Firm Description
Founded in 1994, AMI Asset Management Corporation (AMI) provides investment
management services to individuals, high net worth individuals, pension and profit
sharing plans, trusts, corporations and others. In providing its services, AMI generally
utilizes equity and fixed income securities in its investment strategies and manages
client assets in accordance with their overall investment goals and objectives.
Principal Owners
AMI’s principal owners include William Tanner, Matthew Humiston and Peter Mainstain.
Types of Advisory Services
AMI provides its investment management services on a discretionary basis and
currently offers seven core investment strategies:
1. Domestic Large Cap Growth
2. Domestic Small Cap Growth
3. Domestic Small-Mid Cap Growth
4. Domestic Large Cap Equity Income
5. Government/Corporate Fixed Income (Core Bond)
6. Intermediate Quality Tax Exempt Fixed Income (Muni Bond)
7. High Yield Capital Appreciation
Please refer to Item 8 for further information on our methods of analysis and
investment strategies, including details on the specific risks associated with these
strategies.
Retirement Accounts (DOL PTE 2020-02)
When AMI provides investment advice to clients regarding retirement plan accounts or
individual retirement accounts, AMI 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. The way AMI makes money
create 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 interests 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 the Client’s 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 provide advice that is in
the Client’s best interest;
charge no more than is reasonable for our services, and
give the Client basic information about conflicts of interest.
Client Investment Objective Guidelines
The investment advice provided by AMI is customized to each client’s investment
objectives and restrictions as provided to AMI. For individual and high net worth clients,
AMI memorializes each client’s investment objectives and risk tolerance via a
questionnaire. The information provided in the questionnaire, together with any other
information relating to the client’s overall financial circumstances, will be used by AMI
to recommend the appropriate strategy(ies) for the client. For institutional clients, AMI
provides investment advice based on the client’s guidelines outlined in their investment
policy statement or specific instruction as to the strategy in which the client wants to
invest.
AMI does not assume any responsibility for the accuracy of the information provided by
the client and we are not obligated to verify any information received from the client or
from the client’s other professionals (e.g., attorney, accountant, etc.). Under all
circumstances, clients are responsible for promptly notifying AMI in writing of any
material changes to the client’s financial situation, investment objectives, time horizon,
or risk tolerance. In the event that a client notifies AMI of changes in the client’s
financial circumstances, AMI will review such changes and recommend any necessary
revisions to the client’s portfolio allocation. Advisory representatives are available during
normal business hours to consult with clients.
Tailored Relationships
Model Portfolios
AMI provides purchase and sell recommendations in the form of model portfolios
through a Unified Overlay Management Program (UOMP). AMI
does not enter into a
direct relationship with the clients of these investment platforms and does not provide
administrative portfolio account or account-specific performance reporting services to
those clients. The recommendations that are provided through these programs are used
by the Overlay Managers at their sole discretion.
Pooled Investment Vehicle (“Private Fund”)
AMI also provides discretionary investment management services to non-affiliated
private funds. We manage the pooled assets of each private fund using one or more of
AMI’s investment strategies as directed on the Client Investment Plan form.
Sub-Advisory Arrangements
AMI also has sub-advisory arrangements with unaffiliated third-party advisers
(“Advisers”) whereby AMI provides investment management services to certain of the
Advisers’ clients. The clients only enter into an agreement with the respective
Adviser and not AMI. AMI and each Adviser enter into a sub-advisory agreement.
The investment management services provided by AMI are based on the AMI
investment strategy selected by the third-party adviser and in accordance with each
client’s overall investment guidelines as provided to AMI by the third party adviser.
Wrap Programs
AMI offers its investment strategies to wrap fee programs (each, a “Wrap Program”),
which are sponsored by multi-service financial institutions unaffiliated with AMI (each, a
“Wrap Sponsor”).
Generally, a wrap client selects an investment manager, such as AMI, from a list of Wrap
Sponsor approved investment managers. The selected investment manager will provide
investment management services for the wrap client’s assets allocated to the Wrap
Program. For a single all-inclusive fee (the “Wrap Fee”), a wrap client receives certain
other services provided by the Wrap Sponsor, such as trading execution and custodial
services. AMI receives a portion of the Wrap Fee from the Wrap Sponsor for providing
investment management services to the wrap client. The wrap clients generally enter
into a written agreement with the Wrap Sponsor and not AMI.
Although the types of investment management services that AMI provides to wrap clients
are generally the same as the types of investment management services provided to our
other clients, certain differences may exist. These include: 1) the fact that the Wrap
Sponsor obtains each wrap client’s investment objectives and restrictions and assists in
determining the investment strategy best suited for the wrap client, and 2)
communications regarding the investment management services provided to a wrap
client is between the Wrap Sponsor and the wrap client, with AMI only communicating
with the Wrap Sponsor (unless the wrap client requests otherwise).
AMI does not serve as the sponsor of any wrap programs.
Investment Management Agreement
Prior to the start of any client relationship, AMI enters into an agreement with the
client. The agreement outlines the terms and conditions of the relationship including a
description of the services to be provided by AMI, responsibilities of the client, fees as
well as other standard contractual terms. The agreement between AMI and the client
will continue in effect until terminated by either party pursuant to the terms of the
agreement. AMI’s annual fee shall be prorated through the date of termination as
defined in the agreement and any remaining balance shall be charged to the client, as
appropriate, in a timely manner.
In accordance with Rules 204-3 and 204-5 under the Investment Advisers Act of 1940, as
amended, AMI will provide a disclosure brochure (ADV Part 2A), one or more disclosure
brochure supplements (ADV Part 2B) and a Client Relationship Summary (ADV Part 3)
to each client or prospective prior to or contemporaneously with the execution of the
agreement.
Client Assets Under Management
As of October 31, 2023, AMI had $1,621,735,427 in discretionary assets under
management.