Laffer Tengler Investments, Inc. (hereinafter, “LTI,” the “Firm,” “Our,” or “We”) was incorporated
in 1999 and started managing discretionary accounts in August of 2000. Dr. Arthur B. Laffer and
Arthur B. Laffer, Jr. founded the Firm. Nancy Tengler is the Chief Executive Officer and Chief
Investment Officer. Arthur B. Laffer, Jr. is the President and the Senior Portfolio Manager.
The Firm is organized as a common stock corporation and is currently domiciled in the state of
Tennessee. 100% of the stock is owned by ButcherJoseph Financial Holdings, LLC. Specific
ownership interest information is located on Schedule A and Schedule B of Part 1 of the firm’s
Form ADV.
As of December 31st, 2023, Laffer Tengler Investments managed $462,553,183 in discretionary
assets and provided advice on model portfolio assets in the amount of $724,713,891.
The Laffer Tengler Wealth Management Wrap Program (“Wrap Fee Program”) is one of the
programs Laffer Tengler Investments, Inc. offers. For its wealth management clients, LTI offers an
investment program in which the client pays a single fee for asset management and transaction
costs in their accounts (“Wrap Fee”). Wrap Fees include transaction fees for the purchase or sale
of securities, but do not include expenses related to the use of margin, wire transfer fees, the fees
charged to shareholders of mutual funds or ETFs, mark-ups and mark- downs, spreads, odd-lot
differentials, fees charged by regulatory agencies, and any transaction fees for securities trades
executed by a broker-dealer other than our recommended qualified custodian.
Because of the nature of a Wrap Fee Program, a client may pay more, or less than if the client had
compensated another adviser outside of the Wrap Fee Program. For example, if a client’s account
is rarely traded, the transaction fees that the client would have paid would be minimal, thus
limiting the benefits of “wrapping” management fees and transaction fees.
LTI receives the Wrap Fee for our services. When transaction fees are charged by our
recommended custodian or broker/dealer, we will pay those fees on behalf of our client. The
remainder of the Wrap Fee is the net management fee payable to LTI. The amount payable to us
varies depending upon the trading activity in a client's account. The more transactions in the
account, the greater the amount of transaction fees, and therefore the less compensation to us.
Accordingly, we have a financial incentive to avoid trading the account. This can create a conflict
of interest between the Firm and its Wrap Fee Program clients. We mitigate this conflict by
requiring that the Firm’s employees acknowledge their fiduciary duty to place client interests
ahead of their own and through a review of client accounts.
Services
Clients participating in the Wrap Program shall receive the following services to the extent
applicable to their financial needs:
• Access to an investment adviser representative for financial advice and account service;
• Development of a broadly diversified portfolio with asset classes and investment
selections designed to meet the liquidity and risk characteristics of your financial goals;
• Recommendations of specific investment strategies used to implement your portfolio;
• Assistance setting financial goals and monitoring progress toward goals;
• Quarterly performance reports provided by LTI. This reporting is in addition to the
regular statements you receive from the custodian who holds your assets.
An investment adviser representative will assess your current financial circumstances, taking into
account your tolerance for risk and your investment objectives. An asset allocation structure will
be developed specifically for you to help you toward your long-term financial goals.
LTI will help you implement the recommended asset allocation structure using various
investment strategies managed by LTI’s portfolio managers that will give you exposure to a
diverse mix of equities, fixed income and cash. See ITEM 6: PORTFOLIO MANAGER SELECTION
AND EVALUATION for more information on the investment strategies we offer.
Limited circumstance may warrant allocating a portion of your portfolio to a third-party manager
when LTI does not offer a specific strategy needed to implement the recommended allocation.
In this
case, LTI will provide you with the necessary information about the manager, including
any additional fees you might incur.
Fees
The following discussion represents the basic compensation arrangements of Laffer Tengler
Investments. However, fees and other compensation are negotiable in certain circumstances and
arrangements with any particular client may vary. Each client’s specific fee schedule will be stated
in their Investment Management Agreement.
Unless specifically stated to the contrary, fees will be calculated based upon the aggregate
market value of all assets under management within the client’s account(s), including allocations
to cash (unless a specific cash account is designated as unmanaged). Fees that are calculated as
a percentage of assets under management are generally charged quarterly in arrears.
Laffer Tengler Investments standard fee schedule for this Wrap Fee Program is below.
Client’s Aggregate Portfolio
Management Assets
Annual Fee Rate*
(Applies to all household assets once total Client assets reaches
the specified range below)
Up to $3,000,000 1.15%
$3,000,001 - $5,000,000 1.00%
$5,00,001 - $10,000,000 0.90%
$10,000,001 - $20,000,000 0.75%
Over $20,000,000 Negotiable
Laffer Tengler Investments reserves the right, in its sole discretion, to negotiate and to charge
different fees for certain accounts based on a client’s particular needs or requirements as well as
overall financial condition, goals, risk tolerance and other factors unique to the client’s particular
circumstances.
Clients can elect to have fees owed to Laffer Tengler Investments deducted directly from their
account. In instances where a client has authorized direct billing, the client’s “qualified custodian”
sends periodic statements, no less frequently than quarterly, showing all transactions and
holdings during the period. Clients are urged to review their account statements for accuracy and
compare the information to any reports received directly from Laffer Tengler Investments.
Clients may also request that billings be made directly to the client or a designated third party if
authorized in writing by the client.
A wrap fee arrangement typically covers portfolio management, advisory services, custodian
fees, brokerage commissions and other costs associated with purchase and sale when
transactions are executed through the account custodian. Mark-ups, mark-downs and dealer
spreads are costs borne by the client as they are reflected in the price of the transaction. The
advisory fee does not include other fees such as trade-away fees, account transfer fees, account
maintenance fees, wire fees, interest, or taxes. All fees paid to Laffer Tengler Investments are
separate and distinct from the fees and expenses charged by mutual funds or in conjunction with
internal expenses associated with exchange-traded funds. The client will be solely responsible,
directly or indirectly, for these additional expenses.
Depending on the rate of the wrap fee charged, the amount of account activity, the value of
custodial and other services provided and other factors, the wrap fee may exceed the aggregate
costs of the services provided if they were to be obtained separately and, with respect to
brokerage, transaction-based commissions.
Investment advisory agreements between Laffer Tengler Investments and its clients are generally
terminable at any time by the client or the Firm upon 5-day advance notice by either party to the
other. Clients should review their Investment Management Agreement for the terms and
conditions specific to their account. Termination typically requires that written notice be given
by the terminating party. In the event of termination during a quarterly period, the client will pay
only that portion of the fee earned by Laffer Tengler Investments up to the actual date services
are terminated. To the extent that fees are paid to the Firm in advance and a client terminates
its agreement during the quarterly period, Laffer Tengler Investments will refund to the client a
pro rata portion of the fee paid.
Compensation
Laffer Tengler Investment advisory personnel are not compensated based on your participation
in this Wrap Fee Program; therefore, there is no incentive to recommend this program over other
advisory services we may offer.