority, please see Item 16.
Investment Discretion.
CAM advises clients on a wholistic basis to address that the investments made on their
behalf are balanced with respect to all holdings and the clients’ total asset picture when
disclosed by the client.
CAM uses a combination of funds and individual securities to fulfill clients’ strategic asset
allocations. In general, the investment portfolio can be described by two elements:
1. Core Portfolio: discretionary management of Crews’ existing Model Portfolio Program.
Seeks to capture broad market returns for predominately equity and fixed income asset
classes, with the ability to refine investment characteristics such as size, style, sector,
quality, duration, and geographic exposures etc. Asset allocations are designed to attempt
to maximize risk-adjusted returns using long-term capital market assumptions for asset
returns, volatilities and correlations. Investments are primarily concentrated in low-cost
mutual funds and ETFs. Asset allocation is the primary return driver.
2. Satellite Portfolio | Crews Opportunity Strategy: an actively managed, discretionary
investment strategy designed to supplement the Core Portfolio by adding the potential for
return-enhancement. Seeks to capture above-market rates of return by identifying and
purchasing securities trading at steep discounts to internal estimates of intrinsic value.
Investments are predominately in the common equity of publicly traded companies that
are headquartered in the United States, and the portfolio is concentrated in 20-30
individual positions. Security selection is the primary return driver.
These two elements collectively make up the CAM Core-Satellite Strategy. This
combination allows CAM to maintain a competitive cost structure, while also providing
Crews Form ADV Parts 2A & B (2023) 7
clients a greater level of service. All clients for which a return-enhancement strategy is
suitable have access to the Crews Opportunity Strategy under the same customary fee
based on assets under management (AUM), which is described below under Item 5. Fees
and Compensation.
Suitability is in important factor in determining the respective weights for the Core and
Satellite Portfolios in the client’s strategic asset allocation. Many clients benefit from
allocating a portion of their equity exposure to a return-enhancement strategy like the
Crews Opportunity Strategy, as it theoretically increases the expected return per unit of
risk for the overall portfolio. However, some clients because of their unique objectives and
constraints (economic, time horizon, risk tolerance, level of comfort, level of familiarity etc.)
should not invest in return-enhancement strategies. CAM works with clients to determine
the appropriate investment allocation at the outset of the relationship. We discuss the CAM
Core-Satellite Strategy and the Crews Opportunity Strategy in more detail in Item 8.
Methods of Analysis, Investment Strategies and Risk of Loss.
Client portfolios may also vary due to the restrictions that clients put on their accounts. For
more information on client directed restrictions please see Services Tailored to Individual
Client Needs and Client Imposed Restrictions below.
CAM Expanded Advisory Services
Expanded advisory services extend upon the investment management services offered,
adding layers of complexity and oversight required by institutional clients and high net
worth individuals. These services may include selection and oversight of a greater
number of investment managers, monitoring and reporting on all investment accounts,
and providing more comprehensive services such as cash flow forecasting, integrated
asset-liability risk management, heightened governance procedures, and tax planning.
All advisory services, i.e., investment management and expanded advisory services, are
provided under the same customary fee based on assets under management (AUM),
which is described below under Item 5. Fees and Compensation.
In these programs, you will retain the right to: (1) withdraw securities or cash; (2) vote on
shareholder proposals of beneficially-owned security issues, or delegate the authority to vote on
such proposals to another person; (3) be provided, in a timely manner, with a written confirmation
or other notification of each securities transaction, and all other documents required by law to be
provided to security holders; and (4) proceed directly as a security holder against the issuer of any
security in your account and not be obligated to join any person involved in the operation of the
applicable program, or any other client of the applicable program, as a condition precedent to
initiating such proceeding. We will provide you with periodic monitoring and reporting of your
portfolio’s performance no less than annually.
We are engaged in a wide range of securities services. We may also give advice and act in the
performance of our duties to other clients that differ from the advice we give you, or the timing and
Crews Form ADV Parts 2A & B (2023) 8
nature of actions we may take for any of these programs. Additionally, we may be limited in our
ability to divulge or act upon certain information we possess because of investment banking
activities or other confidential sources.
Services Tailored to Individual Client Needs
All of our investment recommendations for program accounts are based on an analysis of your
individual financial need, as stated in the IPS and in accordance with the Risk Tolerance
Questionnaire (See Item 8 “Riskalyze”). They are drawn from research and analysis Crews
believes to be reliable and appropriate to your financial circumstances. The recommendations of
Crews and CAM may be limited if the client does not provide us with accurate and complete
information.
All clients may impose restrictions on investing in certain securities or types of securities, which
is included in Crews’ investment advisory agreement and available for clients to amend at any
time through their investment adviser representative.
Assets Under Management
As of December 31, 2023, Crews manages $94,446,571 assets on a non-discretionary
basis and $17,953,053 assets on a discretionary basis.