NorthStar Asset Management Company, LLC (“NorthStar” or the “Firm”) was formed on August 17, 2023
and is the successor investment adviser to NorthStar Asset Management, LLC, a SEC registered Investment
Adviser since June of 2000. As of December 31, 2023, NorthStar Asset Management, LLC managed
approximately $568 million of which approximately $505 million was managed on a discretionary basis
and approximately $63 million on a non-discretionary basis. On January 1, 2024, NorthStar Investment
Management Company, LLC completed the purchase of the assets of NorthStar Asset Management, LLC.
At the time of the purchase, the Executive Officers and other employees, service contracts, assets and
performance related information of NorthStar Asset Management, LLC was transferred to NorthStar Asset
Management Company, LLC.
NorthStar specializes in the individual management of portfolios for individuals, businesses and charitable
organizations, and pension and profit-sharing plans on either a discretionary or non-discretionary basis.
NorthStar is a limited liability company organized under the laws of the State of Delaware. NorthStar’s
only business is providing investment advisory services based on the individual needs of its clients.
NorthStar is guided by the philosophy that both the creation and preservation of wealth is best attained
through a growth bias and the Firm believes that asset allocations as well as specific holdings within a
portfolio are best determined by matching client objectives with their individual circumstances and risk
tolerances. Investment objectives are achieved through the purchase of individual stocks and bonds,
exchange traded funds, mutual funds, and other unitized investment products.
NorthStar does not participate in any wrap fee programs.
ERISA Fiduciary Services
Services are provided as a fiduciary of specifically designated ERISA plans based on applicable definitions
(contained in ERISA Section 404(a), IRC §4972, the Investment Company Act of 1940 and state laws). In
performing the following
services, NorthStar acts as a fiduciary as defined by ERISA Section 3(21) or
ERISA Section 3(38).
The services provided could include: Investment Advice to the Plan Sponsor, Preparation of the Investment
Policy Statement (IPS), Investment Menu Design, Selection of a Qualified Default Investment Alternative
(QDIA), Performance Monitoring, Performance Reports and Participant Advice.
When NorthStar provides investment advice to you regarding your retirement plan account, individual
retirement account, or other qualified asset under ERISA, we are fiduciaries within the meaning of Title I
of the Employee Retirement Income Security 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 NorthStar operates under a special rule that requires us to act in your best interest and not put our interest
ahead of yours. Clients can engage NorthStar to provide either education or recommendations with respect
to qualified ERISA assets including:
from a qualified plan to an IRA;
from an existing third-party IRA to a NorthStar IRA;
changing the account type of an existing NorthStar IRA;
from a qualified plan to another qualified plan; and
from an IRA to qualified plan rollover.
Such provisions also extend to other qualified assets such as Education Savings Accounts and retirement
annuities. Clients should fully understand all of the conflicts, risks, costs & expenses, as well as potential
benefits associated with moving qualified retirement assets. Clients are under no obligation to accept or
follow NorthStar’s recommendations. In addition to being a conflict of interest, it is also a prohibited
transaction under ERISA and/or the Code when we receive compensation as a result of recommending a
rollover of qualified ERISA assets. In that circumstance, we would comply with the conditions of
exceptions to the prohibited transaction rules (e.g., an applicable prohibited transaction exemption such as
PTE 2020-02).