A. 1015 Capital Partners, LLC (the “Registrant”) is a limited liability company formed in
October 2023 in the Commonwealth of Pennsylvania. The Registrant is owned by Mary C.
McNutt and Michelle J. Blass and are Co-Managing Members.
B.
INVESTMENT MANAGEMENT
The Registrant provides discretionary investment advisory services on a fee-only basis. The
Registrant’s annual investment advisory fee is based upon a percentage (%) of the market
value of the client’s assets placed under the Registrant’s management.
The Registrant’s annual investment advisory fee typically includes investment advisory
services and financial planning and consulting services. In the event the client requires
extraordinary planning and/or consultation services (to be determined in the sole discretion
of the Registrant), Registrant may determine to charge for such additional services, the
dollar amount of which shall be set forth in a separate written notice to the client.
Before engaging Registrant to provide investment advisory services, clients are required to
enter into an Investment Advisory Agreement setting forth the terms and conditions of the
engagement (including termination), describing the scope of the services to be provided,
and the fee that is due from the client. Before providing investment advisory services, an
investment adviser representative will ascertain each client’s investment objectives.
Thereafter, Registrant will allocate and/or recommend that the client allocate investment
assets consistent with the designated investment objectives. Once allocated, Registrant
provides ongoing monitoring and review of account performance, asset allocation and
client investment objectives.
FINANCIAL PLANNING AND CONSULTING SERVICES
The Registrant may provide financial planning and/or consulting services (including
investment and non-investment related matters, including estate planning, insurance
planning, etc.) on a stand-alone separate fee basis. Registrant’s planning and consulting
services are offered on a fixed fee basis. The Registrant may also be engaged by a client to
complete a project separate and apart from the Registrant’s core services.
Prior to engaging the Registrant to provide planning or consulting services, clients are
generally required to enter into a Financial Planning and Consulting Agreement with
Registrant setting forth the terms and conditions of the engagement (including
termination), describing the scope of the services to be provided, and the portion of the fee
that is due from the client prior to Registrant commencing services. If requested by the
client, Registrant may recommend the services of other professionals for implementation
purposes. The client is under no obligation to engage the services of any such
recommended professional. The client retains absolute discretion over all such
implementation decisions and is free to accept or reject any recommendation from the
Registrant.
If the client engages any recommended unaffiliated professional, and a dispute arises
thereafter relative to such engagement, the client agrees to seek recourse exclusively from
and against the engaged professional. At all times, the engaged licensed professional[s]
(i.e., attorney, accountant, insurance agent, etc.), and not the Registrant, shall be
responsible for the quality and competency of the services provided.
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.
IMPORTANT DISCLOSURES
Limitations of Financial Planning and Non-Investment Consulting/Implementation
Services. To the extent requested by a client, Registrant may provide financial planning
and related consulting services regarding non-investment related matters, such as estate
planning, tax planning, insurance, etc. The Registrant does not serve as a law firm, an
accounting firm or an insurance agency and no portion of Registrant’s services should be
construed as legal, accounting or insurance services. Accordingly, Registrant does not
prepare estate planning documents or tax returns.
To the extent requested by a client, Registrant may recommend the services of other
professionals for certain non-investment implementation purposes (i.e., attorneys,
accountants, insurance agents, etc.). Clients are reminded that they are under no obligation
to engage the services of any such recommended professional. 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 unaffiliated professional, and a dispute arises
thereafter relative to such engagement, the client agrees to seek recourse exclusively from
and against the engaged professional. At all times, the engaged licensed professional[s]
(i.e., attorney, accountant, insurance agent, etc.), and not the Registrant, shall be
responsible for the quality and competency of the services provided.
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 Registrant recommends that a client roll over their
retirement plan assets into an account to be managed by Registrant, such a recommendation
creates a conflict of interest if Registrant will earn new (or increase its current)
compensation as a result of the rollover. If Registrant provides a recommendation as to
whether a client should engage in a rollover or not (whether it is from an employer’s plan
or an existing IRA), Registrant 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 Registrant, whether it is from
an employer’s plan or an existing IRA.
Independent Managers. The Registrant may allocate (and/or recommend that the client
allocate) a portion of a client’s investment assets among unaffiliated independent
investment managers in accordance with the client’s designated investment objective(s).
In such situations, the Independent Managers shall have day-to-day responsibility for the
active discretionary management of the allocated assets. The Registrant shall continue to
render investment advisory services to the client relative to the ongoing monitoring and
review of account performance, asset allocation and client investment objectives. Factors
which the Registrant shall consider in recommending Independent Managers include the
client’s designated investment objective(s), management style, performance, reputation,
financial strength, reporting, pricing, and research. The investment management fee
charged by the Independent Manager(s) is separate and in addition to the Registrant’s
investment advisory fee.
Private Investment Funds. Registrant also provides investment advice regarding private
investment funds. Registrant, 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. Registrant’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 Registrant calculating its investment advisory
fee. Registrant’s fee shall be in addition to the fund’s fees. Registrant’s clients are under
absolutely no obligation to consider or make an investment in any private investment
fund(s).
Risks: 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 the client 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 Registrant references private investment funds owned by the
client on any supplemental account reports prepared by Registrant, 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, Registrant shall calculate
its fee based upon the latest value provided by the fund sponsor.
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 Registrant), there can be no assurance that investment in ESG securities or
funds will be profitable or prove successful. Registrant 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, Registrant 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.
Client Obligations. In performing its services, Registrant 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 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.
Cash Positions. Registrant treats cash as an asset class. As such, unless determined to the
contrary by Registrant, all cash positions (money markets, etc.) shall continue to be
included as part of assets under management for purposes of calculating Registrant’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), Registrant 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, Registrant’s advisory fee could exceed the interest
paid by the client’s money market fund.
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 Registrant 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 Registrant 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 Registrant 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 Registrant unmanaged
accounts.
Cybersecurity Risk. The information technology systems and networks that Registrant
and its third-party service providers use to provide services to Registrant’s clients employ
various controls, which are designed to prevent cybersecurity incidents stemming from
intentional or unintentional actions that could cause significant interruptions in Registrant’s
operations and result in the unauthorized acquisition or use of clients’ confidential or non-
public personal information. Clients and Registrant 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 Registrant has established procedures to reduce the risk
of cybersecurity incidents, there is no guarantee that these efforts will always be successful,
especially considering that Registrant 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 the Registrant’s written Brochure and Client
Relationship Summary, as set forth on Part 2 of Form ADV and Form CRS respectively,
shall be provided to each client prior to, or contemporaneously with, the execution of the
Investment Advisory Agreement or Financial Planning and Consulting Agreement.
C. The Registrant 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). Thereafter, the
Registrant shall allocate and/or recommend that the client allocate investment assets
consistent with the designated investment objective(s). The client may, at any time, impose
reasonable restrictions, in writing, on the Registrant’s services.
D. The Registrant does not participate in a wrap fee program.
E. As of April 1, 2024, the Registrant had $0 in assets under management on a discretionary
basis.