A. Lee, Danner & Bass, Inc. was founded in 1988 as an independent investment counseling firm
dedicated to providing its Clients with an investment management service of superior quality.
We are registered with the Securities and Exchange Commission under the Investment
Advisors Act of 1940. Our firm is owned in its entirety by its principals and officers and is
not affiliated in any way with any other company. The owners are:
1. Frank Bass II
2. Ernest Williams III
3. Lawson C. Allen
4. Mark B. Smith
5. Frank M. Bass III
6. Fred T. Lowrance, Jr.
B. We provide investment management services of financial assets, to include stocks, bonds,
mutual funds, ETFs, options, and cash equivalent money market instruments.
C. The Client is the focal point around which the entire investment management process
evolves. The process begins with a clear definition of the Client’s individual needs,
objectives and constraints, if any. Factors will include income and liquidity requirements,
expectations of capital enhancement, time horizon and tolerance for risk. A program is then
designed to achieve these objectives. As time passes, conditions change and a Client’s needs
and objectives may change. By maintaining a close working relationship with each Client,
we are able to reflect such change in the Client’s investment portfolio in a timely and
responsive manner. Clients may impose investment restrictions. This may affect account
performance.
D. From time-to-time LDB participates in wrap fee programs by providing portfolio
management services. The Client’s agreement with the wrap program sponsor generally
requires transactions to be executed through the program sponsor’s broker/qualified
custodian and best execution policies of the broker/qualified custodian are utilized. Of the
wrap fee charged to Client accounts, LDB receives a portion of this fee consistent with our
regular fee schedule
E. LDB manages approximately $1,539,122,999 in discretionary investment assets on
December 31, 2023 and $0 in non-discretionary investment assets.
F. Retirement Plan Rollover Recommendations - When LDB provides investment advice about
your retirement plan account or individual retirement account (“IRA”) including whether to
maintain investments and/or proceeds in the retirement plan account, roll over such
investment/proceeds from the retirement plan account to an IRA or make a distribution from
the retirement plan account, we acknowledge that LDB is a “fiduciary” within the meaning
of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal
Revenue Code (“IRC”) as applicable, which are laws governing retirement accounts. The
way LDB makes money creates conflicts with your interests, so LDB operates under a
special rule that requires LDB to act in your best interest and not put our interest ahead of
you.
Under this special rule’s provisions,
LDB must as a fiduciary to a retirement plan account or
IRA under ERISA/IRC:
• Meet a professional standard of care when making investment recommendations (e.g.,
give prudent advice);
• Never put the financial interests of LDB ahead of you when making recommendations
(e.g., give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that LDB gives advice that is in your
best interest;
• Charge no more than is reasonable for the services of LDB; and
• Give Client basic information about conflicts of interest.
To the extent we recommend you roll over your account from a current retirement plan
account to an individual retirement account managed by LDB, please know that LDB and our
investment adviser representatives have a conflict of interest.
We can earn increased investment advisory fees by recommending that you roll over your
account at the retirement plan to an IRA managed by LDB. We will earn fewer investment
advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by
LDB.
Thus, our investment adviser representatives have an economic incentive to recommend a
rollover of funds from a retirement plan to an IRA which is a conflict of interest because our
recommendation that you open an IRA account to be managed by our firm can be based on
our economic incentive and not based exclusively on whether or not moving the IRA to our
management program is in your overall best interest.
We have taken steps to manage this conflict of interest. We have adopted an impartial
conduct standard whereby our investment adviser representatives will (i) provide investment
advice to a retirement plan participant regarding a rollover of funds from the retirement plan
in accordance with the fiduciary status described below, (ii) not recommend investments
which result in LDB receiving unreasonable compensation related to the rollover of funds
from the retirement plan to an IRA, and (iii) fully disclose compensation received by LDB
and our supervised persons and any material conflicts of interest related to recommending the
rollover of funds from the retirement plan to an IRA and refrain from making any materially
misleading statements regarding such rollover.
When providing advice to you regarding a retirement plan account or IRA, our investment
advisor representatives will act with the care, skill, prudence, and diligence under the
circumstances then prevailing that a prudent person acting in a like capacity and familiar with
such matters would use in the conduct of an enterprise of a like character and with like aims,
based on the investment objectives, risk, tolerance, financial circumstances, and a client’s
needs, without regard to the financial or other interests of LDB or our affiliated personnel.