A. Description of the Advisory Firm
Epogee Capital Management, LLC (hereinafter “ECM”) is a Limited Liability Company
organized in the State of Massachusetts. The firm was formed in March 2024, first became
licensed as an investment adviser in May 2024 and the Managing Partner, Chief
Compliance Officer and sole owner is Jay Warner.
B. Types of Advisory Services
Portfolio Management Services
ECM offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. ECM creates an Investment
Policy Statement for each client, which outlines the client’s current situation (income, tax
levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a
portfolio that matches each client's specific situation. Portfolio management services
include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring
ECM evaluates the current investments of each client with respect to their risk tolerance
levels and time horizon. ECM will request discretionary authority from clients in order to
select securities and execute transactions without permission from the client prior to each
transaction. Risk tolerance levels are documented in the Investment Policy Statement,
which is given to each client.
ECM seeks to provide that investment decisions are made in accordance with the
fiduciary duties owed to its accounts and without consideration of ECM’s economic,
investment or other financial interests. To meet its fiduciary obligations, ECM attempts to
avoid, among other things, investment or trading practices that systematically advantage
or disadvantage certain client portfolios, and accordingly, ECM’s policy is to seek fair and
equitable allocation of investment opportunities/transactions among its clients to avoid
favoring one client over another over time. It is ECM’s policy to allocate investment
opportunities and transactions it identifies as being appropriate and prudent among its
clients on a fair and equitable basis over time.
ECM may direct clients to third-party investment advisers to manage all or a portion of
the client's assets. Before selecting other advisers for clients, ECM will always ensure those
other advisers are properly licensed or registered as an investment adviser. ECM conducts
due diligence on any third-party investment adviser, which may involve one or more of
the following: phone calls, meetings and review of the third-party adviser's performance
and investment strategy. ECM then makes investments with a third-party investment
adviser by referring the client to the third-party adviser. These investments may be
allocated either through the third-party adviser's fund or through a separately managed
account managed by such third-party adviser on behalf of ECM's client. ECM may also
allocate among one or more private equity funds or private equity fund advisers. ECM
will review the ongoing
performance of the third-party adviser as a portion of the client's
portfolio.
Services Limited to Specific Types of Investments
ECM generally limits its investment advice to mutual funds, fixed income securities, real
estate funds, equities, hedge funds, private equity funds, and ETFs, including EWTFs in
commodities sectors. ECM may use other securities as well to help diversify a portfolio
when applicable.
Written Acknowledgement of Fiduciary Status
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.
C. Client Tailored Services and Client Imposed Restrictions
ECM will tailor a program for each individual client. This will include an interview
session to get to know the client’s specific needs and requirements as well as a plan that
will be executed by ECM on behalf of the client. ECM may use one or a combination of
model allocations (conservative, balanced and aggressive growth) and tailors each to the
particular investment profile (including personal restrictions, needs, and targets) of each
of ECM’s clients. When tailoring services to an individual client, including when using
model allocations, ECM looks beyond risk tolerance to understand each client’s financial
goals, time horizon, liquidity needs, and their overall financial conditions. The intent is
to always tailor services to specific needs. Clients may impose restrictions in investing in
certain securities or types of securities in accordance with their values or beliefs. However,
if the restrictions prevent ECM from properly servicing the client account, or if the
restrictions would require ECM to deviate from its standard suite of services, ECM
reserves the right to end the relationship.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees and transaction costs. ECM does not participate in wrap fee
programs.
E. Assets Under Management
ECM has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$0 $0 April 2024