a. Harvest Investment Consultants, LLC (Advisor or Harvest) has been in business since 1987. The
previous legal names were Harvest Investment Consultants, Inc., and Hickory Capital
Management, Inc. The principal owner is Michael J. Meily, Managing Member.
b. Harvest provides professional fee-based investment management services to private clients and
various types of organizations. We provide portfolio design and active portfolio management for
individuals and families, as well as professional investment management and consulting services
for defined benefit plans, 401(k) retirement plans, endowments, and charitable organizations.
In addition to portfolio management, we offer personalized financial planning services to our
clients, which can be billed at either an hourly rate or flat fee. The fee is disclosed to the client
prior to such engagement (See Section 5 for more information on Fees and Compensation).
Harvest utilizes a modularized approach to the financial planning process. Some areas in which
we may assist clients include retirement planning, retirement income distribution planning,
education planning, insurance analysis, charitable contribution planning, and estate planning. We
approach the financial planning process in the same way as we handle our investment
management services; we spend significant time with clients to fully understand their questions
and objectives. Based upon the needs of each client, we seek to provide an unbiased perspective
and planning guidance that is both practical and functional. We encourage our clients to review
pertinent planning information with us at least annually, and whenever a significant life event or
important change occurs.
c. We focus on designing and managing portfolios using conservative, moderately conservative,
moderate, moderately aggressive, and aggressive strategies. Which strategy or combination of
strategies is used is based upon the needs of each client. Depending on the size and complexity of
the portfolio, a portfolio could be managed in part or in whole by way of a risk-appropriate model.
Portfolios may also be partly or wholly customized depending upon objectives, tax-sensitivity, or
other client-driven needs.
Our portfolios may include a variety of security types such as individual corporate, government,
and municipal bonds, stocks, mutual funds, exchange-traded funds (ETFs), REITs, Certificates of
Deposit (CDs), hybrid securities and preferred stocks. We seek to manage risk on multiple levels
and our investment portfolio focus is on absolute, not relative performance.
Clients may impose certain restrictions on the types of securities used or exclude securities of
certain industries or the direct investment in specific companies. The Advisor, by way of
investment advisor representative and portfolio management team develop an appropriate
investment profile for each client, considering any unique needs or applicable restrictions to be
followed. The client-specific profile in conjunction with interview data and risk tolerance
communications will drive the portfolio design and implementation process at Harvest.
d. Retirement Plan Rollover Recommendations: When Harvest Investment Consultants 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 a IRA or make a distribution from the
retirement plan account, we acknowledge that Harvest Investment Consultants 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 Harvest
Investment Consultants makes money creates conflicts with your interests so Harvest Investment
Consultants operates under a special rule that requires Harvest Investment Consultants to act in your
best interest and not put our interest ahead of you.
Under this special rule’s provisions, Harvest Investment Consultants 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 Harvest Investment Consultants 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 Harvest Investment Consultants gives
advice that is in your best interest;
• Charge no more than is reasonable for the services of Harvest Investment Consultants 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 Harvest Investment Consultants please know that Harvest
Investment Consultants 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 Harvest Investment Consultants. We will earn fewer
investment advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by
Harvest Investment Consultants.
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 , (ii) not recommend investments which result in Harvest Investment
Consultants receiving unreasonable compensation related to the rollover of funds from the retirement
plan to an IRA, and (iii) fully disclose compensation received by Harvest Investment Consultants 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 your 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 Harvest Investment Consultants or our affiliated personnel.
e. Advisor does not participate in wrap fee programs.
f. Assets under management as of December 31, 2023, are as follows:
Discretionary: $448,217,205
Non-Discretionary: $0
Total: $448,217,205